POLICY FOR THE PREVENTION OF CORRUPTION

The Vigilpol Scarl Supervisory Institute believes it is appropriate to implement all necessary measures to prevent any act or behavior that could lead to corruption and, to ensure this, implements the following preventive measures:

• absolutely prohibits behaviors that could be considered corruption or attempted corruption or induction into corruption;
• personally respects and requires compliance with current legislation regarding the prevention and fight against corruption, throughout the Italian territory in which it operates, from all employees, collaborators, partners, business associates and suppliers;
• identifies areas of potential risk and identifies and implements appropriate actions to mitigate these risks;
• is committed to meeting the requirements of the anti-corruption management system, ensuring its constant implementation and the pursuit of continuous improvement;
• encourages the reporting of suspicions in good faith, based on reasonable and confidential belief, without fear of retaliation. To this end, the email address wbl@vigilpol.com has been created for reporting any suspicious events;
• promotes awareness among business partners involved in sensitive activities, asking for acceptance of the policy and acceptance of the controls required by the anti-corruption management system;
• promotes ongoing training and information for staff, collaborators, customers, and suppliers on policies, the anti-corruption system, and significant regulatory updates;
• It promotes awareness among staff and collaborators so that they are able to recognize a corrupt event or even just an attempt and can report it, even anonymously;
• requires all staff and collaborators to report to the Corporate Anti-Corruption Function for any issues related to corruption and the management system. The Anti-Corruption Officer is an external, independent figure, i.e., not involved in the organization's activities exposed to the risk of corruption, with appropriate expertise, delegated authority, and tasked with overseeing the design and implementation of the management system;
• informs that failure to comply with the policy may result in the application of the company's sanctions system.