Since the start of its operations in 2006, Ansaldo STS has adopted the Organisation, Management and Control Model pursuant to Legislative Decree no. 231/2001, which deals, inter alia, with bribery offences. The Organisation, Management and Control Model has been adopted by the preexisting Italian Group companies (merged into the Parent Company in 2009) since the enactment of Legislative Decree no. 231/2001. The employees of Ansaldo STS S.p.A. are required to comply with the Organization, Management and Control Model and the corporate procedures that specify the operational procedures of the various corporate processes. Among these procedures is a procedure, which is applicable to all Group companies, which regulates the procedures for selecting and managing agents and providers of services to support business activities in order to ensure transparency and traceability in relation to these subjects.
In case of corruption events (which have never occurred so far in the Group), the reaction would be the disciplinary sanction as required by the Model, which also provides for dismissal without notice. The main risk areas, which include both those exposed to direct risks and those which support the commission of bribery offences, and which are subject to the formalities required by the Organisation, Management and Control Model are: sales, management of orders, sites, administration, finance and control, HR and soft loans. All the employees are given an information notice whenever the Model is subsequently updated. Certain employees who have been identiﬁed as operating within the areas subject to the risk of crime, or executives and middle managers of the company, received a speciﬁc e-learning training on the occasion of updates of the Organisation, Management and Control Model and of the regulations under Legislative Decree no. 231/2001. The same persons also sign periodical statements to attest to the compliance with the Organisation, Management and Control Model and, where applicable, the statement also speciﬁes the most signiﬁcant relationships maintained with representatives of public administrations.