Avio S.p.A.

Based on public information, there is no readily available evidence that the company has published a statement from the Chief Executive Officer or the Chair of the Board supporting the ethics and anti-corruption agenda of the company.

Based on public information, there is no readily available evidence that the company’s Chief Executive Officer or Chair of the Board demonstrate a strong personal, external facing commitment to the ethics and anti-corruption agenda of the company.

Based on public information, there is no readily available evidence that the company’s Chief Executive Officer demonstrates a strong personal, internal-facing commitment to the ethics and anti-corruption agenda of the company.

Based on public information, there is limited evidence that the company has a formal statement of values representing high standards of ethical business conduct. The company refers to encouraging transparency in its operations, and the values of honesty, integrity and fairness in the Code of Conduct. The company therefore scores 1. To score higher the company would need to provide evidence that it explains these values in detail and demonstrates that they are translated into company policies.

Based on public information, there is no readily available evidence that the company belongs to one or more national or international initiatives that promote anti-corruption or business ethics with a significant focus on anti-corruption.

Based on public information, there is evidence that the company has appointed the Compliance Committee and the Supervisory Body with overall corporate responsibility for its ethics and anti-corruption agenda. The Compliance Committee and the Supervisory Committee are responsible for the implementation and effectiveness of rules provided by Model 231. The company therefore scores 1. To score higher the company would need to provide evidence that clarifies the roles of both committees.

Based on public information, there is limited evidence that the company has appointed the “Preposto” of the Internal Control System with responsibility for implementing the company’s ethics and anti-corruption agenda. The company therefore scores 1. To score higher the company would need to provide evidence that this individual is identifiable by name.

Based on public information, there is evidence that annually the Board of Directors review the Internal Control System. This includes examining the significant risks facing the company, the ability of the Internal Control System to mitigate these risks, the measures adopted to manage these risks, and the preparation of any additional policies, process and rules of conduct with which to react to new risks.

Based on public information, there is limited evidence of a formal, clear, written plan in place on which the review of the ethics and anti-corruption agenda by the Board is based. Annually the Board of Directors reviews the Internal Control System. This includes examining the significant risks facing the company, the ability of the Internal Control System to mitigate these risks, the measures adopted to manage these risks, and the preparation of any additional policies, process and rules of conduct with which to react to new risks. The company therefore scores 1. To score higher the company would need to provide evidence of the implementation of improvement plans.

Based on public information, there is some evidence that the company has a formal process for review and updates its policies and practices where appropriate in response to actual or alleged instances of corruption. The Code of Conduct is reviewed and modified by the Board of Directors in regard to contributions received from employees and third parties. The company therefore scores 1. To score higher the company would need to provide evidence of the review process for other company ethics policies and practices.

Based on public information, there is no readily available evidence that the company has a formal anti-corruption risk assessment procedure implemented enterprise-wide. TI notes that the company implements an Enterprise Risk Management, and the Internal Control System is applied to mitigate identified risks and ensure compliance with laws and regulations. However, it is unclear if corruption is an identified risk.

Based on public information, there is no readly available evidence that the company has a formal anti-corruption risk assessment procedure for assessing proposed business decisions.

Based on public information, there is evidence that the company conducts due diligence when selecting or reappointing its agents. Agents are selected on their ability to conduct business with transparency and fairness. The company does not accept contracts with individuals who are registered with countries considered not to conform with the standards of international law, as expressed by the FATF. The company therefore scores 1. To score higher the company would need to provide evidence that due diligence is refreshed at least every 3 years and/or when there is a significant change in the business relationship.

Based on public information, there is evidence that the company has contractual rights for the behaviour of agents with respect to countering corruption. The company expects all parties who act in the name of or on behalf of the company, to apply the Code of Conduct. The company states it will not engage in business with anyone who refuses to comply with the Code’s principles and the provisions of Model 231, with contractual clauses in place to ensure that agents follow them. The company therefore scores 1. To score higher the company would need to provide evidence that it has the right to monitor and audit agents.

Based on public information, there is evidence that the company makes clear to contractors, sub-contractors, and suppliers, its stance on bribery and corruption and the consequences of breaches to this stance. In addition to suppliers respecting the values of the Code of Conduct, the Code also contains a Supplier Code of Conduct that suppliers must accept and sign. The Supplier Code of Conduct contains rights to apply sanctions in the event of a breach of its principles.

Based on public information, there is no readily available evidence that the company explicitly addresses the corruption risks associated with offset contracting.

Based on public information, there is no readily available evidence that the company conducts due diligence that minimises corruption risk when selecting its offset partners and offset brokers.

Based on public information, there is evidence that the anti-corruption policy prohibits corruption in its various forms, including the giving and receiving of bribes and conflicts of interst.

Based on public information, there is no readily available evidence that the company has an explicit zero tolerance policy of corruption. However, the company has a zero tolerance policy of violations of the Code of Conduct. The company therefore scores 1.

Based on public information, there is evidence that the company’s Code of Conduct is easily accessible to Board members, employees and third parties. It is available on the company’s website in English and Italian. It is also available on the company’s intranet and it can be requested from the Personnel Department, the Legal Department or from the Supervisor of the Internal Control System.

Based on public information, there is evidence that the company’s Code of Conduct is somewhat understandable to Board members, employees and third parties. It is legalistic and not written in accessible, comprehensible language. The company therefore scores 1.

