Ethical business practices — the lines we don't cross
Anti-bribery policy, conflicts-of-interest registry, gifts and hospitality rules — applied to Italy sales and procurement.
Anti-bribery — UK Bribery Act and FCPA aligned
Zero tolerance for facilitation payments. All sales people sign anti-bribery declaration annually. Suspicious payment requests escalated to compliance officer in 24 hours.
Conflicts of interest — registry and recusal
Every employee declares related parties, side businesses, family relationships with suppliers/customers. Conflicts trigger recusal from PO approvals or supplier vetting. Registry reviewed quarterly.
Gifts and hospitality — limits and disclosure
Hard limit on individual gifts. Above the limit requires manager pre-approval. All gifts above a small de-minimis amount logged. Hospitality (meals, events) logged when above thresholds.
Italy — local context
Italy business culture and limits apply. IVA 22%-related invoicing via SdI (Sistema di Interscambio) — all transactions traceable to invoice. Milano sales team coached locally on what is normal vs not normal in Italy.
FAQ
What if a customer asks for a kickback?
Refuse, document, escalate to compliance. Customer relationship escalated to leadership. Won't compromise — we walk away from deals before we pay bribes.
Hospitality limit — what is it?
Set by country and role. Specific limits published in employee handbook. Above limit needs pre-approval and goes into registry.
Whistleblower protection?
Yes — confidential channel, anti-retaliation policy, third-party intake available.
Training cadence?
Annual mandatory training for all employees, refresher for sales/procurement quarterly.
Audit of compliance?
Internal audit annually, external audit every 3 years as part of ISO certifications.