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Ethics
Ethics

Business Ethics

Ethical Code, Organisational Management and Control Model, and Anti-Corruption Policy



Ethics, transparency and compliance

Topics relating to ethics are considered strategically important by our Company and, in this context, particular importance is placed on compliance with internal and external regulations and codes of conduct, the highest standards of integrity, and the absence of conflicts between corporate and personal interests.

To ensure compliance with the standards and principles of ethics, transparency and compliance in all business activities, Ray Way has adopted a set of documents, procedures and policies.


Code of Ethics

The Code of Ethics regulates the set of rights, duties and responsibilities that we assume towards the stakeholders with whom the Company interacts.


Organisational, Management and Control Model

The Organisational, Management and Control Model pursuant to Legislative Decree no. 231/2001 which is designed to prevent and reduce the risk of crimes and offences being committed in the course of our business activities (of which the Code of Ethics is in any case an integral part).


Anticorruption Policy

The Anti-Corruption Policy aims to counter specific forms of corruption and illegality, and contains additional measures compared with the Organisational, Management and Control Model.

The compliance framework adopted by Rai Way, which includes the aforementioned main documents, is also an integral part of its Internal Control and Risk Management System (ICRMS), the ultimate assessment and responsibility for which lies with the Board of Directors - with the support of the Control, Risks and Sustainability Committee, established within the Board itself - which defines the guidelines of the ICRMS, evaluating its adequacy and effectiveness at least twice a year, also in relation to relevant ethical and anti-corruption issues.




Code of Ethics

Approved by the Board of Directors, the Code of Ethics defines the set of values that the Company recognises, accepts and shares, and the responsibilities it undertakes.

It contains the principles of ethics and conduct that are to underlie the work of those who operate or otherwise interact with Rai Way on an ongoing or temporary basis, taking account of their respective roles, the complexity of their functions, and the responsibilities assigned in order to pursue the goals of the Company.

The Code provides for the respect of ethical principles related to fairness and transparency, honesty, compliance with the law, professionalism, impartiality, value of human resources, integrity of people, confidentiality, responsibility towards the community, sustainability and fairness in competition.

The addressees of the Code of Ethics are:

  • the corporate bodies, the Chief Executive Officer, the General Manager, the other managers and employees ("corporate representatives");
    all employees, including occasional or temporary ones;
  • all those who have commercial and/or financial relations of any kind with Rai Way, or who act on behalf of Rai Way on the basis of specific mandates (consultants, suppliers, partners, agents, dealers, intermediaries, etc.);
  • all company representatives and external collaborators of the subsidiaries.

Read Rai Way's Code of Ethics




Model 231

The Organisational, Management and Control Model pursuant to Legislative Decree no. 231/2001 (the “Model 231”) was approved by the Board of Directors in December 2006 and has been kept constantly up-to-date.

It consists of a General Section and a Special Section:

  • The General Section describes the contents and impacts of Legislative Decree No. 231/2001, as well as the basic principles and objectives of the Model, the duties of the Supervisory Board, the methods of adoption, dissemination, updating and application of the contents of the Model, and the provision of the disciplinary system.
  • The Special Section defines the principles of conduct and the management rules that all Model recipients must follow in order to prevent, in the context of the specific activities carried out by Ray Way and considered “at risk”, the commission of offences envisaged by Legislative Decree no. 231/2001, and to ensure conditions of correctness and transparency in the conduct of such activities

Read the Organisation, Management and Control Model


Supervisory Board

The Supervisory Board, endowed with autonomous powers, is appointed to:

  • assess the adequacy of the Model and its suitability to prevent the commission of the offences referred to in the Decree;
  • monitor the compliance of conduct with the provisions of the Model, highlighting any deviations, also in order to adapt the Model to the activities actually carried out;
  • ensure the update of the Model, both through a preventive phase of analysis of the changed company conditions, and through a subsequent phase of verification of the functionality of the proposed changes.

The current Supervisory Board of Rai Way is composed of three members, two of whom are external.

  • External member serving as Chair: Alberto De Nigro.
  • External member: Enrico Mezzetti.
  • Internal member: Maria Cristina Brotzu, Manager of the Company’s Internal Audit Department.

Read the Statue of the Supervisiory Board



Anti Bribery

The Company has adopted a specific Anti-Corruption Policy and set up an internal organisational structure, with the appointment of a company contact person.

The corruption-prevention measures aim to define an internal control and corruption risk prevention system integrated with other “control governance” tools (Legislative Decree Model no. 231/2001 and the Code of Ethics), intending to introduce additional measures or strengthen existing ones by coordinated action for an even more effective fight against corruption and illegality.

The Company envisages constant measures to oversee the ban on making unlawful payments to any supplier, partner or collaborator, in particular prohibiting transfers of money between current accounts not adequately justified by commercial transactions, payments for services not actually rendered or provided and payments by untraceable means.

The Company also provides for a preliminary assessment concerning:

  • the absence of corruption-related offences attributable to parties from whom goods and services are to be procured;
  • compliance with the Company’s principles and measures, particularly those relating to corruption prevention, in the context of contractual relationships.

The Anti-Corruption Policy is communicated to employees through publication on the Company's intranet site and is the subject of training initiatives.

Suppliers, business partners, and collaborators are required to comply with the Code of Ethics, 231 Model (see above) and the Anti-Corruption Policy in passive, active and consultancy/collaboration contracts with specific termination and safeguard clauses, whereby the counterparties declare that they have read these documents and undertake to abide by the principles expressed in them in the performance of the contracts.


Read the Anticorruption Policy



The company contact person for anti-corruption measures

Consistently with the provisions of the Anti-Corruption Policy, the Company has identified a contact person for anti-corruption measures, who, with the coordination of the Supervisory Board pursuant to Legislative Decree no. 231/2001, ensures the functioning of the system for the prevention of corruption, also by verifying the adequacy and effective application of the anti-corruption measures. Contact: rpc@raiway.it