Code of Ethics

The code of ethics clarifies the commitments and responsibilities that should guide the company’s business and activities, requiring compliance by anyone involved in any way with Ansaldo STS.

The code of ethics is available on the company’s web site11. It is a key element of the internal control system, and compliance with it enables Ansaldo STS and the group companies to prevent certain irregularities or illegal acts prohibited by the regulations of the various countries where Ansaldo STS operates, particularly Legislative decree no. 231/01 in Italy.

The code of ethics was formally adopted for the group companies by resolution of the respective boards of directors or equivalent management bodies. It was shared with all group personnel using the same methods as those applied by the parent Ansaldo STS.

In addition, a code of ethics control body was set up within each group company to promote the implementation of the code of ethics. A special information channel for the code of ethics was also created, and can be used to report any conduct that is inconsistent with the principles of the code of ethics by sending an email. The reports are sent and managed in accordance with a group procedure.

2015 events

In 2015, the code of ethics control body received reports of violations of the code related to Ansaldo STS Australia and Ansaldo STS USA. With respect to the three violation reports concerning Ansaldo STS Australia, no violations were ascertained.

The control body also received two requests for interpretation of the code of ethics. The code of ethics control body of Ansaldo STS USA received two reports from some local managers concerning alleged bullying and harassment. These issues were managed by the human resources department.

Training on the code of ethics

Ansaldo STS relentlessly promotes and fosters awareness of the code of ethics and the related protocols and updates, as well as knowledge of the areas of activities in the various functions with responsibilities, hierarchical relationships, duties and training. It informs employees on the code of ethics and the related protocols first by distributing specific documentation to all employees and workers collaborating with the company in any way, and requires, when the material is delivered, that they sign a statement certifying that they have read the documentation received.

In addition, company personnel can, at any time, ask supervisors for guidance and clarifications on the content of the code of ethics, protocols and duties assigned to them. When new employees are hired and/or contracted, Ansaldo STS immediately gives them the information necessary for adequate knowledge of the code of ethics and protocols, with particular respect to those that concern them specifically.

11. http://www.ansaldo-sts.com/sites/ansaldosts.message-asp.com/files/downloadspage/asts_cod_etico_italiano.pdf