Compliance & Ethics

Anti-corruption and the prevention of corporate crimes

In order to ensure that the conduct of all those operating on the company’s behalf or in its interests is always consistent with the principles of correctness and transparency in business dealings and company activities, Ansaldo STS has adopted an Organizational, management and control model (the “Model”) in line with the requirements of Legislative decree no. 231/01 and the guidelines issued by Confindustria, Italy’s main Organization representing Italian manufacturing and service companies.

The code of ethics is an integral part of this Model. The company has also set up a supervisory body to monitor application of the Model.

The Company ensures that all employees are completely familiar with the Model by providing them with informative reports when it is updated. Employees working in risk areas, as well as executives and managers, sign periodic statements to certify the respect of the Model and, when needed, to describe the most significant relationships with customers and representatives of public administration.

The Model was most recently updated with the board of directors’ resolution of 27 February 201710. This latest update was adopted mainly in order to introduce (i) the offence of organ trafficking provided for by Italian Law 236 of 11 December 2016, which introduced art. 601 bis to the Italian Criminal Code, in Special Part “F” of the Model dedicated to “Conspiracy” and (ii) the new offence of unlawful brokerage and labor exploitation provided for by art. 25-quinquies of Italian Legislative decree 231/01, introduced by Italian Law 199 of 29 October 2016 by amendment of art.

603 bis of the Italian Criminal Code, to Special Part “C1” of the Model dedicated to “Offences of employing citizens of third-party countries whose stay is irregular and the reduction to slavery or its maintenance”.

The Model is available on the company’s web site.

Ansaldo STS S.p.A.’s supervisory body has several members, including two external members, one of whom serves as Chairman, and both of whom were selected among academics and professionals with demonstrated expertise and experience in legal, economic and financial issues, as well as one internal member who is the interim General Counsel & Compliance manager.

The board of directors approved the current composition on 16 May 2016 after expiration of the three-year appointment of the supervisory body, so all previously appointed members of the body were confirmed for another three years. Any conduct contrasting with the ethical principles described in the code of ethics or the indications in the Organizational, management and control model pursuant to Legislative decree no. 231/01 can be anonymously reported to the supervisory body, which evaluates the reports in accordance with the relevant company procedure currently in place.

In this respect, in 2016, no reports were made and no sanctions were imposed following violations pursuant to Legislative decree no. 231/01.

Human Rights protection and labor policies1

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.

Ansaldo STS does not allow or tolerate the establishment of employment relationships, even by external collaborators, suppliers or business partners, violating the existing legislation on child, woman and immigrant labor, and carefully controls the risks associated with the employment of forced workers. The Company, besides, requires its contractors and subcontractors to ensure the same attention in order to contribute to abolish such illegal behaviors.

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 labor agreements, company agreements and current regulations. 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.

1. 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.