To help guide our employees’ behaviour, we have implemented a Compliance System composed of policies, procedures, models, organisational structures and control activities.

The System is also structured to ensure that we respect applicable competition laws preventing anti-competitive practices and corrupt behaviours, and maintain high levels of integrity in all our interactions with public authorities.

A whistleblowing system completes the Compliance System, allowing individuals to anonymously report presumed or known violations, and giving them protection against any form of retaliation, discrimination, or penalty.

 

Code of Ethics

The Group’s commitment to business ethics is stated in our Code of Ethics, which defines for each corporate value the principles that guide our behaviours. These include honesty, fairness, integrity, impartiality, confidentiality, physical integrity protection, respect for human dignity, environmental protection, and the respect of local communities.

The Code represents a reference point for our employees and everyone who contributes to our mission and objectives. Similarly, the principles provide conduct guidelines for the Group’s directors, employees, and all those who collaborate with the Salini Impregilo Group.

We require all new employees to sign up to the Code of Ethics, and all contracts with Group’s partners, suppliers, providers of services, consultants, etc. include an obligation to comply with the rules of the Code.

 

"Organizational, Management and Control" Model

Salini Impregilo has adopted a Group Organisational, Management and Control model (also called Model 231) aimed at:

  • Defining and embedding a corporate culture based on compliance and transparency;
  • Raising awareness among employees and stakeholders.

The Model operates under the scope of the Internal Control System and is aimed at preventing offences under Italian Law 231/2001, through the monitoring of operations with a risk of civil and penal liability for the company and our representatives.

The Model contains measures that guarantee activities are conducted in compliance with the law and that promptly detect and eliminate potential risks.

An independent control body – the Integrity Board – oversees the effective implementation of and compliance with the Model by means of audits conducted by the Compliance Department.

 

Anti-Corruption Compliance System

To reinforce the provisions of the Code of Ethics and fully integrate the tenth principle of the Global Compact into the organisation, Salini Impregilo developed its own Anti-Corruption Compliance System. This comprises 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. By following this model, we aim to strengthen certain prevention protocols, minimise the risk of active or passive corruption, and ensure compliance with the principles introduced by 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.

The violation of the principles and provisions of the Anti-Corruption Model, or 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 would take the appropriate measures, as prescribed by legal and contractual requirements (such as conservative sanctions, dismissal, termination of the contractual relationship, damages, etc).

In order to promote awareness and understanding of the Model, Salini Impregilo provides a mandatory anti-corruption training programme for all employees. The course is adapted to the qualifications and position of the individual employee, and to the extent of his/her involvement in potentially sensitive activities.

Additionally, all contracts with third parties now include specific clauses obliging compliance with the principles contained in the Group’s Code of Ethics and the Anti-Corruption Model.

All employees at our corporate head office, as well as those working on construction projects in Italy, receive dedicated training on anti-corruption, through both traditional in-house courses and e-learning. In 2016 this training drive will cover all Group employees working on projects outside Italy and people hired in 2015.