In compliance with the standards set forth by the new international standard, UNI EN ISO 37001: 2016 - Anti-Bribery Management Systems, which “specifies requirements and provides guidance for establishing, implementing, maintaining, reviewing and improving an anti-bribery management system", in order to prevent cases that could take the form of bribery offences, ALD Automotive Italia has adopted a voluntary management model, in accordance with the standard, establishing guidelines in its own Manual, the scope of application, the policy, the procedures for whistleblowing management and everything appropriate to ensure correct application thereof.
The Anti-Bribery Management Model is aimed at ensuring conduct based on the criteria of correctness, loyalty and moral integrity. Together with whistleblowing, it constitutes an additional element of the company's strategic security project and reputational risk protection.
The company, in fact, favours, encourages and allows whistleblowing, in good faith or on the basis of a reasonable belief and with the guarantee of anonymity, on attempted, alleged and actual bribery or any violation or shortcoming related to the Anti-Bribery Management System, the Code of Ethics and the Organisational Model.
[Certificato ISO 37001]
All whistleblowing may be undertaken to the Head of the Anti-Bribery Management System, also anonymously, and is handled confidentially, in order to protect the identity of the whistle-blower and other parties involved and/or mentioned in the report.
Any kind of retaliation against those whistleblowing is forbidden and the company undertakes to protect whistle-blowers from retaliation in the event of reports relating to acts of attempted, certain or presumed bribery or violations concerning the Anti-Bribery Policy or Anti-Bribery Management System.
To this end, ALD Automotive Italia provides qualified personnel, including external staff, who can expertly address what to do if faced with a suspect or a situation that may involve acts of bribery. Moreover, they provide periodic information sessions concerning the topic of "Reporting Suspects".
All reports may be forwarded to the e-mail address: firstname.lastname@example.org.
The Head of the Anti-Bribery System records all whistleblowing in the "Unlawful Conduct Report" form and, before deciding how to deal with the Report, communicates it to the Chief Executive Officer and to the superior of the party concerned, in order to assess the known facts and the potential seriousness of the matter. If they do not have sufficient information to reach a decision, they arrange specific investigations into the subject of the whistleblowing. To ensure an adequate level of application and oversight of its management system, ALD Automotive Italia has requested certification by a third party.
WHISTLEBLOWING management system
The Group's commitment to fighting corruption has now become a primary objective.
The agreements with US authorities require the Group to report “overt or alleged behaviour that may constitute a case:
- of bribery of a public official wherever occurring;
- of fraud in the event of a link with the United States, including but not limited to, market manipulation or other types of "financial and commercial" fraud.
By virtue of these agreements, the failure to report a possible violation could have serious consequences for the entire Group.
The documents indicated in the links below help make the main concepts related to this subject even clearer and provide important operating instructions on the new whistleblowing system made available by the Group.