Having regard to the prevention of corruption, the Policy describes the forbidden behavior, the general principles to which Poste Italian Group undertakes to adapt in the performance of its activities and the specific rules of conduct in respect of the more corruption-prone activities.
The Policy applies to Poste Italiane and our subsidiaries, for which it serves as a benchmark for the implementation of the general principles and specific issues.
Compliance with the UNI ISO 37001 standard, relating to anti-corruption management systems, represents an opportunity for Poste Italiane to strengthen its commitment to fight corruption and contribute to consolidating the principle of legality, with obvious benefits for the protection of the company's reputation and assets. In 2023, the commitment made by Poste Italiane with its stakeholders regarding the certification in accordance with ISO 9001 and ISO 37001 "Quality Management and Corruption Prevention System" to the entire perimeter of the company's processes and sites (approximately 16,000 sites) was achieved. In particular, the activities carried out have made it possible, in line with the extension initiatives of previous years, to maintain the Integrated Quality and Anti-Corruption Certification covering the entire Poste Italiane perimeter. With regard to Group companies, all certifications obtained, as of 2019, by the companies Poste Vita, PostePay, BancoPosta Fondi SGR, SDA Express Courier, Poste Assicura, EGI and Postel were confirmed.
The Integrated Policy contains a commitment to promptly comply with current regulations: ISO 37301:2021 for compliance management, UNI EN ISO 9001:2015 for quality control, ISO 45001:2018 for occupational health and safety, ISO 37001:2016 to prevent practices that may result in alleged and/or confirmed crimes of bribery, ISO/IEC 27001:2013 and ISO/IEC 20000-1:2018 respectively with respect to the management of data security, and for the management of IT systems which support company processes.
Customer centricity
Fundamental values such as courtesy, transparency, fairness and impartiality, which guide the Group's approach to its customers, are described in the Code of Ethics, ensuring that customer relations are managed on the basis of correct, healthy and profitable principles.
Code of ethics
In order to clearly define the values and social role with which the Company contributes to the processes of cohesion, inclusion and sustainability of the country, as well as the rules of conduct in the performance of professional activities, the Poste Italiane Group has adopted a Code of Ethics for directors, supervisory boards, management, all employees and all those who work, directly or indirectly, permanently or temporarily, to pursue the objectives of Poste Italiane. The Code is disseminated to all levels of the organisation with the aim of spreading its values, including through training and information initiatives, so that all persons to whom the document is addressed become aware of its contents.
The Code enshrines the principles that inspire the culture, behaviour and way of doing business of the Company and its stakeholders, such as, for example, the principle of legality, impartiality and fairness, respect and development of people, transparency and completeness, confidentiality, quality, diligence and professionalism. In this document, Poste Italiane affirms its commitment to adopting criteria of conduct that exclude conflicts of interest with the Group and promote the ability to make decisions that are consistent with the Company's objectives; criteria that avoid corruption, money laundering and terrorism and that encourage conduct of integrity, while respecting the health and safety of workers and protecting the privacy of all the recipients of the Code. Five years after the last update, in 2023, the Code of Ethics has been revised, attributing a decisive and central role to the People of Poste Italiane who, by applying the Group's values in their relations with all stakeholders, contribute to the creation of value. Moreover, in line with regulatory developments, sustainability policies, the values enshrined in the Sustainability Pillars, as well as the role that Poste Italiane plays for the territory and the communities, new guiding principles have been introduced and existing principles have been revised and integrated. In addition to the Code of ethics, the Company adopted a Group integrated policy, which reflects and documents the commitment made to all Company's stakeholders, to improve its performance and, at the same time, build and develop trusting relationships with them, as part of a process of generating and sharing value for the Company as well as for the communities in which it operates, with a view to achieving continuity and reconciliation of the related interests.
In addition, Poste Italiane has set up a reporting system and an Ethics Committee with the task of managing reports and violations. In this regard, the Group has introduced the “Guideline on Whistleblowing”, a document aimed at regulating the system through which reports can be made by personnel and third parties, with reference to acts or facts referable to violations of internal and/ or external regulations, as well as illegal or fraudulent conduct that may determine, directly or indirectly, a financial or image damage for the Company. The Group has made a reference portal available to the recipients of the Guidelines, the management of which is entrusted to the Whistleblowing Committee, which also performs the functions of the Ethics Committee and is responsible for receiving, examining and evaluating the communications received. The Whistleblowing Committee envisages assigning to an external professional with high standards of professionalism, honourableness and independence and the permanent presence within the Committee of the Group Risk Management structure/Oversight 231, in order to ensure constant assessment of the relevance of the reports received.
Poste Italiane and Guardia di Finanza
The historic collaboration with Guardia di Finanza (Finance Police) and the signed protocol provide even more effective and up-to-date tools to counter any abuse and make a concrete contribution to the country's development.
The Memorandum of Understanding with Guardia di Finanza consolidates the entrenchment of company standards and rules in processes, through the increasingly widespread dissemination of the principles of legality and transparency in the market and the prevention of financial offences. In particular, within the framework of the Protocol, the shared objectives are the fight against tax evasion, avoidance and fraud, offences relating to public expenditure, economic and financial crime, money laundering, counterfeiting and fraud concerning payment systems. The Protocol also stipulates that Poste Italiane shall assist in the work of prevention and law enforcement by sharing with Guardia di Finanza its wealth of information against unlawful acts in areas of institutional interest carried out also by exploiting technological and IT means. Under the agreement, Poste Italiane will make available to Guardia di Finanza the data in the "Identity Check" system, which will be useful for investigations to prevent and repress fraud and any other offence of an economic or financial nature. The Protocol also establishes regular meetings to review the progress of the collaboration and share information on new fraud scenarios and initiatives to be implemented.
The Policy applies to Poste Italiane and our subsidiaries, for which it serves as a benchmark for the implementation of the general principles and specific issues.
Having regard to the prevention of corruption, the Policy describes the forbidden behavior, the general principles to which Poste Italian Group undertakes to adapt in the performance of its activities and the specific rules of conduct in respect of the more corruption-prone activities.