Compliance & Ethics

Anti-corruption and the prevention of corporate crimes

Ansaldo STS has adopted the Organizational, management and control model (the “Model”) pursuant to Legislative decree no. 231/2001, which deals with, inter alia, corruption against the public administration and in the private sector. The Model has been adopted in the Group’s pre-existing Italian companies (which merged into the parent in 2009) since the introduction of Legislative decree no. 231/2001.

Ansaldo STS S.p.A.’s employees are required to comply with the Model and the procedures, which specify the operating methods of the various company processes.

These procedures relate, in particular, to the following:

  • advisors and sales representatives;
  • sponsorships, publicity campaigns and contributions to associations and bodies;
  • conferral of advisory engagements and professional services;
  • gifts, hospitality, facilitating payments and entertainment expenses;
  • M&As (mergers and acquisitions).

These procedures have been adopted in line with the former parent Finmeccanica’s initiatives to strengthen the internal control system, concerning, in particular, corruption and corporate crimes. Several audits were performed to check their actual implementation. In the event of acts of corruption (which has never occurred in the Group so far), Ansaldo STS would respond with the disciplinary sanction provided for by the Model, which also includes dismissal without notice.

The main risk areas, including direct risks and the areas that could potentially facilitate acts of corruption, subject to the requirements of the Model, are mainly the sales area, contract management, procurement, sites, administration, finance and control, HR and soft loans.

In order to ensure that all employees are completely familiar with the Model, they receive reports when it is updated. In addition, a new e-learning training programme was carried out in 2014 for nearly all company employees. Employees working in the areas at risk of these crimes being committed, along with the company’s managers and junior managers sign periodic statements of compliance with the Model and, where applicable, statements describing the most significant relationships with customers and representatives of the public administration.

Human rights12

Ansaldo STS upholds and promotes human rights in every context in which it operates, by creating equal opportunities for its people and fair treatment for all - regardless of race, nationality, political creed, religion, gender, age, minority status, disability, sexual orientation, personal or social condition – and always respecting the dignity of each individual and each employee (code of ethics).

12. Ansaldo STS acts in accordance with the UN’s International Bill of Human Rights (which includes the Universal Declaration of Human Rights, the International Convention on Civil and Political Rights and the International Convention on Economic, Social and Cultural Rights), the ILO’s Fundamental Conventions (nos. 29, 87, 98, 100, 105, 111, 138 and 182), the Declaration on Fundamental Principles and Rights at Work, the UN’s Convention on the Rights of the Child, the ILO’s Conventions nos. 107 and 169 on the Rights of Indigenous and Tribal Peoples, the European Convention on Human Rights and the OECD’s guidelines for multinational enterprises.

Labour13

Ansaldo STS offers equal opportunities, ensuring fair treatment on the basis of individual expertise and abilities and hiring people under legal employment contracts, mainly on an open-ended basis, in accordance with laws, national labour agreements, company agreements and current regulations.

Over the course of employment, training is a crucial lever to make the most of human resources and update their skills to the market context, thereby expanding upon the abilities and knowledge of each employee, in line with the company’s values. Ansaldo STS also applies a policy based on the recognition of one’s merits and equal opportunities. Ansaldo STS’s internationalisation process has also consolidated work experience abroad, thereby enabling people to share their different experiences and foster the value of multiculturalism.

Ansaldo STS guarantees that its workers are free to join trade unions, and sees that its relationships with the unions are cooperative and friendly in which workers may report their opinions to Human Resources directly or via delegates.

Child labour

Ansaldo STS does not allow and does not tolerate employment situations that violate current regulations on child labour, women’s labour and immigration. This also applies to its external contractors, suppliers and business partners.

Forced labour

Ansaldo STS carefully monitors the risk of forced labour.

In addition, the company requires its contractors and sub-contractors to guarantee the same in order to contribute to the abolition of such illegal practices.

13. See: Human resources

Reporting on commitments

IN 2014 WE SAIDIN 2015 WE DID
COMPLIANCE & ETHICS
  • Include the new predicate crime of self-laundering in the Organizational, management and control model as per Legislative decree no. 231/01
  • The risk assessment for the predicate crime of selflaundering was carried out in 2015. The Model was updated in February 2016 to include such crime and other regulatory changes pertaining to 2015.