Corruption Prevention Policy
Corruption Prevention Policy
Fully aware of the negative effects of corrupt practices on the economic and social development in the area in which it operates, the FININC GROUP adopts a firm and strictly prohibitive approach to any form of corruption.
Hence the prevention of corrupt practices, in addition to being a legal requirement, is one of the fundamental principles underlying the actions of the FININC GROUP.
As a concrete demonstration of its commitment in this respect, in addition to adopting this policy, the FININC GROUP requires that its subsidiaries (INC S.p.A., SIS S.c.p.a., SIPAL S.p.A.) adopt:
- a Code of Ethics that defines the values and principles to which the FININC GROUP companies aspire, and which they undertake to respect in pursuing their mission;
- a Corruption Prevention Management System in accordance with UNI ISO 37001;
- an Organization and Management Model in accordance with Legislative Decree 231/2001;
The FININC GROUP prosecutes any corrupt conduct, demands compliance with the law and undertakes to adopt and enforce the Corruption Prevention Management System with a view to increasing the awareness of all Stakeholders of the regulations and the conduct that must be respected.
The FININC GROUP therefore bases its operations, conduct and modus operandi, whether in internal relations or relations with third parties, on propriety, fairness, integrity, loyalty and professional rigour, centred on full respect for the law and compliance with company procedures.
In their activities, company personnel are required to abide by the principles of transparency, clarity, correctness, integrity and fairness; any conduct or practice that may even simply appear illegal or collusive, or payments that may appear illicit, favouritism, direct or indirect solicitation for personal or career advantage to oneself or others, are strictly prohibited in all business relations.
The FININC GROUP undertakes to continuously improve its Corruption Prevention Management System and guarantees the authority (defined through the responsibilities attributed to the function and made known to all company personnel) and independence (guaranteed by non-involvement in activities identified at risk of corruption) of the Corruption Prevention Compliance Department.
In the event of corrupt conduct or infringement of anti-corruption law, all personnel operating in the name and on behalf of the FININC GROUP are aware they would be committing offences punishable not only under criminal law, but under corporate by-laws as well. The companies of the FININC GROUP therefore require all “Business Partners” to comply with the laws in effect, the company ethical codes and this Policy, through clauses for which non-compliance implies termination of contract.
Considering the institution of whistleblowing as effective in combating corruption, FININC GROUP companies encourage whistleblowing on potential corruption through a specific “whistleblowing” procedure, which governs the management and verification of reports, guaranteeing confidentiality of the content, the identity of the whistleblower and the person reported, to protect the whistleblower from any discrimination or retaliation.
Management has given this Policy the highest levels of diffusion throughout the organisation, and assures that it is understood and implemented by all personnel; it will also be available on the corporate websites, for this purpose.