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1.10 ETHICS & COMPLIANCE
1.10 ETHICS
AND COMPLIANCE
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Maire Tecnimont, in building the Group’s identity, has adopted specific ethical values and principles that guide the day-to-day activities of all Group employees.
GROUP’S VALUES
MERIT AND EQUAL OPPORTUNITIES
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INNOVATION
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RESILIENCE AND FAIRNESS
RESPONSIBILITY TOWARDS THE COMMUNITY
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RESPECT AND SUSTAINABILITY
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INTEGRATION AND MULTICULTURALISM
MARKET FOCUS
ETHICAL PRINCIPLES OF MAIRE TECNIMONT GROUP
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LEGALITY
TRASPARENCY AND FAIRNESS
LOYALTY
RESPECT FOR INDIVIDUAL
PROTECTION OF HEALTH AND SAFETY IN THE WORKPLACE
PROTECTING THE ENVIRONMENT
PROTECTION OF PHYSICAL SAFETY
The Maire Tecnimont Group considers it essential to conduct business in full compliance with the law, regulations, statutory provisions and with the principles of ethical integrity and fairness.
Maire Tecnimont has set out these values and principles in the Group Code of Ethics17 and in its corporate standards and procedures.
The Group Code of Ethics applies to the Board of Directors, Auditors, all employees and external personnel (consultants, business partners, etc.), suppliers, sub-contractors, clients and any other parties who at any level come in contact with Maire Tecnimont or act for and on its behalf18. It must be adopted by all Maire Tecnimont Group subsidiaries in Italy and abroad, to ensure that the conduct of business and the management of company operations is ethical and meets high standards of integrity at all times, in every location.
The Board of Directors of Maire Tecnimont S.p.A. has adopted its
own 231 Model, which is updated from time to time to reflect regulatory developments and organizational and corporate changes, thus meeting the need for fairness and transparency in the conduct of its business and management of its activities. The Board of Directors has therefore appointed a 231 Supervisory Body with autonomous powers of initiative and control.
The Italian sister companies directly controlled and fully-owned by Maire Tecnimont S.p.A. also have their own 231 Model and 231 Supervisory Body.
Aside from the Group Code of Ethics, the 231 Model establishes a set of rules and principles of control and conduct to be adopted and implemented in order to mitigate the risk of committing the offences referred to in Italian Legislative Decree 231/2001, including
17 The Group Code of Ethics is a single document for the whole Maire Tecnimont Group. It is available in Italian and English and is published in the “Governance” section of the website www.mairetecnimont.it. All the companies directly or indirectly controlled by Maire Tecnimont, in Italy and abroad, are required to adopt it and to comply with its contents. 18 The recipients of the Group Code of Ethics will hereafter be referred to as “Interested Parties”.
ORGANIZATION, MANAGEMENT AND CONTROL MODEL: INTEGRATED SYSTEM OF RULES
CODE OF ETHICS
VALUES, PRINCIPLES AND CONDUCT GUIDELINES On which Maire Tecnimont Group operations are based
GENERAL PART
GENERAL PRINCIPLES OF ORGANIZATION, MANAGEMENT AND CONTROL - Governance and Internal Control and Risk Management System - Risk assessment - Disciplinary system - Supervisory body and reporting - Training and communication of the model
SPECIAL PARTS, PROTOCOLS
GENERAL PRINCIPLES AND CONTROL AND CONDUCT RULES Considered appropriate for managing the areas for which the potential committal of 231 offenses has been indicated
STANDARDS, PROCEDURES, REGULATIONS
OPERATIONAL BASIS OF THE CONTROL PRINCIPLES For the risk processes, with indication of the duties and responsabilities of the company fuctions involved
corruption and the violation of environmental protection and workers’ health and safety rules.
Maire Tecnimont Group personnel, and persons acting on its behalf, are responsible for understanding the applicable rules and must act in compliance with the internal regulatory instruments such as the Group Code of Ethics, the 231 Model and the corporate standards and procedures. Such instruments, which also include rules and principles concerning anti-corruption policies, are communicated to all Group employees and Interested Parties.
Maire Tecnimont has committed to integrating the various mechanisms for collecting and manag-
ing complaints and reports. Maire Tecnimont is aware of the importance of these channels to prevent any category of abuse and is highly engaged in strengthening and ensuring their effectiveness.
The reporting mechanism is detailed not only in the Group’s Code of Ethics and 231 Model, but also in a specific procedure which is published on the Company’s website and is thus available to all employees and external stakeholders.
Breaches (actual or alleged) of the 231 Model and/or of the Group’s Code of Ethics or other company policies may be reported by employees and third parties to the Group Corporate Affairs Governance & Compliance function or to the 231 Supervisory Body respectively, through various channels including post, Supervisory Bodies’ e-mail inboxes, and a specific platform.
All complaints are promptly dealt with and are managed by the Head of Group Corporate Affairs, Governance & Compliance in collaboration with the relevant Supervisory Body, the Head of Internal Audit of Maire Tecnimont, Human Resources, ICT & Process Excellence Senior Vice President and the Group General Counsel (“Work Group”). Anonymity for whistleblowers is guaranteed and all complaints are dealt with in accordance with the current regulations.
In 2020, 3 reports were received concerning Maire Tecnimont companies, referring to alleged breaches of the Code of Ethics or other company policies. The complaints were examined in accordance with the above procedure; for two of them, the investigations did not reveal any violations of the principles or controls of the Code of Ethics and the policy system; for one complaint, the investigations are still ongoing but no critical issues have yet emerged.
