We strive to act responsibly, not limiting ourselves to simply respecting all national and international laws but promoting ethical and transparent conduct in order to strengthen our reputation among our stakeholders and increase their trust.
We regularly monitor our exposure to all compliance risks in order to minimise potential damage to our reputation and economic losses deriving from the violation of laws in force, including those designed to prevent corruption. The Group policies have defined standards of conduct valid all over the world with the introduction of compliance programmes that include actions to monitor the biggest risks.
We condemn and combat all forms of corruption and financial crime. We make our position clear in the Code of Conduct which outlines the values, expectations and ethical principles that inspire the people that work with us or for us, and also acts as a guide for settling ethical questions or dilemmas.
All requests for explanations, doubts or reports of inappropriate behaviour can be addressed - also in anonymous form where permitted by law - to one’s manager or the local or Group compliance officers, or submitted via our helpline, a web and telephone channel managed by a third-party supplier active 24 hours a day, every day. Confidentiality is guaranteed and we will show zero tolerance towards any form of retaliation.
Group Anti-Money Laundering & Counter-Terrorism Financing Policy
Policy on International Sanctions
Group Rules of the Code of Conduct on Anti- bribery and anticorruption and on Conflicts of Interest
250 reports received via the helpline
A preliminary analysis is carried out on all reports to assess whether further investigation is required. When this has concluded, any eventual necessary measures are identified. These range from the adoption of disciplinary measures to dismissal or the termination of contracts, according to the party involved (employee/ contractual partner) and the severity of the event.
We continue to carry out awareness raising and training activities on the various issues covered by the Code.
have completed the basic Code of Conduct course and 9,495 employees the relative updating course launched in 2016
11 Our Code in Brief
training cartoons uploaded onto the Group portal and local intranets in 2016
focusing on Integrity Week
Our Code – My Notebook
a notebook containing our Code and a reminder of the channels that can be used to report breaches, which has been enriched with a summary of our principles
2 Integrity Weeks
In support of the OECD CleanGovBiz initiative we launched a global internal campaign focused on strengthening trust and integrity and combating corruption. Local activities included coffee meetings, videos and the distribution of free gifts.
We launched the second Integrity Week of 2016 with the aim of communicating the roles of the Compliance department: providing tools, policies and advice to protect colleagues and Group clients, on one hand preventing the potential risk of penalties and reputational damage and, on the other, supporting our culture of integrity in an open, fair and stimulating work environment.
In order to raise awareness among all our employees, on the Group portal and local intranets we have published real examples of the application of the procedures established in the event of Code breaches. We are committed to promoting them over time and developing an authentic permanent library.
Together with our clients,
for further information on our commitment to combating fraud
We run our business in compliance with the law, internal regulations and professional ethics.
The Code of Conduct defines the rules of conduct to be observed, for example, for the promotion of diversity and inclusion, the management of personal data and privacy, the prevention of conflicts of interest and corruption, bribery, money laundering, terrorist financing and international sanctions, and the proper management of relationships with customers and suppliers.
The Responsible Investment Guideline codifies responsible investment activities at Group level.
The Group Policy for the Environment and Climate contains the guiding principles of reference for our environmental management strategies and objectives.
The Ethical Code for suppliers highlights the general principles for the proper and profitable management of relations with contractual partners.
We also have a structured internal regulatory system named Generali Internal Regulation System (GIRS).
Corporate Governance and Share Ownership Report 2016, p.45