For Salini Impregilo, balancing business values with a solid work ethic and maintaining integrity throughout the enterprise is the surest way to preserve the Group’s investments and reputation.
Code of Ethics
This commitment is unequivocally stated in the Group’s Code of Ethics. That Code defines the values and principles of honesty, fairness, integrity, transparency, impartiality, confidentiality, safety of physical integrity and human dignity, protection of the environment, dialogue and engagement with stakeholders, as the distinctive elements of the Group’s activities.
The Code represents a reference point for those who work in the Group, for all individuals involved in the Company's mission, or who contribute to the pursuit of the Group's objectives. The principles outlined likewise provide conduct guidelines for the Group’s directors, employees, and all those who for whatever reason collaborate with the Salini Impregilo Group worldwide.
The internal Control and Risk Committee and Integrity Board are in charge of monitoring compliance with the Code of Ethics. In particular, the Integrity Board – an independent three-member committee established in accordance with the Italian Legislative Decree no. 231/2001 – ensures compliance with the Code through inspections carried out by the Compliance Department. All recipients of the Code can make us use of a direct mailbox to inform the Integrity Board of any possible breaches, which are dealt with in complete confidentiality to protect those concerned.
Anti-Corruption Compliance System
To reinforce the provisions of the Code of Ethics and fully integrate the 10th principle of the Global Compact into the organisation, in 2014 Salini Impregilo developed its own Anti-Corruption Compliance System, composed of a specific policy, a management model, and detailed guidelines and procedures that assign roles and responsibilities for operations and monitoring at all levels of the organisation.
The Anti-Corruption Model is an element of the Group’s internal control system aimed at strengthening certain prevention protocols, minimising the risk of active or passive corruption, and ensuring compliance with the principles introduced by the anti-corruption laws and international Best Practices.
A special Anti-Corruption Legal Support Unit, founded within the Compliance Department, is responsible for providing assistance and advice on anti-corruption issues, as well as for monitoring the Model’s application and its effectiveness.
A key element of the model is the whistle-blowing system, which allows individuals to anonymously report presumed or known violations, guaranteeing them protection against any form of retaliation, discrimination, or penalty.
The violation of the principles and provisions of the Anti-Corruption Model, or also the failure to report known or suspected illegal actions, represents a serious breach of contract between the Company and its employees or collaborators. In these cases, Salini Impregilo will take the appropriate measures prescribed in the legal and contractual rules, namely conservative sanctions, dismissal, termination of the contractual relationship, damages, etc.
In order to raise awareness and full understanding of the Model, Salini Impregilo provides a binding anti-corruption training programme for all employees, its level of detail adjusted to the qualifications and position of the individual employee, and to his/her degree of involvement in activities considered sensitive.
In 2014 an internal briefing programme on the Model was provided for all the members of the Board and of the Committees, along with all employees and business partners. Moreover, all contracts with third parties now include specific clauses obliging compliance with the principles contained in the Code of Ethics and the Anti-Corruption Model of the Group.
In the course of the year, all employees at headquarters and at construction projects under way in Italy received specific training on anti-corruption, through both traditional in-house courses and e-learning. In 2015 this training drive will cover all Group employees working on projects outside Italy.