Italian Legislative Decree 231/2001

Download PDF: D. Lgs. 231 e Organismo di Vigilanza


Code of Ethics

Leonardi & C. S.p.A in carrying out its activities complies with the laws and regulations in force in all of the countries where it does business. The Company acts in observance of the principles of liberty, dignity of the human person and respect for diversity, rejecting any discrimination based on gender, race, language, personal and social conditions, and religious and political beliefs. The Company seeks to build its own growth by strengthening an image that is true to the values of fairness and loyalty. It believes therefore that the respect for ethical rules and transparency in the conduct of business is a necessary condition, as well as a competitive advantage, in order to pursue and achieve its objectives. To this end, Savino Del Bene S.p.A. promotes the creation of an environment featuring a strong sense of ethical integrity, in the firm belief that such an aspect is crucial for the effectiveness of policies and control systems, affecting conduct that might otherwise escape most sophisticated supervision systems..

Therefore, the Company has adopted a document, called 'Code of Ethics' which governs the rights, duties and responsibilities that Leonardi & C. S.p.A. assumes while performing its corporate activities towards all stakeholders that deal with it directly or indirectly and that are capable of influencing its activity or are influenced by it.

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Anti Bribery guidelines

These Anti-Bribery Guidelines are a policy document issued by the company's top management to identify and set up anti-corruption strategies by specifically analysing the risks of bribery that can be actually identified in the company and by drawing up relevant protocols, regarded as organisational tools to prevent the risk of bribery. The aim of the Anti-Bribery Guidelines therefore is to identify specific ethical and behavioural rules for combating bribery, which establish as illegal all of those activities carried out by employees, consultants and associate workers for or on behalf of the company, which allow the latter, either directly or indirectly, to achieve an illegal interest and/or advantage. The effective and tangible implementation of the Anti-Bribery Guidelines is ensured not only through adequate personnel reporting/training but also by using a system of specific surveys and/or by gathering and analysing information, reports and violations. In order to ensure effective application of the document, disciplinary measures are applied in the event of a breach, regardless of whether these breaches have actually led to corrupt behaviour or have exposed the Company to sanctions. Leonardi & C. S.p.A. does not accept any form of bribery and is committed to abiding by the anti-bribery laws in force in all countries in which it operates. The purpose of the Guidelines is to guarantee principles of transparency and to ensure clarity with regard to permitted conduct and compliance with relevant anti-bribery legislation wherever Savino Del Bene conducts its business.

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Supervisory committee and Whistleblowing

Leonardi & C. S.p.A. has created a digital space to offer employees and all citizens the possibility of reporting any or alleged unlawfulness about which they have come to know. Leonardi & C.S.p.A. has always been particularly attentive to the prevention of risks which could compromise the responsible and sustainable management of its business. For this reason, adhering to the ANAC indications, the Reporting Procedure - Whistleblowing portal has been created. It is a web tool available for all who wish to report situations which could cause damage or detriment to the company, like fraud, generic risks or a potentially dangerous situation.

The portal is part of the internal control tools adopted by the Leonardi & C. S.p.A. in order to prevent corruption, guarantee honesty and transparency when conducting business and in the activities carried out, and protect its standing and reputation

The reports must be made in good faith and not anonymously. To protect the 'reporter' as much as possible, the necessary security measures have been put in place: the identity of whoever submits a report and its content will be kept confidential through secure protocols and encryption tools which allow the protection of personal data and information, including the information disclosed in any attachmentsi. The corporate body responsible for the management of the reports is the Supervisory Board. The reports are managed in a transparent manner through a predefined procedure. The entire process guarantees the reporters protection from pressure and discrimination, be it direct or indirect, from the individuals responsible for the verification of the reports. The identity of the reporter shall never be revealed without consent from the reporter, with the exception of cases in which the verifications conducted following the reports do not fall within the specific case of criminal, administrative or tribunal investigations, or they give rise to a disciplinary procedure based solely on the complaint received, for which knowledge of the identity of the author of the report is absolutely essential to the defence of the accused.

Therefore, Whistleblowing represents an important pillar of the security system of Leonardi & C. S.p.A.. Thanks to secure communication protocols and encryption systems, the portal: -Protects the identity of the reporter and does not disclose it without the explicit consent of the reporter; -Protects the identity of the accused; -Maintains the confidentiality of the information in all contexts following the report; -Permits the computerised management of reports to company departments responsible for receiving and verifying them


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