Business Ethics
Business Ethics
Sisal has always been committed to ensuring high standards in terms of ethical management of its activities.
We have established several principles, rules and ethical standards that guide the day-to-day activities of our people. The observance of these principles is ensured by carrying out training and awareness activities directed at all our personnel and, also, through monitoring activities and second-level controls, which ensure that our business ethics system is not only defined but also implemented and managed.
The key elements of our business ethics strategy are the following:
The key elements of our business ethics strategy are the following:
Organizational, Management and Control Model 231/2001
Code of Ethics and Conduct
Third Party Code of Conduct
Anti-corruption Management System and Anti-corruption Policy
Antitrust Policy
Anti-Money Laundering
Documents
Sisal SpA_Codice etico_EN.pdf
4,65 MB
Antitrust Policy.pdf
382 KB
Sisal Anticorruption Policy.pdf
1,98 MB
The Organizational Model as per Legislative Decree 231/2001
Sisal has adopted an Organizational, Management, and Control Model aimed at establishing a structured and comprehensive system designed to prevent the risk of committing crimes connected to corporate activity as outlined by Legislative Decree 231/2001, including attempted crimes, and more generally, to ensure correct behavior by all who act on behalf of the Company. The Model, which is constantly updated following legislative or organizational changes, strengthens the internal control and risk management system contributing to Sisal's sustainable success, makes everyone who operates in our name and on our behalf aware of the duty to comply with the provisions contained therein and, more generally, with legal and company regulations. It emphasizes that all illegal behaviors are condemned, regardless of the pursued intent, even if inspired by a misguided social interest or the mistaken belief of acting in Sisal's interest or benefit. This is because such behaviors are contrary to the ethical principles that Sisal intends to adhere to and thus contrary to its interest.
Fundamental and interdependent elements of the Organizational Model are:
- Code of Ethics and Conduct;
- Organizational system, i.e. articulation of Sisal functions / departments and the roles and responsibilities assigned to them in respect of the principle of segregation of duties;
- Powers of Attorney / Delegation of Authorities;
- A system of protocols (known as Special Parts) and implementing procedures aimed at preventing crime risks, which defines the principles and ways of performing corporate activities in order to ensure the effectiveness and efficiency of processes in compliance with applicable legal provisions;
- Sanction system.
Furthermore, complying with Decree requirements, Sisal's Board of Directors appointed a Supervisory Body (SB), composed of a collegiate board. This body has autonomous initiative and control powers and oversees the operation and observance of the Organizational Model while also ensuring its updates. The SB is characterized by:
- independence: reporting directly to the Board of Directors so that it isn't subordinate to any corporate function;
- professionalism;
- integrity;
- continous action.
In particular, key duties include:
- verifying the actual ability of the Model to prevent the commission of crimes and administrative offenses under Decree 231/2001;
- monitoring the observance of the Model’s prescriptions, verifying the adherence between the actual behaviors and the definite Model, proposing corrective actions and the initiation of disciplinary proceedings;
- promoting updates to the Model, where needs related to new / modified relevant crimes and administrative offenses under Decree 231/2001 or organizational changes are identified, or following vigilance activity which uncovers significant violations, in relation to which the SB makes adjustment proposals;
- making awareness proposals regarding corporate administrative liability issues;
- monitoring adequate training and constant information of the employees related to the Model’s principles and prescriptions.
Code of Ethics and Conduct
To successfully navigate the complexity of our operating context, it's crucial to clearly define the set of values that Sisal aspires to and expects to be respected. For these reasons, we have prepared the Code of Ethics and Conduct, a fundamental document which contains the values that guides us in conducting our activities.Our Code of Ethics and Conduct aims to ensure utmost transparency and integrity in every aspect of our business activity, promoting professional ethics and legality, respect for laws and human rights, environmental protection, and social responsibility. It represents the fundamental charter of values and principles at the foundation of our corporate culture and reliability. These inspire our management policies and our conduct in carrying out daily professional activities.
The Code of Ethics and Conduct is based on principles of integrity, respect, commitment, and transparency, and represents the reference point for all our activities. Our goal is to generate widespread well-being for all our stakeholders, ensuring long-term sustainable growth in line with the Sustainable Development Goals (SDG) defined by the United Nations' 2030 Agenda.
Code of Conduct for Third Parties
Respect for human rights, labor, the environment, prevention of corruption in relationships between private entities and with public administration, implementation of measures on information security and privacy, as well as a commitment to responsible gaming are some of the principles to which Sisal has chosen to inspire its business activities with all parties involved (workers, suppliers, customers and other third parties).
Consequently, we require their concrete implementation by all involved parties (stakeholders) and especially by all third parties who wish to maintain any business relationship with us.
For this reason, and in order to ensure that our commercial partners conform to our values and principles in carrying out their activities, we have adopted a specific Code of Conduct for Third Parties. We require this Code to be concretely implemented by anyone wishing to maintain any business relationship with us.
Consequently, we require their concrete implementation by all involved parties (stakeholders) and especially by all third parties who wish to maintain any business relationship with us.
For this reason, and in order to ensure that our commercial partners conform to our values and principles in carrying out their activities, we have adopted a specific Code of Conduct for Third Parties. We require this Code to be concretely implemented by anyone wishing to maintain any business relationship with us.
Anti-corruption Management System and Anti-corruption Policy
Sisal adopts a zero-tolerance approach towards corruption. For this reason, and consistently with our values system and emphasis on Corporate Governance, we have implemented an ISO 37001:2016 certified Anti-corruption Management System, which integrates with the Organizational, Management and Control Model pursuant to Legislative Decree 231/2001.
In this context, Sisal has adopted a specific Anti-corruption Policy which establishes a systematic reference framework of ethical-behavioral principles and anti-corruption rules, further raising awareness on the behaviors that must be observed by members of the Group. The main objectives of the Policy are to:
- prohibit corruption (active e passive, public e private) and ensure compliance with the highest national and international anti-corruption standards;
- promote and develop a commitment to the continuous improvement of the Anti-corruption Management System;
- encourage reports of any suspected attempted, certain, or alleged act of corruption act through dedicated channels and methods.
Furthermore, third parties collaborating with Sisal are required to adopt similar anti-corruption safeguards such as policies, procedures and/or dispositions aimed at preventing even attempted corrupt practices involving their administrators, employees and collaborators. They must promote an integrity culture within their organization and commit to maintaining these safeguards effectively implemented for the entire duration of the collaboration, obliging themselves to fully adhere to the principles of Sisal's Code of Ethics and Anti-Corruption Policy.
The Antitrust Policy
We are fully aware that a proper incentive for competition and observance of consumer protection norms are essential elements for the development of the markets in which we operate: hence, we believe that it is fundamental to conduct our activities fairly and transparently, ensuring full compliance with competitive and consumer principles.
The Antitrust Policy falls within the scope of numerous initiatives undertaken by Sisal to promote the knowledge of the matter and it is part of a broader antitrust and unfair commercial practices compliance program carried out in accordance with the Guidelines published by AGCM in 2018, as well as national and European best practices.
The document outlines the principles underlying Antitrust laws and Consumer Code, and retraces the various stages of Sisal's compliance program adoption. This program is aimed at preventing and minimizing the risk of potential violations of Italian and European competition laws, as well as promoting an antitrust culture within the Group.
Anti-Money Laundering
We are strongly committed to preventing the use of our services for money laundering and terrorism financing purposes. We have established a specific control infrastructure designed to identify, mitigate, manage, and monitor significant risks in this area.
For more details, please consult the dedicated page by clicking here.
