Ethics, Compliance, Integrity

Development, implementation, and continuous strengthening of internal controls and risk management system as well as compliance and anti-corruption programs.

Italcertifer S.p.A. guarantees to run his business consistent with the defined strategic objectives and aware of the risks that may affect the achievement of these objectives and the reputation of the company.

In line with the highest standards and best practices, Italcertifer S.p.A. promotes dissemination of internal control and risk prevention corporate culture, encouraging the taking of informed decisions and ensuring the safeguarding of the company’s assets, the efficiency and effectiveness of business processes, the reliability of financial information, the compliance with the laws and the protection of Company and the Group reputation, both in Italy and abroad.

Integrity and honesty are the fundamental values enshrined in the FS Italian Group Code of Ethics, which expresses its commitment to act in full respect of legality and transparency and to repudiate and discourage all forms of corruption, or any form of abuse, at any level practiced, both in Italy and abroad.

Sustainability, responsibility, competence, and independence are the principles that inspire the activities of Italcertifer S.p.A. declared in the company policies and in compliance with the Code of Ethics of the FS Group.

Management Whistleblowing Reports

The following people can submit a report:

employees, self-employed workers, contractors, volunteers and trainees, including non-paid people, who work for Italcertifer S.p.A. ;
workers or collaborators, who work for organisations providing goods or services or that carry out works for third parties; freelancers and consultants working for Italcertifer S.p.A.; Italcertifer's shareholders and individuals with administrative, management, control, supervisory or representative roles.

These people report on breaches of which they have become aware as part of their job.

Reports may be submitted:

when the legal relationship has not yet begun, if information on breaches was acquired during the recruitment process or at other pre-contractual stages;
during the probationary period;
after the termination of the legal relationship if the information on breaches was acquired during the relationship.

Italcertifer S.p.A. encourages that the Whistleblower's identity be disclosed in the report, for which confidentiality is guaranteed in compliance with the legislation in force, so that the reported facts can be verified more easily and the Whistleblower can be informed of the results of the investigations carried out. However, reports may be made anonymously.

What to report

Information on breaches involving facts (of any nature whatsoever, even if merely omissive), attributable to FS Italiane Group Employees or Third Parties, which may constitute:

breaches of the Italcertifer S.p.A. Model 231 and procedures for its implementation and/or of the Anti-Corruption Policy and the Italcertifer S.p.A. Anti-Bribery&Corruption management system (hereinafter "ABC system") and/or of the Code of Ethics and/or of the company's internal regulations and/or in any case likely to cause damage or harm, even only in terms of image or reputation, to the FS Group;
administrative, accounting, civil or criminal offences;
unlawful conduct pursuant to Legislative Decree No. 231 of 8 June 2001;
offences under the scope of European Union and national provisions implementing them;
acts or omissions detrimental to the financial interests of the European Union;
acts or omissions concerning the internal market (e.g. competition and state aid violations);
acts or conduct that undermine the object or purpose of the European Union provisions.

The reports must concern facts of which the Whistleblower has direct knowledge, with the Whistleblower having well-founded reasons to believe that the information reported is true at the time of the report.

Reports must be made promptly upon becoming aware of the facts in question in order to ensure that verification is fully possible.

The following do not constitute so-called whistleblowing reports: disputes, claims or requests relating to a personal interest of the whistleblower that relate exclusively to his/her individual employment relationship or relating to his/her relationship with hierarchically superior people; reports or complaints concerning commercial activities or services to the public.

Italcertifer S.p.A. provides the following channels for submitting reports:

IT platform: that can be accessed from the Italcertifer S.p.A. website - www.Italcertifer.it and the company intranet. This should be considered as the preferential channel as it is more suitable to guarantee, by means of IT modalities, confidentiality with regard to the identity of the Whistleblower and adequate information security measures;
ordinary mail: to the Italcertifer S.p.A. address,Technical Secretariat Ethics and Reporting Committee c/o Italcertifer S.p.A. Auditing - Piazza della Croce Rossa, 1 - 00161 Rome or Supervisory Body c/o Italcertifer S.p.A. Auditing - Piazza della Croce Rossa, 1 - 00161 Rome;

e-mail: to the address comitatoetico@Italcertifer.it or odv@Italcertifer.it;

In compliance with the provisions of the law, Italcertifer S.p.A. guarantees the confidentiality of the Whistleblower’s identity as soon as the report is received and prohibits (and penalises to the extent permitted by its powers and authority) any direct or indirect form of retaliation or discrimination against the Whistleblower as a result of a report, including omissive conduct, also attempted or threatened, or directed at third parties associated with the Whistleblower, such as relatives, colleagues, legal entities owned by or working for the Whistleblowers, who are operating with the FS Italiane Group.

To ensure that there will be no retaliation against the Whistleblower even after the report has been made, Italcertifer S.p.A. employees are monitored for a period of two years from the date of the report.

Individuals who are involved in any capacity in the management of reports are required, within the limits provided for by law, to maintain confidentiality as to the existence and content of the report received and the activity carried out in this regard, and to protect the confidentiality of the Whistleblower's identity in accordance with the provisions of the applicable legislation.

The Whistleblower is informed that the report has been received within 7 days from the date of receipt. The Whistleblower is also informed of the results of the investigation into the matter.

Italcertifer S.p.A protects the rights of the Involved Persons, first and foremost by ensuring, to ensure appropriate confidentiality, that any disclosure of their identity strictly follows the “need to know” criterion (principle whereby a person is authorised to access certain information only if necessary - and within the limits of what is necessary - for the performance of the activities for which he/she is responsible according to his/her company's assigned tasks).

The Involved Person is informed of the existence and content of the report and receives a copy of the same, excluding any reference to the Whistleblower's identity, which may not in any event be disclosed to the Involved Person, except in the cases expressly provided for by law.

The Involved Person has the right to be informed of the outcome of the investigation. After due assessment, information to the Involved Person may be delayed or not provided completely or only partially if it intervention by the public authorities is deemed necessary, or if it is reasonable to believe that, by providing the information, the confidentiality of the Whistleblower's identity, which is protected by law, may be at risk.

The corporate bodies in charge (theEthics and Reporting Committee and the Supervisory Board) check the content of the report and perform fact-finding activities on the reported facts to verify their validity and allow measures to be taken to prevent or sanction the irregularities or offences identified.

Slanderous or defamatory reports are prohibited and sanctioned in accordance with the law and by the Company's disciplinary measures.

As part of the reporting management process, personal data is processed in compliance with current legislation on the matter (EU Regulation 679/2016 and Legislative Decree 196/2003 as amended by Legislative Decree 101/2018). Information on the processing of personal data can be found below.

Privacy notice(.pdf — 514 KB)

Ethics, Compliance, Integrity

Whistleblowing Managment Procedure

Management Whistleblowing Reports