Code of Ethics

The Code of Ethics defines the general principles of conduct on which it bases its actions and business decisions, representing the main pillar of the Group’s Corporate Governance system. The Code of Ethics also sets out the principles of conduct with regard to the issues of greatest importance to the Group, including, in particular, relations with third parties, government authorities, customers and suppliers. The Code of Ethics also defines the principles of conduct with regard to market competition issues and potential conflicts of interest.

Through the Code of Ethics, the Group promotes business management based on the highest standards of ethics and conduct, including in relation to the sustainability commitments and policies it has adopted.

The Code of Ethics expresses Fedrigoni’s Behaviours, i.e. the set of actions that guide what the Group does, how it interacts with others and how it approaches transformation in Fedrigoni.

All persons operating in Italy and abroad on behalf of or in favour of the Group, or who have business relations with it, are required to comply with the principles and provisions set out in the Code of Ethics.
Internal Audit, Risk & Compliance monitors compliance with the Code of Ethics. Breaches of the provisions of the Code of Ethics may be reported by any employee via the mailbox: codeofethics@fedrigoni.com

Model 231

The Group’s Organisational Model pursuant to Italian Legislative Decree number 231/2001 describes the main controls and behavioural guidelines to ensure the prevention of the commission of offences pursuant to such Decree.

It consists of a General Section that illustrates the regulations, the purposes, the rules relating to the Supervisory Body, a description of the Group’s disciplinary system and the staff training system on the content of the Organisational Model, as well as a Special Section that describes the behaviour and prevention tools adopted in order to reduce the risk of the commission of the offences covered under Italian Legislative Decree number 231/2001.

If implemented and subject to concrete supervision by the Supervisory Body, the Organisational Model may constitute a mitigating factor exempting the Company from corporate liability.

Global Policy

The Global Policies contribute to the realisation of the Group’s Compliance Program. In conjunction with the Code of Ethics, the Organisational Model pursuant to Italian Legislative Decree number 231/2001 and the regulations adopted, the Global Policies provide guidelines for the management of compliance with the main regulations relevant to the Group, in compliance with the principles of conduct and behaviour already set out in the Code of Ethics.

This set of regulations is based on by the main benchmark standards in the industry.

ERM

Our Enterprise Risk Management (ERM) model, inspired by international best practices, is designed to identify and ensure adequate governance of the Group’s main risks and the achievement of strategic objectives.

This model promotes the proactive management of risks at Group level, favouring a transversal and dynamic assessment that enhances the existing management systems, ensuring adequate reporting to the administration and control bodies.

The Group Compliance Officer & Chief Internal Auditor is responsible, with the support of the Risk Owners, for ensuring that the Group’s main risks are promptly identified, assessed, managed and continuously monitored.

The Board of Directors is primarily responsible for the supervision, management and evaluation of the ERM Model, consistent with the Group’s strategies.

The Audit & Risk Committee supports the Board of Directors in the decision-making processes concerning the ERM Model.

The Chief Executive Officer is responsible for the definition and implementation of the underlying methodologies of the ERM Model and supervises their design and implementation. He is supported in this by the Executive Committee.

Finally, all Risk Owners are responsible for identifying, assessing and managing risks within their field of remit and for proposing, implementing and monitoring mitigation plans to maintain acceptable risk exposure.