Charter of Values
By resolution of the Board of Directors of Febraury 19 2019, SOGEPA S.p.A. adopted the Charter of Values of the Leonardo Società per Azioni Group. The Charter of Values provides the principles that guide the Group’s strategy and the daily activities of all those who work and collaborate with the Group itself: Ethics and Respect, Expertise and Merit, Innovation and Excellence, Internationality and Multi-culturalism, Rights and Sustainability are the main values to be followed in the conduct of business activities, in close relationship and collaboration with all the stakeholders.
Code of Ethics
The Code of Ethics, adopted by the Board of Directors on March 5th 2014 and modified on July 18th 2019, provides the ethical commitments and ethical responsibilities in the conduct of company business corporate activities undertaken by all those who have relationships of any kind with SOGEPA S.p.A.. The Company promotes the knowledge and the respect of the Code of Ethics, requiring compliance and providing, in case of violation of one or more provisions of it, adequate and proportionate disciplinary or contractual measures.
Guidelines Management of Red Flags
The Board of Directors on 27.04.2015 adopted the guidelines on the management of red flags, already adopted by the parent company Leonardo S.p.a., that define and describe in order to specify and regulate the process for disclosures, either qualified or anonymous disclosures, by anyone who may be aware of conducts against the law or the internal policies of the Group. Such guidelines are aimed at eliminating or minimizing the risk of committing crimes in areas that are potentially more exposed to the occurrence of unlawful conduct.
By the Board of Directors resolution of July 18 2019 – SOGEPA S.p.A. adopted the Anti-Corruption Code of the Leonardo Società per Azioni Group that, through the enunciation of a set of liability and warranty principles, continues to maintain the commitment to fight against corruption and illegal conduct by spreading and promoting ethical values and principles as well as through the effective implementation of rules of conduct and control processes in line with the requirements set by the applicable regulations and international best practices.
Management and Control Model pursuant to Legislative Decree no. 231/01
By the Board of Directors resolution of July 23th 2015 SOGEPA adopted the Management and Control Model pursuant to Legislative Decree no. 231/01 (“Model”), subsequently amended by the Board of Directors resolution on July 18th 2019.
The current Model consists of: