We are committed to opposing any form of corruption. Our Anti-corruption Procedure is an integral part of a broader system of business ethics and internal control aimed at ensuring compliance with national and international laws and standards and protecting the company’s reputation.
The anti-corruption measures are contained in the specific Policy and in the Procedure, which provides a systemic reference framework for the regulatory instruments present in Italgas, inspired by the principles of conduct set out in the Code of Ethics and aimed at preventing any form of corruption in relations with third parties, to protect the business integrity and reputation of the group.
The Procedure also contains policy elements on anti-corruption matters, and was adopted in compliance with the tenth principle of Global Compact, the international initiative launched in 2000 by the United Nations to support ten universal principles regarding human rights, work, the environment and the fight against corruption.
Specifically, the Anti-corruption Procedure
Makes a clear distinction between permitted conduct and prohibited conduct.
Prohibits any form of corruption, involving either public officials or private individuals.
Pays particular attention to the selection of suppliers and the qualification process, the awarding and management of contracts, standard protection clauses, including those of commitment to comply with Anti-corruption laws and verification of the ethical requirements of suppliers.
Establishes that all relations of the Italgas Group with, or referring to or involving a public official must be conducted in compliance with the provisions of the Procedure.
A Legal Anti-corruption Department was established, with the task of monitoring the adoption of the Procedure, updating it and educating personnel. As envisaged by the Model 231 and the Anti-corruption procedure, all Italgas personnel must be informed and receive training on the Anti-corruption laws.
Specific information flows between the company departments are also envisaged, such as the direct superior of the employee who became aware of a corruption attempt, the Supervisory Body, and the anti-corruption Legal Department. As required by legislation, an email address has been set up also for anonymous reports (firstname.lastname@example.org) regarding requests made by a public official and/or a private individual that could constitute corruption, in addition to a specific reporting system for any suspected infringement of the anti-corruption laws and of the Procedure itself.
Group employees must be informed about the applicable anti-corruption laws and the importance of compliance with the Procedure. They must, in fact, have perfect knowledge of the offences, risks, personal liabilities, administrative liabilities for group companies, the actions to be taken to combat corruption, and the penalties.
The Procedure applies to Italgas S.p.A. and its subsidiaries as part of the management and coordination activities performed by the group’s corporate body. Suppliers and intermediaries are also required to adhere to the anti-corruption measures.
Our commitment to promoting Anti-corruption Procedures
Italgas is committed in fighting and preventing any form of corruption both nationally and internationally. Italgas S.p.A. and its subsidiaries have adopted specific procedures which prohibit the corruption in any form of any Italian or foreign public or private entities; measures that are an integral part of a broader business ethics control system that aims to ensure the Company’s compliance with national and international anti-corruption laws, including the UK’s Bribery Act, and with the best international anti-corruption standards, helping to protect the Company’s reputation. Moreover, Italgas Group is committed to spreading the knowledge of the Anti-corruption policies and procedures by organizing specific trainings to all its people. In conclusion, Italgas requires to its suppliers and stakeholder to adhere to and comply with its anti-corruption measures.
STANDARD GRI 205-2 COMMUNICATION AND TRAINING ABOUT ANTI-CORRUPTION POLICIES AND PROCEDURES
|COMMUNICATION AND TRAINING ABOUT ANTI-CORRUPTION POLICIES AND PROCEDURES||U.O.M.||2020||2021||2022|
* The training considered covers the following subjects: Code of Ethics, Model 231, Anti-corruption, Antitrust and Data Protection.
STANDARD GRI 205-3 CONFIRMED INCIDENTS OF CORRUPTION AND ACTIONS TAKEN
In 2022, as already pointed out in 2021, no incidents of corruption took place (see the table below).
|CONFIRMED INCIDENTS OF CORRUPTION AND ACTIONS TAKEN||U.O.M.||2020||2021||2022|
|Total confirmed incidents of corruption||n.||0||0||0|
|Confirmed incidents of corruption with dismissal/ disciplinary measure of employees||n.||0||0||0|
|Confirmed incidents of corruption with termination/non-renewal of contracts with business partners||n.||0||0||0|
ISO 37001 certification
During 2022, Italgas S.p.A. and the main subsidiary Italgas Reti S.p.A. have achieved the confirmation of the certification of the management system for preventing and combating corruption implemented by the aforementioned companies in accordance with standard UNI ISO 37001:2016 that certifies the conformity of the management system for the prevention and fight against corruption; certifications that the two Companies had obtained for the first time in the 2018 and subsequently renewed in 2021 for the three-year period 2021- 2024.
During 2022 the management systems for the prevention of and fight against corruption adopted by Italgas Acqua S.p.A., Geoside S.p.A., Medea S.p.A., Toscana Energia S.p.A. Umbria Distribuzione Gas S.p.A. and Metano Sant’Angelo Lodigiano S.p.A., have achieved the maintenance of the certification, obtained, for the first time in 2020, in accordance with standard UNI ISO 37001:2016.
With a view to Group certification and in order to enable integrated management of the monitoring and supervision of the performance of management systems for preventing and combating corruption adopted by each Italgas Group companies, the deadline of the 37001 certification of management systems for preventing and combating corruption adopted by subsidiaries and affiliates has been aligned with that of the management system for preventing and combating corruption adopted by Italgas S.p.A. In view of the above, the 37001 certification of all management systems for preventing and combating corruption will expire on December 24, 2024.
During 2022, audits were also conducted by the certification body aiming at obtaining the certification of the management system for preventing and combating corruption adopted by Bludigit S.p.A.; certification under UNI ISO 37001:2016 was achieved on November 15, 2022 and will be valid until December 24, 2024.
The management systems for the prevention of and fight against corruption were certificated upon completion of the in-depth audits conducted by the certification body DNV Business Assurance Italia S.r.l. during which the commitment and collaboration of the corporate departments and representatives, supervised by the compliance function, in the implementation and observance of the measures adopted in order to assure the adequacy and suitability of each management system for the prevention of and fight against corruption in accordance with standard UNI ISO 37001:2016 was found.