Anticorruption Policy

Anticorruption Policy _ Duferdofin – Nucor

The Duferdofin – Nucor Group considers it opportune to take a firm approach with an absolute prohibition on any form od corruption.

This policy of the Group to contrast corruption applies to all Recipients who must observe the highest standards of correct behaviour and moral integrity.

It is the express decision of the Group to comply with all laws, rules and regulations regarding the fight against corruption in Italy and in all countries in which the Group operates.

The Group seeks to conduct its business so as not to be involved in any form of corruption and not to facilitate or risk involvement in unlawful situations, i.e. in relations with Public Bodies and Private Entities.

For the purposes of this anticorruption policy, “Public Bodies” means public officials and civil servants or all those working within the ambit of the Public Administration in Italy or in countries with which the Group operates; “Private Entities” means persons representing or operating on behalf of customers, suppliers, business partners or contractual counterparties in general and in any case individuals with whom the Recipients work – in carrying out their business- in the interest of Group companies.

In particular, is strictly forbidden to:

  • offer, promise, give, pay or authorise to give or pay, directly or indirectly, money or other economic advantages or utilities or benefits of any sort to Public Bodies or Private Entities;
  • accept a request or authorise someone to accept or solicit, directly or indirectly, a payment or economic advantage or other benefit from Public Bodies or from Private Entities,

when the aim is:

  • to induce the other party to perform its function incorrectly, be it of a public or private nature, in relation to work done by or for the Group or in order to reward an activity carried out in respect of the Group;
  • to influence the realization of an act or its omission in the interests of the Group;
  • to obtain, ensure or retain a piece of business or an unfair or unreasonable advantage with respect to the conduct of the business.

Recipients are also prohibited from receiving or obtaining any e promise of money or other benefit, for themselves or for others, to from committing or omitting to acts in violation of the obligations inherent in their office or obligations of loyalty, also causing damage to the Group.

All the limitations described above apply not only to cash payments but also to any benefit, including indirect benefit, such as, by way of example: gifts, contributions to associations or sponsorships, jobs, professional appointments or consultancies; investment opportunities; confidential information relating to the market or products; discounts or instalment payment terms, gratuities for third parties such as hospitality, meals, transportation and entertainment.

The Management provides to the anticorruption policy the maximum circulation at the relevant staff, ensuring it is understood, implemented and supported at all levels; for this purpose, it is avaiable online on the company informative system.

It is responsibility of Managers to verify that the document is understood by their employees and, if necessary, to provide the requested clarification.

The adequacy over time of the anticorruption policy is regularly checked by the Management (normally during the Management Review), and – if necessary – the appropriate corrective actions are taken.

San Zeno, 15th November 2017