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Group Compliance

Corporate compliance refers to the conformity of all business activities with procedures, regulations, legal provisions, and codes of conduct. The main purpose of compliance is to protect the company from legal and reputational risks.

Quality Health, Safety and Environmental (QHSE) Policy

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. 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.

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Code of Ethics

Aprile S.p.A in carrying out its activities complies with the laws and regulations in force in all of the countries where it does business. The Company acts in observance of the principles of liberty, dignity of the human person and respect for diversity, rejecting any discrimination based on gender, race, language, personal and social conditions, and religious and political beliefs. The Company seeks to build its own growth by strengthening an image that is true to the values of fairness and loyalty. It believes therefore that the respect for ethical rules and transparency in the conduct of business is a necessary condition, as well as a competitive advantage, in order to pursue and achieve its objectives. To this end, Aprile S.p.A. promotes the creation of an environment featuring a strong sense of ethical integrity, in the firm belief that such an aspect is crucial for the effectiveness of policies and control systems, affecting conduct that might otherwise escape most sophisticated supervision systems.

Therefore, the Company has adopted a document, called “Code of Ethics” which governs the rights, duties and responsibilities that Aprile S.p.A. assumes while performing its corporate activities towards all stakeholders that deal with it directly or indirectly and that are capable of influencing its activity or are influenced by it.

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Anti-Corruption Guidelines

These Anti-Bribery Guidelines are a policy document issued by the company’s top management to identify and set up anti-corruption strategies by specifically analysing the risks of bribery that can be actually identified in the company and by drawing up relevant protocols, regarded as organisational tools to prevent the risk of bribery. The aim of the Anti-Bribery Guidelines therefore is to identify specific ethical and behavioural rules for combating bribery, which establish as illegal all of those activities carried out by employees, consultants and associate workers for or on behalf of the company, which allow the latter, either directly or indirectly, to achieve an illegal interest and/or advantage. The effective and tangible implementation of the Anti-Bribery Guidelines is ensured not only through adequate personnel reporting/training but also by using a system of specific surveys and/or by gathering and analysing information, reports and violations. In order to ensure effective application of the document, disciplinary measures are applied in the event of a breach, regardless of whether these breaches have actually led to corrupt behaviour or have exposed the Company to sanctions.

Aprile S.p.A does not accept any form of bribery and is committed to abiding by the anti-bribery laws in force in all countries in which it operates. The purpose of the Guidelines is to guarantee principles of transparency and to ensure clarity with regard to permitted conduct and compliance with relevant anti-bribery legislation wherever Aprile S.p.A conducts its business.

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Legislative Decree 231/2001

Pursuant to the Italian Legislative Decree no. 231 on the administrative liability of companies, Aprile S.p.A has implemented an Organisation, Management and Control Model which ensures accuracy and transparency when conducting business and aims to prevent crimes committed in the interest of or to the advantage of the company.

According to Italian Legislative Decree no. 231 of 8 June 2001, companies and all organisations in general may be called to respond in criminal proceedings, and therefore incur sanctions, to any crimes committed in their interest or benefit by the directors, employees and other parties who operate in the name or on behalf of the organisation or company. In particular, the Decree considers crimes in relationships with the Public Administration, corporate crimes, crimes linked to safety in the workplace and the environment, organised crime, terrorism, cyber crime, crimes against industry and commerce, crimes against individuals etc. To minimise the risk of these crimes being committed, each company is obligated to implement an “Organisation and Management Model”, that is, a set of regulations and procedures, including the adoption of a Code of Ethics and set of Anti-Corruption Guidelines, the establishment of a Supervisory Board and implementation of a control and sanctions system. The adoption and effective implementation of the Model and the appointment of the Supervisory Board allow the organisation to benefit from the hold harmless clause in the event of crimes.

The Aprile “Model 231” is a dynamic and shared document. It is dynamic because it is sensitive to all regulatory and organisational changes. It is shared because its creation involves all of the company population, both in the phase prior to drafting, via the risk assessment, and in the implementation phase, through training and information.

Supervisory Board of Aprile S.p.A 

The Supervisory Board of the Company (hereafter referred to as SB) is a collective body, provided with powers of initiative and control, whose members, selected by the Board of Directors, must possess the traits of autonomy, independence, professionalism, continuity of service and integrity. The SB is tasked with duties of supervising compliance with the provisions of the Model, the effectiveness of the Model and the opportunity to update it, in addition to operative duties linked to the application of the Model.
The Board of the Company Aprile S.p.A. is composed of three members, who are all external:

Chairman: Dr. Michele Gucci
Member: Dr.ssa Alessia Bastiani 
Member: Dr. Vieri Chimenti

Monitoring and updating the Model

All areas at risk of crimes being committed pursuant to Italian Legislative Decree 231 and the rules of conduct in the Model are the product of an analysis of corporate documentation and meetings with personnel, in order to adapt the Model to the characteristics of the Company.

The Aprile Model undergoes continuous assessment to evaluate its efficiency and guarantee it is updated according to internal changes (in the organisational structure, in business activities…) and external changes (legislative changes, best practices…).

Training and information

The training of personnel is an essential element for the efficient implementation of the Model. Therefore, a training plan has been devised which includes both classroom sessions and e-learning modules with diversified content based on the addressees and which uses concrete examples. For the purposes of evaluating the quality of teaching, upon completion of the courses, tests will be distributed on the subjects of the lesson.

Reporting Violation of the Organisational and Management Model

Reports of violation of Model 231 can be sent through the internal channel activated by the Company and indicated in the “Whistleblowing Procedure”.

Whistleblowing

Aprile S.p.A 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 S.p.A has always been particularly attentive to the prevention of risks which could compromise the responsible and sustainable management of its business. For this reason, the Reporting Procedure – Whistleblowing 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 procedure is part of the internal control tools adopted by the Company Aprile S.p.A 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 may also be anonymous. 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 attachments.

The corporate body responsible for the management of the reports is the Whistleblowing System Manager. 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 S.p.A.
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

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Privacy Information

The personal data acquired within the reports are processed in full compliance with current privacy legislation, with particular regard to the identity of the reporter. The Data Controller is Aprile Spa with registered office in Via di Francia, 28 16149 Genova.

 
 
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