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The RGI Group is firmly committed to combating corruption in all its forms, aware of the negative effects of corrupt practices on economic and social development and the reputational damage that can result from the violation of anti-corruption regulations. The RGI Group places values such as transparency, ethics and respect for legality at the core of its corporate culture, all fundamental elements to promote an environment marked by business integrity.
In carrying out its activities, the RGI Group adopts a “zero tolerance” policy toward all corrupt behaviour, committing itself to preventing the risks of unlawful practices at all levels and in all geographical areas. This commitment is realized through the dissemination and promotion of ethical principles, the adoption of clear rules of conduct and the implementation of rigorous control processes, in compliance with applicable regulations and international best practices.
As a concrete demonstration of the RGI Group’s commitment to fighting corruption, a Compliance Program has been adopted, that is based on a solid architecture of principles and tools. At the heart of this system lies the Code of Conduct, which defines the core values by which the RGI Group is inspired to achieve its objectives and the essential principles for responsible business management. The Group Compliance Program is further enriched by the adoption of a Group Anti-Corruption Policy. In addition, RGI S.p.A., the parent company, has adopted the Organisation, Management and Control Model pursuant to Legislative Decree 231/2001, which keeps constantly updated to respond effectively to regulatory and operational requirements, which is also relevant for the subsidiaries for their respective areas of responsibility.
In particular, the Group Anti-Corruption Policy defines concrete measures to prevent and fight all forms of corruption, both in the public and private sectors.
The Group Anti-Corruption Policy is prepared for application to all subsidiaries, in the countries in which they operate, providing for each company a useful framework for the identification, review and achievement of anti-corruption objectives defined in accordance with the Policy.
With the aim of providing its recipients a useful tool, the Group Anti-Corruption Policy not only contains general principles with which the recipients must comply, but also provides:
- types of prohibited conduct and the supplementary elements of the individual cases, both in the public and private sectors
- prohibited conduct in relation to other crimes with the Public Administration
- specific examples of forms of corruption in the different sensitive areas identified in the RGI Group.
Taken together, all of these tools constitute an integrated system of rules and principles that guide the day-to-day actions of the RGI Group, ensuring that activities are conducted ethically and in full compliance with current regulations, strengthening the effectiveness of our approach to managing the risk of wrongdoing and promoting transparent and accountable corporate governance.
For the RGI Group, operating with integrity is not only an ethical duty, but a core value that guides our strategy and relationship with employees, customers, suppliers, and other business partners as well as the communities in which we operate.
ORGANIZATIONAL MODEL UNDER LEGISLATIVE DECREE 231/2001
Legislative Decree No. 231/2001 (also the “Decree”) introduced into the Italian legal system the regime of administrative liability of corporations for certain crimes committed in their interest or to their advantage by individuals in top management positions or persons subject to their direction or supervision. The administrative liability of the corporation is independent of the criminal liability of the natural person who committed the crime and stands alongside the latter.
The Decree provides a specific form of exemption from such liability if it appears that the entity has adopted and effectively implemented “models of organization, management and control” that are suitable for preventing, with reasonable certainty, crimes similar to the one that occurred.
THE 231 MODEL IN RGI
In order to avoid the possible commission of the offenses contemplated by the Decree, RGI S.p.A. has adopted its own model of organization, management and control (“Model 231”), aimed at preventing both the risk of the relevant offenses being committed and, consequently, the administrative liability of the Company. Model 231, adopted starting from an accurate analysis of the company’s activities aimed at identifying areas potentially at risk, constitutes a set of general principles, rules of conduct, control tools and organizational procedures, as well as encompasses information and training activities and the disciplinary system, aimed at ensuring, as far as possible, uniformity of application for the prevention of the commission of crimes.
With the adoption of Model 231, the Company has equipped itself with a complex system of rights, duties and responsibilities, as well as protocols that, as a complement to the system of attribution of functions and delegation of powers and other internal organizational tools, all have the purpose of ensuring adequate transparency and knowability of the decision-making and financial processes, as well as the conduct that must be kept by the recipients of Model 231, both in the phase of prevention of crimes and in the phase of control of the effective implementation of Model 231.
In fact, among the purposes of Model 231 is to develop awareness in the Recipients (employees, collaborators, suppliers, consultants and third parties in general) who operate in processes at risk that they may incur offenses that entail sanctions both against them, as reported in the disciplinary and sanction system of Model 231, and against the Company, through adequate internal training and communication of Model 231 to the outside world.
IN DETAIL
RGI S.p.A. periodically adjusts its Model 231 (the last update was on November 9, 2023) to regulatory developments, as well as to changes in the company’s organization, such as corporate change and revision of the company’s internal processes. In particular, the latest regulatory updates of Model 231 include the amendments to the Criminal Code introduced by Law 22/2022, the introduction of new criminal offenses into Legislative Decree 231/2001 by Legislative Decree 184/2021 and Legislative Decree 19/2023, and the transposition of the European legislation on whistleblowing that occurred with Legislative Decree 24/2023.
THE SUPERVISORY BODY
RGI has entrusted a Supervisory Body with the task of supervising compliance with the requirements of Model 231, verifying their actual effectiveness and assessing the need for any updates. The Supervisory Board was appointed in the person of Mr. Emiliano Nitti (Chairman), Dr. Enrico Calabretta and Mrs. Silvia Tironzelli..
REPORTS, EVEN ANONYMOUSLY, RECEIVED BY RGI
The top management, all employees and collaborators of the Company are required to report, even in confidential or anonymous form, any unlawful conduct, commission or omission, which constitutes or may constitute a violation or suspected violation of the 231 Model and the Code of Ethics or unlawful conduct relevant under Legislative Decree 231/2001 integrating specific types of offenses, of which they have become aware by reason of the functions performed.
In this regard, the Company has provided for the Speak Up! computer reporting channel and adopted, in implementation of the provisions of Legislative Decree No. 24 of 2023, a group policy to which the Model refers and an excerpt of which can be found in the dedicated section with all the information useful for the submission and management of reports.
THE 231 MODEL IN RGI GROUP
Although the Decree has direct validity only for companies headquartered in Italy, establishing their administrative liability for unlawful activities committed both in Italy and abroad in the interest or to the benefit of companies headquartered in the Italian territory, the adoption and updating of Model 231 also applies to other RGI Group companies headquartered abroad, mainly in France, Germany, Tunisia.
RGI S.p.A., in fact, takes steps to sensitize the foreign subsidiaries, on the contents of the Italian law in order to implement an extensive control system, common to all the companies belonging to the Group, as well as to disseminate to the Group the values, principles and rules of personal and professional behavior that must be followed in the exercise of business activities through the adoption of a common code of conduct.
CODICE ETICO (EX D. LGS. n. 231/01) 
Modello di Organizzazione e Gestione (EX D. LGS. n. 231/01)
Courtesy extract of the Organization, Management and Control Model in English
Our Suppliers policies define the behavioural rules relevant for RGI Group to create transparent and lasting relationships.
Values and principles that inspire RGI Group in carrying out its activities, such as sustainability, safety, business conduct, conflict of interest, IP, environmental, data protection, and confidentiality, require also respect from RGI suppliers. in this section you can find our Suppliers’ Code of Conduct and the General Terms of Purchase