Ansaldo STS promotes the fight against corruption in all its different forms at all levels and within the scope of its business, whether active or passive, direct or indirect, involving subjects related to the public or private sector.
In this context, Ansaldo STS has adopted a "zero tolerance" approach, which entails that the Company does not tolerate any kind of corruption, in any form, manner or jurisdiction in which it may occur, including therein any conduct that may be permitted, tolerated or not prosecuted in the countries in which the Group operates.
Ansaldo STS, despite not having a specific formalised policy - that the company aims to adopt during the year 2018 - has implemented a corruption risk management system based on several control tools to combat and prevent corruption-related behaviour that together constitute the system of policies adopted by Ansaldo STS in the fight against corruption. Among these tools, Ansaldo STS S.p.A. considers particularly important its adoption of the Organisation, Management and Control Model pursuant to Italian Legislative Decree no. 231/2001, the body of corporate procedures and also the due diligence activities carried out on the third parties with which Ansaldo STS deals.
The main risk areas, including direct risks and the areas that could potentially facilitate acts of corruption, subject to the requirements of the Model, are mainly sales, contract management, procurement, sites, administration, finance and control, HR and soft loans.
The Group's Code of Ethics serves as a tool to control and mitigate corruption risk. Compliance with the principles and rules of conduct contained therein enable Ansaldo STS and the Group companies to prevent certain illegal conduct or offences - including those that are corruption-related and as required by the regulations of the various countries in which the Ansaldo STS Group operates - from being committed by corporate representatives. In particular, through the Code of Ethics, the Company promotes and applies a corporate culture inspired by responsibility, correctness and integrity in the conduct of daily activities, paying maximum attention to the professional conduct of its recipients.
The above-mentioned Code of Ethics is complemented by the Organisation, Management and Control Model pursuant to Italian Legislative Decree no. 231/2001 approved by the Board of Directors of Ansaldo STS, which contains specific principles of conduct and control aimed at preventing and mitigating the risk of committing corruption-related offences as set out by Italian Legislation and specifically referred to in Articles 25 and 25-ter of Legislative Decree no. 231/2001.
In order to ensure the comprehensive acknowledgement of the Organisational, Management and Control Model pursuant to Italian Legislative Decree no. 231/2001 by all personnel, all employees receive a report whenever updates are made to the Model. In addition, a new e-learning training programme was recently offered to nearly all employees of Ansaldo STS S.p.A. Employees working in at-risk areas, as well as executives and middle managers, sign periodic statements to certify the respect of the Model and, when needed, to describe the most significant relationships with customers and representatives of the public authorities.
The prevention and fight against corruption-related conduct are also supported by a well-structured and comprehensive body of corporate procedures, applicable - where possible - to all Group companies. These procedures govern the conduct of company transactions and operations so as to ensure the identification of the persons responsible for the decision-making and authorisation process and provide traceability, enabling the identification, inter alia, of the reasons for the decisions made and the persons to be held accountable for them. The corporate body of procedures specifically governs and defines those which, due to their very nature or to the type of parties involved, including external parties, are potentially vulnerable to the risk of corruption.
In order to mitigate, inter alia, the risk of corruption, Ansaldo STS has defined, as a tool to combat this problem, a process to assess the various types of third parties with whom it deals, both within the scope of business activities and for ordinary corporate operations. This process includes, in view of the multiple risk profiles that can be associated with the third parties involved, a range of assessment tools aimed at verifying, inter alia, the existence of potential indicators of a high risk of corruption.
In order to further equip itself with effective prevention tools against the occurrence of potential corruption-related events, Ansaldo STS has launched a process at Group level aimed at analysing its own corruption risk management system and to identify possible areas for improvement. This activity was carried out in compliance with the Company's international vocation and took into consideration the Best Practices in this area and the main international Guidelines and Conventions concerning the prevention and fight against corruption. To ensure the uniformity and completeness of the risk management systems adopted by the Company, the activity was carried out in a fully integrated manner and in full coordination with the risk management tools defined pursuant to Italian Legislative Decree no. 231/2001.
The improvement initiatives identified at the end of the aforesaid analysis will refine the current corporate corruption risk management system, with a view to increasing the effectiveness of the mitigation instruments that concern combating and preventing corruptive phenomena, including those at an international level. In this regard, Ansaldo STS has drawn on industry's best practices to support the analysis described above.
As a result of this analysis, Ansaldo STS is in the process, inter alia, of:
- refining its Corporate Governance system, by means of an extensive allocation of further specific roles and responsibilities within the corruption risk management system, also from a Group perspective;
- strengthening the existing monitoring tools and control mechanisms designed to control the corruption risk, and to define additional tools;
- strengthening the tools for disseminating the elements of its corruption risk management system to its staff, and improving its awareness and training.
Finally, it should be noted that no cases of corruption involving the Company and/or its employees were observed during the year.