GOING IN THE
GOING IN THE
When we talk about corporate compliance, we refer to the compliance of all corporate activities about procedures, regulations, legal provisions, and codes of conduct. Therefore, compliance’s main purpose is to protect the company from legal and reputational risks.
Health and Safety, Environment and Quality, Ethical and Social Responsibility.
Management invites everyone to share our policy committed to
1. Assessing risks and mitigating potential threats that could impact the business, people and the environment, committing to meet applicable requirements.
2. Paying attention to the growth of human resources, Investing on young graduates and specific school projects.
3. Prohibiting any form of discrimination on the basis of age, sex, race or ethnicity, religion, political opinion, physical condition, nationality, marital status, and sexual orientation, in full compliance with the code of ethics.
4. Monitor and maintain the flexibility necessary to meet client needs.
5. Share policy and own values both within and outside the company.
6.Monitor efficiency and reliability of processes and procedures.
7. Ensure compliance with local, national, and international laws, regulations, and compliance obligations.
8. Prevent pollution, reduce waste and limit the use of natural resources.
9. Start recycling and properly dispose of waste.
10. R Make the workplace safe, healthy, and pleasant.
11. Regularly update technological tools to ensure the best possible service, monitor processes, control quality, environmental aspects, conditions, and The factors that may affect the health and safety of the workers, and tore data and documentation so that they are always readily available.
12. Carefully select and evaluate carriers and all third-party suppliers In line with this Policy.
13. Implement effective measures to prevent and resolve nonconformities, and promote continuous improvement of the system to increase its performance.
14. Ensure human and financial resources to carry out activities.
15. Strengthen both internal and external communication channels regarding this policy and corporate objectives, through the website.
16. Reduce air pollution by choosing “Green” carriers and implementing systems to monitor the shipments.
17. Prevent accidents, injuries, and occupational diseases.
18. Measure system performance with specific indicators and monitoring tools to verify and Set targets in management reviews.
Code of Ethics
In carrying out its activities, Aprile S.p.A respects the laws and regulations in force in all the countries in which it operates. The Company, therefore, acts in compliance with the principles of freedom, the dignity of the human person, and respect for diversity repudiating any discrimination based on sex, race, language, personal and social condition, religious and political belief,s and therefore intends to build its growth by consolidating an image faithful to the values of fairness and loyalty. It, therefore, believes that compliance with the rules of ethics and transparency in the conduct of business constitutes a necessary condition, as well as a competitive advantage, for pursuing and achieving its objectives. To this end, Aprile S.p.A promotes the creation of an environment characterized by a strong sense of ethical integrity, in the firm belief that this contributes decisively to the effectiveness of policies and control systems, influencing behavior that could escape even the most sophisticated supervisory mechanism. Therefore, the Company has adopted a document, called the “Code of Ethics,” which regulates the set of rights, duties, and responsibilities that Aprile assumes, in carrying out its social activity, towards all stakeholders who have a direct or indirect relationship with the company and are ablecancebalancevity or are affected by it.
These Anti-Corruption Guidelines are a programmatic document issued by the top decision-making management of the company aimed at identifying and articulating corruption prevention strategies through a specific analysis of the corruption risks concretely identifiable in the company’s reality and the elaboration of the consequent protocols, understood as organizational tools designed to prevent corruption risks. Therefore, the Anti-Corruption Guidelines aim to identify specific ethical-behavioral norms in the field of anti-corruption that allow to qualify as illegal all the activities carried out by employees, consultants and collaborators in various capacities carried out in favor or on behalf of the company and that allow the company, either directly or indirectly, to achieve an unfair interest and/or advantage. The effectiveness and concrete implementation of the Anti-Corruption Guidelines is ensured not only by adequate information/training of personnel but also by a system of ad hoc investigations and/or through the collection and analysis of information, reports and ascertainment of violations. In order to ensure the effective enforcement relevance of the document, disciplinary measures are envisaged in case of violations an, regardless whether such violations have concretely led to corrupt behavior or have exposed the Company to sanctions. Aprile does not condone any form of corruption and is committed to complying with the anti-corruption laws in force in all the countries in which it operates. The purpose of the Guidelines is to guarantee the principles of transparency, ensure clarity in the scope of permissible conduct, and compliance with relevant anti-corruption regulations wherever Aprile conducts its business.
