Anticorruption Governance in Italy and Abroad
We have chosen to conduct our business according to the highest national and international Corporate Governance standards: we are therefore committed to apply and rigorously respect the principles of lawfulness, integrity, impartiality and transparency. These principles are even more important when we
must deal in practical terms with the problem of corruption.
This is a global phenomenon, which irreparably destroys the integrity of companies, both public and private, and against which national and supranational institutions increasingly concentrate their preventive and repressive efforts.
Amongst the Anti-corruption tools, the Model 231 (for companies under Italian law) and the Anti-corruption Guidelines (for companies
under foreign laws) are the most important; both documents were drafted according to the guidelines of the Group's Code of Ethics.
In 2016, in view of the Group's increasing operations abroad and the growing need to prevent corruption, we carried out a study on the anti-corruption regulations applied in the countries of interest, to assess the advisability of improving our current Anti-corruption Guidelines.
In 2017, we will carry out a new risk assessment to update the activities performed by the companies that do business abroad, and which expose them to corruption risk and on that basis we will consider changes and/or additions to the above-mentioned Guidelines. After completing the analysis, we will set up specific training for our personnel. Model 231 and Anti Corruption Guidelines
The principles of this Model are based on our Code of Ethics and ensure that our day-to-day business is managed in a correct, transparent and traceable manner.
The general part:
• defines the overall structure of the Model in relation to the content of the decree and the specific aspects of the company's business;
• describes the offences and sanctions set out in the decree;
• identifies the Supervisory Committee of the Company and defines its responsibilities and powers;
• defines the training and information activities and the system of sanctions to be applied in case of violations.
The special part defines the rules to be followed in the context of the sensitive activities carried out.
The Supervisory Committee is tasked with overseeing the observance of the Code of Ethics and guaranteeing the implementation of the Model (for example by implementing specific information flows and on the basis of the outcome of Model 231 and audit monitoring programmes), as well as identifying the need for
In this context, during 2016, ERG Hydro (the owner of hydroelectric assets) adopted its Model 231 and the Models 231 of some of the Group's companies were updated, also in order to simplify their structure and make it easier for the risk owners to apply them and comply with them.