POLICY FOR THE PREVENTION OF CORRUPTION

The Vigilance Institute Vigilpol considers it appropriate to implement all necessary actions to prevent any act or behaviour that could generate a corrupt event and, to guarantee this, implements the following preventive measures:

• Prohibits in absolute terms behaviours that could be construed as corruption or attempted corruption or inducement to corruption;
• Respects personally and requires compliance with current legislation on the prevention and contrast of corruption throughout the Italian territory in which it operates for all employees, collaborators, partners, business associates and suppliers;
• Identifies potential risk areas and identifies and implements suitable actions to mitigate those risks;
  Commits to meeting the requirements of the management system for the prevention of corruption, ensuring constant implementation and the pursuit of continuous improvement;
• Encourages the reporting of good faith suspicions based on reasonable and confidential conviction without fear of retaliation. To this end, the email address wbl@vigilpol.com has been created for the reporting of any suspicious event;
• Promotes awareness among business associates involved in sensitive activities, requesting acceptance of the policy and acceptance of the controls required by the management system for the prevention of corruption;
  
• Promotes constant training and information for personnel, collaborators, clients and suppliers on the policy, the system for the prevention of corruption, and relevant regulatory updates;
  
• Encourages awareness among personnel and collaborators to recognise a corrupt event or even just an attempt and to report it even anonymously;
  
• Requests all personnel and collaborators to refer to the Corporate Anti-Corruption Function for any matters related to corruption and the management system. The anti-corruption officer is an external figure, independent, that is not involved in the organisation's activities exposed to the risk of corruption, with adequate skills, delegated and tasked with supervising the design and implementation of the management system;
  
• Informs that failure to comply with the policy may result in the application of the company's sanctioning system.