Anti-corruption Policy

The anti corruption system

The fight against corruption is one of the main challenges of our times, from a financial, political and social viewpoint. Based on our cultural system and deeply rooted values, we have decided to expand and strengthen, where necessary, our in-house control system with an anti-corruption system, valid for all of our Italian and foreign companies and in line with international standards, which refer to ISO 37001:2016.

Between 2017 and 2018, we were one of the first companies in Italy to get an "Anti-corruption System" and an "Anti-corruption Policy" which measure the level of exposure to the risk of corruption and identify measures to prevent and reduce their occurrence.

In 2019 the Anti-Corruption Policy and System were updated to take account of the Group's entry into the solar sector and specific rules of conduct were introduced with regard to relations with the Public Administration, the whistleblowing system and the adoption of a specific Due Diligence Procedure for significant third parties.

The latter ensures that specific controls are carried out on significant third parties (suppliers, clients, partners, etc.), with the aim of guaranteeing ERG's adequate knowledge of these third parties and mitigating any tangible risks identified, helping the management to decide whether to embark on a contractual relationship with the same through the involvement of Compliance 231. To guarantee the effectiveness of the System, specific training activities are organised for the top management and personnel of all levels on the contents of the Policy and anti-corruption procedures. The System is also monitored through specific audits and tests on activities susceptible to the risk of corruption, which are performed by the Internal Audit Department.
Anti-corruption Policy
Approved by the Board of Directors of ERG SpA on 2nd August 2019
Politique de lutte contre la corruption
Approuvée par le Conseil d'administration d'ERG S.p.A. le 2 août 2019
Antikorruptionsrichtlinien
genehmigt vom Vorstand von ERG S.p.A. am 02. August 2019

How to report

ERG provides two dedicated channels of communication for anybody that wants to report a crime or a violation of the Code of Ethics, the Organisation and Management Models pursuant to Legislative Decree 231/01 or the Anti-Corruption Policy: an email address and a regular postal address, adopting suitable tools for guaranteeing the confidentiality of the identity of the reporter and the subject of the report when managing the report.

ERG identifies the subjects - Supervisory Committees, Compliance 231 - which, according to the issues reported, are in charge of examining and investigating, also with the help of the Internal Audit, the reports received, verifying and ensuring that whoever makes a report in good faith is not subject to any form of retaliation, discrimination or penalisation, direct or indirect, and protecting their identity, without prejudice to legal obligations or the protection of the Company's rights or those of persons accused wrongly and/or in bad faith. Reports received will be examined and investigated if substantiated and founded on precise and agreed facts.

Any substantiated anonymous reports (containing all the objective details required to move to the next verification phase) are taken into consideration for further investigation.

ERG shall issue penalties to anyone that violates the confidentiality of the reporter and/or the subject of the report. If the reports are found to be groundless or evidently unfounded, they will be filed away together with a specifically drafted report.
 
Reports on potential violation must be sent using the dedicated e-mail address
compliance231@erg.eu  

or by ordinary post by writing to Compliance 231 ERG Group. via De Marini, 1 - 16149 Genoa


The result and impact on business

The solution we have adopted enables us to:
  • guarantee compliance with different anti-corruption standards, with an approach common to all companies in the Group and in keeping with international standards;
     
  • provide stakeholders with a further guarantee of business sustainability, integrity, business ethics and compliance with current regulations;
     
  • strengthen the in-house control system, supplementing it and avoiding inefficiency and doubling of controls;
     
  • ensure ongoing improvement of anti-corruption compliance.