Anticorruption Policy

Corruption jeopardises free competition, it nourishes criminality and therefore represents an extremely serious moral and economic problem for our country and a considerable hindrance to the evolving of our civil society.
The legislator intended to control the corruption phenomenon by adopting a number of provisions aimed at preventing and curbing corruption and unlawfulness, initially geared towards public administration only, and then extended to affiliated companies, a category to which AdB belongs. In particular, Law 190 of 20112 passed the "provisions for the prevention and curbing of the corruption and unlawfulness in the public administration".

Despite the fact that there no longer is any public control on the society AdB Spa, following the listing on the Stock Exchange of the Issuer, which took place on 14 July 2015, AdB BoD confirmed their voluntary ongoing commitment and compliance with the safeguard of the anticorruption system linked to the 231/2001 Model.

Accordingly, to prevent the so called 'corruption risk', AdB resolved to apply, within their own internal control framework, some of the principles of Law 190/2012.
Specifically, they have developed an Anticorruption Policy, within the Organisation and Management Model, in order to protect the impartiality and good performance of the society, the corporate assets and the shareholders' expectations, the work of all employees and of the shareholders in general.

The Ethical and Anticorruption Committee, has the role of monitoring and supervising the effective implementation of the Anticorruption Policy and of its compliance, particularly with the responsibility to:

• verify the effective implementation of the policy and its compliance;
• define the appropriate procedures to select and train the employees who will operate in sectors which are particularly exposed to corruption;
• suggest any amendments to the policy in case any significant non-compliance has been certified or any organisational changes taken place;
• promote the internal mobility of the charges or the implementation of alternative measures in the offices where the risk of corruption is at its highest;
• identify personnel who will be involved in the training on ethical and lawful issues;
• control the disclosure obligations of the society, also in order to assess the society's compliance in this matter;
• manage the report within their competence about any unlawful behaviours, safeguarding the confidentiality of the reporters in compliance with the Whistleblowing Policy.