Based on public information, there is evidence that the anti-corruption policy applies to all employees and Board members.

Based on public information, there is evidence that the company has a policy on conflicts of interest, including a definition and examples. As the Code of Conduct applies to employees and Board members, this policy applies to both groups.

Based on public information, there is evidence that the company has a minimal policy that regulates the giving and receipt of gifts. Employees are instructed to never give gifts that are in breach of the law, in contrast with the Code of Conduct, or that may be bad for the image of the company if the gift is made public. Similarly, employees are forbidden to accept any gifts that may prejudice their independence of judgement. In regard to representatives of public institutions, all gifts must be of modest value, proportionate to the case and may not be interpreted with a purpose of gaining unfair advantage. However, there is no readily available evidence of upper limits for gift exchange or a specific threshold necessary for senior authorisation. The company therefore scores 1.

Based on public information, there is evidence that the company has a minimal policy that regulates the giving and receipt of hospitality, where the terms ‘benefits’ and ‘favours’ are understood to mean hospitality. Employees are instructed to never give benefits that are in breach of the law, in contrast with the Code of Conduct, or that may be bad for the image of the company if the hospitality is made public. Similarly, employees are forbidden to accept any benefits that may prejudice their independence of judgement. In regard to representatives of public institutions, all favours must be of modest value, proportionate to the case and may not be interpreted with a purpose of gaining unfair advantage. However, there is no readily available evidence of upper limits for hospitality or a specific threshold necessary for senior authorisation. The company therefore scores 1.

Based on public information, there is no readily available evidence that the company has a policy that explicitly prohibits facilitation payments. TI notes that the Code of Conduct states that the company will not tolerate any kind of bribery to public officials, in any form or manner whatsoever.

Based on public information, there is evidence that political contributions are only allowed if permitted by law and if they are authorised by the relevant corporate bodies of each division of the company. Despite the company stating that any relations between the company and political parties shall be marked by the highest principles of transparency, there is no readily available evidence that the company publically discloses its political contributions. The company therefore scores 1.

Based on public information, there is no readily available evidence that the company has a clear policy on engagement in lobbying activities. TI notes that the Code of Conduct states that only duly delegated departments and employees shall manage relations with public institutions. Additionally, any intervention to promote the interests of the Group shall be conducted only in strict compliance with laws and in conformity with the company’s Code of Conduct and other procedures.

Based on public information, there is no readily available evidence that the company prohibits or regulates charitable contributions in order to prevent undue influence or other corrupt intent. TI notes that the company has previously declared that it supported the voluntary organisation, Telefono Amico.

Based on public information, there is no readily available evidence that the company provides written guidance to help Board members and employees understand and implement its ethics and anti-corruption agenda. Additionally, the Code of Conduct is not very detailed and contains no scenarios or illustrations.

Based on public information, there is evidence that the company has a training programme on its Code of Conduct, which includes an anti-corruption policy. The company therefore scores 1. To score higher the company would need to provide evidence that it has an explicit anti-corruption training module.

Based on public information, there is evidence that training on the Code of Conduct is provided in the principal countries where the company operates. The company therefore scores 1. To score higher the company would need to provide evidence that this training is provided in all countries where the company operates.

Based on public information, there is no readily available evidence that the company provides targeted anti-corruption training to Board members.

Based on public information, there is limited evidence that the company provides tailored ethics and anti-corruption training for employees in sensitive positions. Employees holding responsibilies – understood to mean supervisors, heads, chiefs or managers – are given necessary training, so as to maintain an efficient and coherent internal control system. Similarly, training on the Legislative Decree 231/2001 was differentiated to employees, depending on the level of risk in their role. The company therefore scores 1. To score higher the company would need to provide evidence of the roles that receive tailored training in response to different levels of risk.

Based on public information, there is evidence that the company has a clear and formal process for employees to declare conflicts of interest. However, employees are instructed to inform their managers, albeit formally and in writing. The company therefore scores 1. To score higher the company would need to instruct employees to report conflicts of interest to an independent department.

Based on public information, there is evidence that the company is explicit in its commitment to apply disciplinary procedures to all employees and Board members who violate the Code of Conduct.

Based on public information, there is readily available evidence that the company has some channels for employees to report concerns or instances of suspected corrupt activity. The Code of Conduct states that employees should report a violation or suspected violation to their direct superior or to the Preposto of the Internal Control System. However, TI notes that contact details for the Preposto of the Internal Control System or the Audit Committee are not provided. The company therefore scores 1. To score higher the company would need to provide evidence that employees are able to report instances of suspected corrupt acitivities anonymously or to an independently operated channel.

Based on public information, there is no readily available evidence that whistleblowing channels are available to all employees in all geographies. Reporting to a line manager is a limited form of reporting and as contact details for the Preposto of the Internal Control System or the Audit Committee are not provided, it is unclear if these reporting channels are available worldwide.

Based on public information, there is no readily available evidence that the company has formal and comprehensive mechanisms to assure itself that whistleblowing by employees is not deterred, or that whistleblowers are treated supportively.

Based on public information, there is evidence that employees have access to resources where help and advice can be sought on corruption-related issues. These resources include the Group companies’ Legal Departments and Personnel Departments.

Based on public information, there is evidence that the company has a commitment to non-retaliation for bona fide reporting of corruption. The company therefore scores 1. To score higher the company would need to provide evidence that disciplinary measures are applied to employees who breach this policy.