Anti-Corruption system

Politica per la Prevenzione della Corruzione-1

The Anti-Corruption Model

In compliance with what is defined by the corporate Code of Ethics and in compliance with the Principle  of the Global Compact, based on which “companies undertake to combat corruption in all its forms, including extortion and bribes“, the formal and substantial commitment of Giovanni Putignano e Figli srl in the fight against corruption, takes concrete form in the implementation of an Anti-corruption System, managed in line with the requirements of the UNI ISO 37001:2016 (Anti-Bribery Management System), including the company procedures that define the roles and responsibilities of the subjects involved and the operational procedures of the processes and the control systems defined in the anti-corruption model adopted.

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

It provides a systematic framework of reference for the anti-corruption regulatory instruments and policies that Giovanni Putignano e Figli srl intends to pursue, acting as a guide, both for internal personnel and for business partners, in addressing the risks of corruption that may occur in the performance of business activities.

In order to guarantee effective measures to ensure assistance and advice on anti-corruption matters, and in accordance with the provisions of the UNI ISO 37001:2016 standard, Giovanni Putignano e Figli srl has established the Compliance Function for the Prevention of Corruption (FCPC), responsible, among other things, for giving specialized indications and providing clarifications with respect to the content and implementation of the ABMS System, as well as the application of Italian anti-corruption laws or laws of the country in which the organization operates.

The FCPC is also entrusted with the activity of constant review and monitoring of the ABMS System to ensure that it remains effective at the highest level and the verification activity aimed at ascertaining its correct application.

The application of the ABMS System is the direct responsibility of the sole administrator, the statutory auditors, the managers and all employees of Giovanni Putignano and Figli srl, as well as all those who, directly or indirectly, permanently or temporarily, establish relations with the organization and reports, each within the scope of its functions and responsibilities (Business Partners). All business associates are therefore required to comply with the utmost diligence and attention with all the principles and provisions contained therein.

In order to disseminate adequate knowledge and understanding of the contents of the AMBS System, Giovanni Putignao e Figli srl has defined:

  • an obligatory anti-corruption training program for all employees, modulated with a different level of detail, in relation to the qualification of the recipients and to the different level of involvement of the same in sensitive activities;
  • an awareness program on anti-corruption issues for all business associates;

specific contractual “compliance” clauses that provide, among others, the obligation to comply with the principles contained in the Anti-corruption Policy and in the organization’s ABMS System.

The sanctioning system

The violation of the principles of the Anti-Corruption Policy and of the requirements of the ABMS System by the organization’s personnel constitutes a serious breach of contract, which is why Giovanni Putignano e Figli srl reserves the right to sanction such violations in compliance with the law and / o contractual applicable to the single relationship, both with conservative sanctions and through the termination of the contractual relationship itself (dismissal or withdrawal); the organization also has the right to carry out damages actions in accordance with current legislation.

Business Partners 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 activity. Violation of the principles of the Anti-Corruption Policy and the requirements of the ABMS System by business partners constitutes a serious breach of contract, which is why Giovanni Putignano e Figli srl reserves the right to terminate any existing commercial relationship.


The Whistleblowing platform is one of the communication channels 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 Legislative Decree 231/01.