Anti-corruption policy

The policy aims to establish principles of behavior to avoid and prevent the implementation of corrupt practices and to provide guidelines for complying with current anti-corruption provisions.

The policy applies to AFV Acciaierie Beltrame S.p.A. and its subsidiaries. Addressees of the policy are employees, directors, customers, suppliers, financial partners and all parties in business relationships with the Group.

Almost all states have laws prohibiting bribery against their public administration, just as many states (including Italy, France, Switzerland) have enacted regulations prohibiting bribery among private individuals.

For the drafting of the policy, mainly the definitions provided by the Italian legislation were taken into consideration, taking into account that they are substantially overlapping with those of other states.

External references:

• United Nations Convention against Corruption (Merida Convention);
• OECD Convention on Combating Bribery;
• Criminal Code and Civil Code in force in the individual states where Group companies are based;
• Specific reference legislation of the individual states where the Group companies are based or where the activities that could be at risk are carried out.

Internal references:

• Code of Ethics;
• Organizational Model and related Protocols.