Model 231 and Anticorruption
Hera SpA has adopted, since February 2004, the organization and management model referred to in Legislative Decree 231/01 (the “Model 231”), in line with the ethical principles expressed in the Code of Ethics and in compliance with the commitments made to stakeholders. Model 231 is aimed at preventing crimes that entail liability for legal persons in whose interest or to whose advantage the crime was committed, as provided for in Legislative Decree 231/2001. Model 231 was subsequently extended within the Hera Group and expanded and updated, in relation to the new cases included in the scope of application of Legislative Decree 231/2001 and in adherence with respect to the evolution of the Group and the business activities carried out. Model 231 consists of a General Part and Protocols that make up the Special Part and regulate sensitive processes.
The Model adopted by the Hera Group is in line with the contents of the guidelines developed on the subject by trade associations and with the indications of Italian and U.S. Internal Auditing associations. The Model 231 adopted, which is unique for the entire Hera Group, includes an information and training activity for those involved in sensitive processes in order to make them aware of prohibited and mandatory behaviors, create awareness in relation to “ethical” behaviors and promote a culture of control and prevention in the management of business risks. Hera Group has equipped itself with a Supervisory Board that oversees the Model and carries out, through the Internal Auditing Department, audit activities in an autonomous and independent form. Hera Group promotes the fight against corruption by making its commitment to “zero tolerance” of corruption and fraud in any form, reaffirmed in both the Code of Ethics and the Quality and Sustainability Policy.
Model 231, which already included measures to combat and prevent corruption, has been supplemented with the “Model for the Prevention of Corruption.” The top management and management of Hera Group are personally committed to compliance with the Model for the Prevention of Corruption, including by carrying out activities to raise awareness and disseminate the principles of the rules aimed at preventing corrupt acts at its facilities. The Model for the Prevention of Corruption covers all people working for the Hera Group.
Hera SpA in 2019, obtained ISO 37001:2016 certification of the Management System for the Prevention of Corruption, and the Supervisory Board assumed the role of Compliance Function.
Whistleblowing
Any suspected violation of the Model for the Prevention of Corruption, alleged crime, fraud, bribery or other wrongdoing, whether or not relevant to liability under Legislative Decree 231/2001 or any other useful information for the purpose of preventing crimes can be reported through the following channels:
Portale di segnalazione Whistleblowing del Gruppo Hera
ordinary mail addressed to the Internal Auditing Department Hera SpA Viale Berti Pichat 40127 Bologna with the indication “Confidential” on the envelope; oral reporting by appointment to be requested by email to presidente.odv@PEC.gruppohera.it or through the use of the portal.
In any case, the confidentiality of the identity of the reporter will be guaranteed, without prejudice to legal obligations and the protection of the rights of the Company or the persons involved in the report. Hera Group is committed to ensuring that no one suffers discriminatory treatment for refusing to be an accomplice to corrupt acts or crimes or for reporting in good faith the occurrence or possible occurrence of such conduct. Discriminatory treatment includes, but is not limited to, dismissal, disciplinary action, threats, or other punitive behavior related to reporting.
The above also applies to the following subsidiaries of Herambiente:
• FEA – Frullo Energia e Ambiente Srl
• Hestambiente Srl
• HASI Srl
• Biorg Srl
• ASA Scpa
• Feronia Srl
Attached guide
