Case study: How Italmobiliare promotes business ethics and integrity

What are the material issues the company has identified?

In its 2019 Sustainability Report Italmobiliare identified a range of material issues, such as economic and financial results, data protection, marketing and labelling, lasting value creation, environmental compliance. Among these, promoting business ethics and integrity stands out as a key material issue for Italmobiliare.

Stakeholder engagement in accordance with the GRI Standards                                                    

The Global Reporting Initiative (GRI) defines the Principle of Stakeholder Inclusiveness when identifying material issues (or a company’s most important impacts) as follows:

“The reporting organization shall identify its stakeholders, and explain how it has responded to their reasonable expectations and interests.”

Stakeholders must be consulted in the process of identifying a company’s most important impacts and their reasonable expectations and interests must be taken into account. This is an important cornerstone for CSR / sustainability reporting done responsibly.

Key stakeholder groups Italmobiliare engages with:

How stakeholder engagement was made to identify material issues

To identify and prioritise material topics Italmobiliare engaged with internal and external stakeholders (the management of Italmobiliare, the subsidiaries, employees of Italmobiliare, shareholders, and financial analysts) by asking them to fill in a questionnaire.

What actions were taken by Italmobiliare to promote business ethics and integrity?

In its 2019 Sustainability Report Italmobiliare reports that it took the following actions for promoting business ethics and integrity:

• Implementing a Code of Ethics
• Italmobiliare introduced its own Code of Ethics for the first time in 1993 and subsequently modified and updated it, most recently in 2018. Italmobiliare’s Code of Ethics states a set of values and principles underlying Italmobiliare’s business and establishes its rules of behaviour and conduct. This document therefore represents a solid set of values for Italmobiliare and its subsidiaries, a necessary condition for ensuring a constructive exchange of ideas with all stakeholders and interested parties. The principles laid down in the Code of Ethics are:
  • Legality
  • Countering money laundering and criminal organisations
  • Integrity
  • Fight against corruption
  • Fairness, dignity and protection of the individual from all forms of discrimination and exploitation
  • Transparency and confidentiality
• As regards the fight against corruption, the Code says that relations between the Group and third parties are to be managed without resorting to illegal means: bribery, illicit favours, collusive behaviour, solicitations of personal advantage for oneself or for others are explicitly banned. The rules of the Code apply, without exception, to all employees and to all those who, directly or indirectly, permanently or temporarily, establish relationships with Italmobiliare or work there to pursue its objectives. Violation of the rules laid down in the Code of Ethics harms the relationship of trust established with the Group and can lead to disciplinary, legal or criminal action or, in the most serious cases, it can lead to an interruption of the work relationship or termination of the employment contract. The main Group subsidiaries (Sirap Gema S.p.A., Italgen S.p.A., Caffè Borbone S.r.l., Clessidra SGR S.p.A.) have in turn adopted their own Codes of Ethics, undertaking to disseminate them, update them and make any tools available to encourage their full application.

• Identifying and addressing compliance risks
• Ever since 2004 Italmobiliare applies an Organisation and Management Model pursuant to Legislative Decree 231/2003 (“the Model”), setting up a Supervisory Body as required. The Model is based on a preliminary risk assessment that allows Italmobiliare to identify potential risk profiles in relation to the commission of the offences indicated in the Decree, with reference to its activities and its organisation, and is subject to continuous updating in order to maintain constant compliance with the regulations – the latest revision of the Model was approved in 2018. In compliance with the Model, Italmobiliare supervises all those behaviours that, if implemented, would lead to situations that could be punished under the law. With regard to potential illegal conduct, Italmobiliare identifies the main activities that could involve the risk of committing the following types of offence:
  • Offences against the Public Administration;
  • Corporate offences;
  • Market abuse;
  • Murder and culpable injury in violation of accident prevention regulations;
  • Receiving stolen goods, laundering, use of money of illegal origin, self-laundering;
  • Organised crime and transnational crimes;
  • Copyright infringement;
  • Cybercrime.
• The rules contained in the Model apply to all those who perform management, administration, management or control functions in Italmobiliare, to employees, even if they are posted abroad on secondment for the business, and to those who, even if not employees of Italmobiliare, work on its behalf or are linked to it in some way. Italmobiliare undertakes to guarantee the dissemination and effective knowledge of the Model to all recipients: training, which also took place during 2019, is mandatory and differentiated in terms of content and delivery according to the level of the recipients, the level of risk in the area where they work, their degree of involvement in sensitive activities as indicated in the Model and whether they exercise any functions involving company representation. Italmobiliare communicates the Model 231 and any subsequent editions or updates to its subsidiaries directly. The task of continuously supervising effective functioning and compliance with the Model, as well as proposing updates to it, is assigned to the Supervisory Body of Italmobiliare, and given adequate resources to ensure autonomy, professionalism and independence in the exercise of its duties. Italmobiliare adopts the measures deemed most appropriate to identify violations of Model 231 and encourage reporting them on a timely basis, also anonymously through reserved channels (“whistleblowing”). Sirap GEMA S.p.A., Clessidra SGR S.p.A., Caffè Borbone S.r.l. and Italgen S.p.A have also adopted their own Model, based on the principles and contents of Italmobiliare ‘s Model, without prejudice to the existence of specific situations (relating to the nature, size, type of activity or the structure of the internal delegations of power) that suggest the adoption of different measures in order to effectively pursue the objectives of responsibility for administrative offences.

Which GRI Standards and corresponding Sustainable Development Goals (SDGs) have been addressed?

The GRI Standard addressed in this case is: Disclosure 205-3 Confirmed incidents of corruption and actions taken

Disclosure 205-3 Confirmed incidents of corruption and actions taken corresponds to:

• Sustainable Development Goal (SDG) 16: Peace, Justice and Strong Institutions
• Targets: 16.5

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References:

1) This case study is based on published information by Italmobiliare, located at the link below. For the sake of readability, we did not use brackets or ellipses. However, we made sure that the extra or missing words did not change the report’s meaning. If you would like to quote these written sources from the original, please revert to the original on the Global Reporting Initiative’s Sustainability Disclosure Database at the link:

http://database.globalreporting.org/

2) https://www.globalreporting.org/standards/gri-standards-download-center/

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