Fincantieri S.p.A

Based on public information, there is evidence that the company publishes a statement from the Chief Executive Officer specifically supporting the anti-corruption agenda of the company.

Based on public information, there is no readily available evidence that the company’s Chief Executive Officer or the 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 some 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. The company website mentions the involvement of the CEO in an internal seminar on issues of anti-corruption. The company therefore scores 1.

Based on public information, there is some evidence that the company publishes a statement of principles representing high standards of business conduct, including integrity, honesty and transparency. However, the range of values falls short of those sought by the question and the values given are not explained in detail. The company therefore scores 1.

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 Oversight Board to oversee the ethics and anti-corruption agenda of the company. It is also helped to some extent by the Auditing Department in overseeing the controls relating to anti-corruption.

Based on public information, there is no readily available evidence that the company has appointed a person at a senior level within the company to have responsibility for implementing the company’s ethics and anti-corruption agenda.

Based on public information, there is some evidence that the company’s Oversight Board monitors and reviews the performance of the company’s ethics and anti-corruption agenda. However, the availability of details regarding the periodicity and scope of the review is limited. The company therefore scores 1.

Based on public information, there is some evidence that the company has a plan in place on which the review of the ethics and anti-corruption agenda by the Board or senior management is based. The review is headed by the Oversight Board and covers various aspects of the anti-corruption agenda. However, the existence of a formal, written plan is not clear from the evidence available. The company therefore scores 1.

Based on public information, there is evidence that the company has a formal process, implemented by the Oversight Board, for review and where appropriate updates its policies and practices in response to actual or alleged instances of corruption.

Based on public information, there is some evidence that the company has an anti-corruption risk assessment procedure, recently set up ‘by the Parent Company’. However, the formality of this process, its application enterprise-wide, the existence of mitigation plans, their ownership and their timescales for implementation are not stated. The company therefore scores 0.

Based on public information, there is some evidence that the company has an anti-corruption risk assessment procedure, recently set up ‘by the Parent Company’. However, the formality of this process, its application to proposed business decisions, and the circumstances of its application are not stated. The company therefore scores 0.

Based on public information, there is evidence that the company conducts due diligence that minimises corruption risk when selecting or reappointing its agents. No public evidence could be found that due diligence is refreshed at least every 3 years. The company therefore scores 1.

Based on public information, there is evidence that the company has contractual rights and processes for the behaviour, monitoring, control, and audit of agents with respect to countering corruption, and makes the agents fully aware of the same before entering into any kind of association. It has a detailed policy on the same titled the Agency, Brokerage & Services Provision Agreement.

Based on public information, there is evidence that the company makes clear to contractors, sub-contractors, and suppliers, through policy and contractual terms, its stance on bribery and corruption and the consequences of breaches to this stance.

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 company has an anti-corruption policy that prohibits corruption in its various forms. It has a separate policy document on anti-corruption which goes into detail on the forms of corruption and bribery, in addition to having a policy on conflicts of interest and corruption risk from suppliers.

Based on public information, there is evidence that the company’s anti-corruption policy is explicitly one of zero tolerance.

Based on public information, there is evidence that the company’s anti-corruption policy is easily accessible to Board members, employees, contracted staff and any other organisations acting with or on behalf of the company. TI notes that key documents are available in English and Italian.

Based on public information, there is evidence that the company’s anti-corruption policy is easily understandable and clear to Board members, employees and third parties.

Based on public information, there is evidence that the company’s anti-corruption policy explicitly applies to all ‘personnel’. Recipients of the policy include all managers and collaborators, including external third parties. The Company therefore scores 1. To score higher, the company would need to provide evidence that the anti-corruption policy explicitly applies to Board members.

Based on public information, there is evidence that the company has a policy on potential conflicts of interest, and it applies to both employees and board members. The policy contains a definition and examples.

Based on public information, there is evidence that the company has a clear policy for the giving and receipt of gifts to ensure that such transactions are bona fide and not a subterfuge for bribery. The company has a separate policy document on the same which makes clear the definition, scope and upper and lower limits, as well as the types and process for any acceptance of gifts.

Based on public information, there is evidence that the company has a clear policy for the giving and receipt of hospitality to ensure that such transactions are bona fide and not a subterfuge for bribery. The company has a separate policy document on the same which makes clear the definition, scope and upper and lower limits, as well as the types and process for any acceptance of hospitality.

Based on public information, there is evidence that the company has a policy that explicitly prohibits facilitation payments. However, there is no readily available evidence that the company provides guidance or supplementary information on how the policy is to be implemented in practice. The company therefore scores 1.

Based on public information, there is evidence that the company regulates political contributions in order to prevent undue influence or other corrupt intent. However, there is no readily available evidence to indicate that the company publicly declares the recipients of any contributions made. 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, in order to prevent undue influence or other corrupt intent.

Based on public information, there is some evidence that the company regulates charitable contributions through an authorisation procedure. The details of the procedure and its scope and requirements, however, remain unclear. The company therefore scores 1.

Based on public information, there is evidence that the company provides written guidance to help Board members and employees understand and implement the firm’s ethics and anti-corruption agenda. It has separate policy documents covering Conflicts of Interest, Gifts & Hospitality, and Services Provision. However, these documents do not contain examples, scenarios and/or case-studies to help employees and Board members understand and implement the policies. The company therefore scores 1.

Based on public information, there is evidence that the company has a training programme for employees that explicitly covers anti-corruption.

Based on public information, there is evidence that the company has a training programme that contains an anti-corruption module and is tailored to every organisational area to help personnel focus on the most relevant issues. TI understands that this would cover employees in a least the principal countries where the company operates or has company sites. However, it is not clear whether all employees in all sites where the company operates receive this training. The company therefore scores 1.

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

Based on public information, there is evidence that the company provides tailored training for employees in sensitive positions.

Based on public information, there is evidence that the company has a clear and formal process by which employees declare conflicts of interest to an independent department in writing.

Based on public information, there is evidence that the company is explicit in its commitment to apply disciplinary procedures to employees, Directors and Board members found to have engaged in corrupt activities.

Based on public information, there is evidence that the company has one whistleblowing channel that is easily accessible and secure, to guarantee confidentiality or anonymity, when an employee reports concerns or instances of suspected corrupt activity. However, this is the only channel and it is not externally operated. Therefore the company scores 1.

Based on public information, there is evidence that across geographies, all employees have access to one whistleblowing channel. The company therefore scores 1. To score higher the company would need to provide evidence that across geographies all employees have access to more than one reporting channel.

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 no readily available evidence that the company has well-publicised resources available to all employees where help and advice can be sought on corruption-related issues.

Based on public information, there is evidence that the company makes a commitment to non-retaliation for bona fide reporting of corruption, and is clear that it will apply disciplinary measures to anyone breaching this commitment.