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ANTI-CORRUPTION POLICY

Fabrizio Carlotto S.r.l has a position of absolute intransigence towards any form of corruption, even towards the personnel of private companies. In this sense, the Company fully warns of its commitment to guarantee actions and conduct based exclusively on criteria of transparency, correctness and moral integrity, which prevent any attempt at corruption.

This position helps to comply with the anti-corruption law requirements and the commitments to which the Company has voluntarily bound itself through the adoption of its Code.

Fabrizio Carlotto S.r.l commitment against corruption prohibits Personnel, Partners, and, in general, anyone who carries out activities on behalf of the Company from requesting, promising, offering or receiving gifts, gratuities or benefits, potential or actual, from of or to subjects external to the Company, whether they are public officials or persons in charge of public service, government representatives, public employees or private citizens, both Italian and from other countries, such as to determine unlawful conduct or, in any case, such as to be interpreted by a impartial observer, as aimed at achieving an advantage, even if not economic, considered relevant by custom and by common belief, also understood as facilitating, or guaranteeing the achievement, of services in any case due in business activities.

 

Each employee, director and manager, business partner and any other external 'interested party' is required to read, understand and apply the procedures and protocols of the anti-corruption management system and to behave in accordance with its provisions.

 

For this to be possible, it is necessary that the whole organization knows and shares the company policy for anti-corruption which is contained in the following concepts:

 

- Commitment of Senior Management in preventing corruption by respecting legislative compliance and the requirements of the anti-corruption management system;

 

- Zero tolerance, appropriate procedures, active role of management, effective communication, constitute the reference framework for the definition and pursuit of improvement objectives;

 

- Encouragement to report suspected cases in good faith, ensuring the protection of the informant in all forms;

 

- Penalty for any form of failure to comply with the corruption prevention procedures and the contents of this company policy;

 

- Assigning the role of Anti-Corruption Compliance Manager to an external resource with adequate status, authority and independence;

 

- Commitment to continuous improvement of corruption risk management and prevention processes.

TO REPORT WRITE TO: info@fabriziocarlotto.com

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