SACE is strongly committed to preventing and countering corruption in all areas of its own operations.
As a practical fulfilment of this commitment, SACE has equipped itself with suitable business structures within its own system of corporate governance aimed at countering and preventing the risk of illicit actions and has adopted an organisational, management, and monitoring model that is compliant with the provisions of Legislative Decree 231/2001, as well as a Code of Conduct containing the whole set of ethical principles and values that all employees are expected to uphold.
Moreover, SACE undertakes specific know your customer control activities with respect to counterparties directly or indirectly involved in transactions. Thus, we require specific declarations and commitments and perform a careful due diligence to mitigate potential corruption risks.
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Below are the references to Model 231 of all SACE Group companies:
SACE: General Part
SACE BT: General Part
SACE FCT: General Part
SACE SRV: General Part
Whistleblowing: reports of misconduct
SACE and its subsidiaries make available to all employees and other stakeholders a platform ("whistleblowing") to report possible violations of the 231 Model, the Code of Ethics, internal regulations, both corporate and Group, anti-money laundering regulations as well as the TUF, CAP and MAR (in relation to SACE and SACE BT). The complainant must be aware of the facts in line with the functions performed.
In accordance with the whistleblowing law (legislative decree n. 24/2023), SACE and its subsidiaries guarantee the confidentiality of the identity of the whistleblower, also to protect the latter from any retaliation and/or discrimination that may occur as a result of the report made.
Except for cases in which confidentiality cannot be enforced by law, the Companies have appointed a person external to the organisation, a legal advisors, who ensures that the names of the reporting parties are kept separately from the contents of the reports, without knowing either nor the others. Upon justified request from the Whistleblowing Manager, if strictly necessary for the verification activity, the custodian can associate the name and content using encrypted codes provided for by the IT procedure.
It is recommended to read the "Report Management Policy", together with the privacy information relating to data processing, at this link.
In summary, the policy provides:
Who can report?
All those who hold representative, administrative or management functions, or who exercise, even de facto, the management and control of company activities, all employees regardless of the related contractual position, those who cooperate and collaborate with Group companies - for any reason - in the pursuit of their objectives and - more generally - anyone who has links with them also due to different legal relationships (e.g. suppliers, consultants, collaborators, partners, candidates, former employees, etc.)
What to report?
Violations of national or European Union regulatory provisions, or internal provisions of which they have become aware in a public or private working context. In any case, any report sent through the reporting channels referred to in this policy will in any case be taken into consideration within the limits of its relevance and verifiability.
How to report?
Who will receive the notification?
The manager of the internal reporting channels is identified as follows:
How is the whistleblower protected?
The protection of the confidentiality of the identity of the whistleblower is always guaranteed. Furthermore, the whistleblower is expressly required to give his consent to communicate his report to third parties other than managers in order to investigate the report. The whistleblower is protected from any retaliatory measures adopted.
External reporting channel (ANAC)
Reports to ANAC can be sent only if: