Mondadori’s commitment with regard to compliance with the regulations and the fight against corruption is governed by the internal control system, the programme that measures and monitors the main risks connected to the company’s activities and ensures solid and proper management of the company.
Compliance with the laws
The Group respects all laws and, in general, any local, national or international regulation applicable in Italy and in any other Country in which it operates. In order to ensure respect of this principle, the Group companies also adopt organisation, management and control frameworks aimed at prevention of crimes in general and at the administrative liability of legal entities with regard to crime.
Financial integrity and the fight against fraud
The Group carries out every economic and financial transaction in accordance with the principles of integrity and transparency and does not carry out any fraudulent transactions. Consequently, every transaction must also be properly authorised, verifiable, legitimate, consistent and appropriate.
Fight against corruption
The Group rejects the use of corruption as a tool with which to conduct its business. Therefore, we do not, under any circumstance, permit corruption or attempted corruption of elected public representatives, public officials or officials charged with a public service, as well as private individuals. In particular, no one may offer, promise or give money or other advantages in order to obtain undue benefits for the Group or for themselves. Moreover, no one may request money or other advantages to carry out undue services.
The Group ensures constant oversight of the issue through organizational measures and controls to help provide and spread proper conduct (personnel training, selection of non-publishing products bundled with the publications, monitoring of the legal framework, networking with other companies in the sector).
In 2019 a whistleblowing procedure has been adopted, with the relating implementation of an IT system managed externally (to guarantee violator and whistleblower privacy) as a communications channel to handle reportings (whistleblowing.mondadori.it); as a result, the various Organisation, Management and Control frameworks of the various Group companies have been updated and training for staff has been planned.
In 2020, after a specific risk assessment, a specific anti-corruption policy will be drafted.
Guidelines of the Organisation, Management and Control Framework
All employees, collaborators, suppliers, consultants and, in general, all third parties that operate on behalf of the Group are required to adhere to the guidelines approved by the Board of Directors of Mondadori, envisaged by the Code of Ethics and by the Organisation, Management and Control Framework.
The supervisory and oversight body, in coordination with the Control and Risks Committee, oversees application of the Code and functioning of the Framework thanks to the data and information collected by the internal audit department.
In addition to employees, even collaborators, suppliers, consultants and third parties operating for Mondadori may submit reports on the guidelines directly to the supervisory and oversight body at firstname.lastname@example.org.