Legislative Decree 231/2001
As required by Legislative Decree 231 on the administrative liability of companies, Aprile has adopted an Organization, Management and Control Model that ensures fairness and transparency in the conduct of business and aims to prevent crimes committed in the interest or to the advantage of the company. According to Legislative Decree 231 of June 8, 2001, companies and in general all entities may be held criminally liable, and thus incur penalties, for certain offenses committed in their interest or to their advantage by directors, employees and others acting in the name or on behalf of the entity or company. In particular, the Decree covers offenses in relations with the Public Administration, corporate offenses, offenses related to occupational safety and the environment, organized crime offenses, terrorism, computer crimes, crimes against industry and commerce, crimes against the individual and others. To minimize the risk of these crimes being committed, each company is required to adopt an “Organization and Management Model,” which is a set of provisions and procedures, including the adoption of a Code of Ethics and Anti-Corruption Guidelines, the establishment of a Supervisory Board, and the implementation of a system of controls and sanctions. The adoption and effective implementation of the Model and the appointment of the Supervisory Board enable the entity to enjoy the exemption clause from liability in case of crimes. Aprile’s “Model 231” is a dynamic and shared document. Dynamic, because it is sensitive to any regulatory and organizational changes. Shared, because its implementation involves the entire corporate population, both in the pre-processing phase, through risk assessment, and in the implementation phase, through training and information.
Supervisory Board of Aprile S.p.A
The Supervisory Board of the Aprile Company (hereinafter SB) is a collegial body, endowed with powers of initiative and control, whose members, identified by the Board of Directors, must meet the requirements of autonomy, independence, professionalism, continuity of action and honorability. The Supervisory Board is entrusted with the tasks of supervising compliance with the requirements of the Model, the actual effectiveness of the Model and the advisability of updating it, as well as operational tasks related to the application of the Model.
The Supervisory Board of Aprile S.p.A. is composed of three members, all external:
Chairman: Dr. Gucci Michele
Component: Dr. Vieri Chimenti
Component: Dr. Alessia Bastiani
Monitoring and updating the Model
The set of areas at risk of commission of offenses under Legislative Decree 231 and the rules of conduct in the Model areise result of an analysis of company documentation and meetings with staff, so that the Model to the characteristics of each company in the group. Aprile’s and the subsidiaries’ Models are continuously monitored to assess their effectiveness and ensure that they are updated witconcerningternal (in organizational structure, business activities) and external (legislative developments, best practices) changes.
Training and information
Staff training is an essential element for the effective implementation of the Model. Therefore, a training plan has been developed that includes both classroom sessions and e-learning modules, with content, diversified according to the recipients and based on concrete examples. Also to assess the quality of teaching, evaluation tests on the topics covered in the class are distributed at the end of the courses.
Supervisory committee and Whistleblowing
Aprile has created a digital space to offer employees and all citizens the possibility of reporting any or alleged unlawfulness about which they have come to know. Aprile has always been particularly attentive to the prevention of risks which could compromise the responsible and sustainable management of its business. For this reason, adhering to the ANAC indications, the Reporting Procedure – Whistleblowing portal has been created. It is a web tool available for all who wish to report situations which could cause damage or detriment to the company, like fraud, generic risks or a potentially dangerous situation.
The portal is part of the internal control tools adopted by the Aprile group in order to prevent corruption, guarantee honesty and transparency when conducting business and in the activities carried out, and protect its standing and reputation.
The reports must be made in good faith and not anonymously. To protect the “reporter” as much as possible, the necessary security measures have been put in place: the identity of whoever submits a report and its content will be kept confidential through secure protocols and encryption tools which allow the protection of personal data and information, including the information disclosed in any attachment.
The corporate body responsible for the management of the reports is the Supervisory Board. The reports are managed in a transparent manner through a predefined procedure. The entire process guarantees the reporters protection from pressure and discrimination, be it direct or indirect, from the individuals responsible for the verification of the reports. The identity of the reporter shall never be revealed without consent from the reporter, with the exception of cases in which the verifications conducted following the reports do not fall within the specific case of criminal, administrative or tribunal investigations, or they give rise to a disciplinary procedure based solely on the complaint received, for which knowledge of the identity of the author of the report is absolutely essential to the defence of the accused.
Therefore, Whistleblowing represents an important pillar of the security system of Aprile.
Thanks to secure communication protocols and encryption systems, the portal:
- Protects the identity of the reporter and does not disclose it without the explicit consent of the reporter;
- Protects the identity of the accused;
- Maintains the confidentiality of the information in all contexts following the report;
- Permits the computerised management of reports to company departments responsible for receiving and verifying them
Send a report
The personal data acquired as part of the reports are processed in full compliance with current privacy legislation, with particular regard to the identity of the reporting party The data controller is Aprile Spa with registered office in Via di Francia, 28 16149 Genova.