Anti-corruption system
Anti-corruption system

Anti-Corruption System

Anti-Corruption Model

In accordance with what is defined in the company’s Code of Ethics and in compliance with the 10th Principle of the Global Compact, according to which “companies pledge to fight corruption in all its forms, including extortion and bribery”, the formal and substantive commitment of Giovanni Putignano & Figli S.r.l. in the fight against corruption is embodied in the implementation of an Anti-Bribery System, managed in line with the requirements of UNI ISO 37001:2016 (Anti-Bribery Management System), including company procedures that define the roles and responsibilities of the individuals involved and the operating methods of the processes and control principals defined in the adopted Anti-Bribery Model.

The Anti-Corruption Model is configured as an element of the internal control system aimed at strengthening certain prevention protocols in order to exclude active and passive corruption conduct and ensure compliance with the principles introduced by anti-corruption laws and international best practices .

It provides a systematic framework of the regulatory tools and policies on anti-corruption that Giovanni Putignano & Figli S.r.l. intends to pursue, serving as a guide, both for internal staff and business associates, in dealing with corruption risks that might occur in the performance of company activities

In order to ensure the effective measures to provide assistance and advice on anti-corruption, and in accordance with the provisions of UNI ISO 37001:2016, Giovanni Putignano & Figli S.r.l. has established the Corruption Prevention Compliance Function (FCPC), which is responsible, among other things, for giving specialized guidance and providing clarification with respect to the content and implementation of the ABMS System, as well as the application of Italian Anti-Corruption Laws or the country in which the organization operates.

The FCPC is also entrusted with the ongoing review and monitoring of the ABMS System to ensure that it remains effective at the highest level, and with the verification activity to ensure that it is properly implemented.

The application of the ABMS System is the direct responsibility of the sole director, auditors, managers and all employees of Giovanni Putignano & Figli S.r.l., as well as all those who, directly or indirectly, permanently or temporarily, establish relationships and relations with the organization, each within the scope of their functions and responsibilities (Business Partners). All Business Associates are therefore expected to comply with all the principles and provisions contained therein with the utmost diligence and care.

In order to disseminate adequate knowledge and understanding of the contents of the AMBS System, Giovanni Putignano & Figli S.r.l. has defined:

  • a mandatory anti-corruption training program for all employees, modulated with a different degree of depth, depending on the qualification of the recipients and the different level of their involvement in sensitive activities;
  • An anti-corruption awareness program for all Business Associates;
  • specific contractual “compliance” clauses that include, among others, the obligation to comply with the principles contained in the organization’s Anti-Corruption Policy and ABMS System.

Sanctions System

Violation of the principles of the Anticorruption Policy and the prescriptions of the ABMS System by the organization’s personnel constitutes a serious breach of contract, which is why Giovanni Putignano & Figli S.r.l. reserves the right to sanction such violations in accordance with the legal and/or contractual regulations applicable to the individual relationship, both with conservative sanctions and through the termination of the contractual relationship itself (dismissal or withdrawal); it also remains and in any case without prejudice to the organization’s right to bring actions for damages in accordance with current legislation.

Business Associates are required to report any violation of the ABMS System, the Anti-Corruption Policy, and/or any anti-corruption law of which they have become aware, even indirectly, in the course of their business. Violation of the principles of the Anti-Corruption Policy and the requirements of the ABMS System by Business Associates constitutes a serious breach of contract, which is why Giovanni Putignano & Figli S.r.l. reserves the right to terminate any existing business relationship.


The Whistleblowing Platform is one of the channels of communication that allows employees, collaborators, consultants, suppliers of the organization and any other third party that has a relationship with the company to send, even anonymously, reports on alleged or known violations of applicable laws or regulations, the Code of Ethics, the Anti-Corruption Policy, the ABMS System and/or the Organization, Management and Control Model pursuant to Leg. 231/01. (Read the Whistleblowing Policy)

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