Crime Prevention by NTET S.p.A.
Corruption is a malpractice that does not pertain to any specific country or sector of the economy and has several negative implications both from a legal perspective, as it is a crime, and from a social perspective.
NTET S.p.A. actively contributes to combating corruption by adopting an Anti-Corruption Management System in compliance with the requirements of UNI ISO 37001:2016. This initiative demonstrates the leadership’s commitment to fostering a culture of integrity, transparency, honesty, and compliance with laws.
The Anti-Corruption Management System implemented by NTET consists of a set of activities designed and carried out with an integrated and synergistic approach, aimed at continuous performance improvement and risk mitigation. It operates in harmony with other compliance tools already adopted by the company as part of the Organization, Management, and Control Model pursuant to Legislative Decree No. 231/2001.
For years, NTET has adopted and implemented an Organization, Management, and Control Model in compliance with the provisions of Legislative Decree 231/01, in the form of an Administrative Responsibility Management System (SGRA), accompanied by the Code of Ethics, available for download from our website.
The supervision of the 231 Model has been entrusted to a Single-Member Supervisory Body, represented by the President of Asso 231, Eng. Ciro Alessio Strazzeri, certified by KHC for his expertise as a 231 Expert, 231 Auditor, and Supervisory Body Member, who can be contacted at the following email address: info@studiostrazzeri.it.
To monitor the proper implementation of the Anti-Corruption Management System in compliance with UNI ISO 37001:2016, NTET has designated the Compliance Function for Anti-Corruption, currently held by Dr. Mia Rupcic, who can be contacted via the following PEC address: mia.rupcic@pec.it.
In accordance with the provisions of UNI ISO 37001:2016 and Legislative Decree 231/01, Article 6, paragraph 2-bis (as amended by Legislative Decree 24/2023), which also regulates the protection of employees reporting alleged misconduct (so-called Whistleblowing), NTET has established the possibility for anyone to report in good faith and with adequate factual basis any conduct deemed illegal or in violation of the 231 Model or the Anti-Corruption Management System. Protections are guaranteed to whistleblowers to ensure they do not face retaliation by the company.
To this end, the following alternative reporting channels have been established:
- By email, to the above-mentioned addresses, either to the Compliance Function for Anti-Corruption or the 231 Supervisory Body, depending on the case;
- Through a secure online reporting channel, ensuring the confidentiality of the information submitted using encrypted protocols that protect personal data and any attachments.
NTET S.p.A. has defined its Anti-Corruption Policy, which includes:
- Strict compliance with current anti-corruption legislation in Italy and in any country where NTET S.p.A. operates;
- The absolute prohibition of any conduct that could constitute corruption or attempted corruption;
- Identifying potential risk areas and implementing measures to reduce or minimize these risks;
- Committing to conduct its policies and actions to avoid involvement in corrupt practices;
- Raising awareness among business partners to adopt anti-corruption policies and practices within their scope;
- Raising awareness and providing training for employees and managers on anti-corruption issues;
- Providing online reporting mechanisms for unlawful behavior or violations of the Anti-Corruption Policy;
- Applying disciplinary measures against any conduct not in line with the Anti-Corruption Policy;
- Ensuring full authority and independence for the Anti-Corruption Compliance Function;
- Striving for continuous improvement of anti-corruption activities.
