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Governance


Values

The Alfa Acciai Group is fully aware that a responsible and sustainable economic strategy is essential for the achievement of a competitive edge in the long term.

Industrial sustainability is intended as a balance between expectations of growth in business value, environmental protection, occupational health and safety, and customer satisfaction and respect.

In line with this sustainable approach, the Alfa Acciai Group has achieved and maintains a good relationship with the local community and the surrounding environment.

 

Product quality, environmental protection and occupational health and safety have always been the objectives pursued by the Alfa Acciai Group, by promoting a strict Quality, Environment and Safety Policy, a benchmark for all the Group’s stakeholders.

 

The progressive decrease in injury rates, the ongoing improvement of environmental performance as a result of a rational use of raw  materials and energy resources, the optimisation and development of business processes and know-how, are all the indispensable elements that foster the growth of sustainable development and ensure business competitiveness.

AA quality, environment and safety policy

Code of ethics

In line with the principles set out in Alfa Acciai’s Code of Ethics, all the companies in the Alfa Acciai Group have adopted their own Code of Ethics that details the principles of behaviour of the Group companies and the commitments undertaken by each of them towards their own stakeholders (employees, partners, customers, suppliers, lenders, governmental authorities and the community).

The Code of Ethics is based on the main regulations, guidelines and documents existing at a national and international level in terms of human rights and corporate social responsibility. The Code of Ethics is a means thereby each company in the Group promotes and disseminates its ethical principles in running their business and operations and is a fundamental aid in the prevention of the crimes envisaged by Italian Legislative Decree 231/2001 regarding the administrative liability of legal entities.

Code of ethics

Organisational, Management and Control Model

In accordance with their own company policies, the companies in the Alfa Acciai Group have deemed it appropriate to adopt Organisational, Management and Control Models complying with the requirements set forth by Italian Legislative Decree 231/2001 and has seized the opportunity to acquire adequate tools for the analysis and control of corporate risks. Based on their specificity and organisation and industrial scope of action, each Group company has identified the areas subject to the risk of administrative liability deriving therefrom:

  • Manslaughter and serious or very serious personal injury due to negligence committed in breach of occupational health and safety rules;
  • Crimes relating to protection of the environment.

 

The principles of behaviour and the protocols listed in the Organisational Model are the backbone and ideally harmonize with the procedures adopted by each Company and the integrated management systems, the company organisational charts and the existing task and authority allocation systems.

The Organisational Model adopted by each company in the Alfa Acciai Group is divided into a general section and two special ones.

The General Section illustrates the regulatory framework, the recipients of the Model and the disciplinary system aimed at sanctioning violations to the provisions of the Model. The tasks and authority of the Supervisory Body are also identified. Reference is made to the contents of the Code of Ethics adopted by the Company.

The two Special Sections provide a detailed description of:

  • The corporate organisation of health and safety in the workplace, with particular reference to the processes aimed at ensuring the fulfilment of the legal obligations envisaged by art. 30 of Italian Legislative Decree 81/2008 as amended;
  • The corporate organisation of the environment, with particular reference to processes aimed at ensuring the fulfilment of the legal obligations envisaged by Italian Legislative Decree 152/2006 as amended, the Environmental Impact Permit (EIP) and/or permits issued by the competent authorities in view of preventing environmental crimes as envisaged by Legislative Decree 231/2001.

Supervisory Body and Reporting

For each of its companies, the Alfa Acciai Group has set up a Supervisory Body (SB), whose job is to supervise the effective implementation of the organisational  model, and review and update it.

The Supervisory Body is a body whose members are properly qualified and are in possession of the technological and professional skills that guarantee continuity of action, autonomy and independence of the management in performing their duties. It is identified as an independent body hierarchically placed at the summit of the pyramid of command, and its decisions are final and undisputable.

The supervisory body must be informed of any proven or alleged breach to the Model, the occurrence of unlawful conduct falling under the scope of decree 231, as well as of any comments regarding the appropriateness of the system, by highlighting any gaps found. In this regard, each company in the Alfa Acciai Group has prepared specific reporting channels, pursuant to art. 6 of Legislative Decree 231/2001, including:

 

Non-anonymous reports shall be accepted only if they contain sufficient circumstantial evidence of decisive facts and situations.

In compliance with the protection guaranteed to those who make reports in good faith (so-called whistleblowers), the Alfa Acciai Group ensure the right to confidentiality of reporting subjects and protect them against any form of direct or indirect retaliation and acts of discrimination or unjustified disciplinary actions for reasons associated, directly or indirectly, with the reporting, including disciplinary sanctions against those who violate whistleblower protection measures.

Antitrust Code of Conduct

Alfa Acciai has adopted an Antitrust Code of Conduct directed to all Group companies and intended for use by the Group’s senior managers, personnel and collaborators. The purpose of this code is to clarify the principles and rules set by the law to protect competition and increase corporate culture in this regard, so as to prevent the risk of possible behaviours not complying with the antitrust rules.

The Antitrust Code of Conduct:

  • Clarifies the legal reference framework of antitrust law, by identifying behaviours that are in conflict with this discipline;
  • Identifies the areas in which the greatest risk of antitrust violations can be found;
  • Provides guidance on the steps to be taken to prevent the occurrence of potentially critical situations and control them appropriately;
  • Highlights the importance to adopting behaviours that comply with the competition rules from an ethical and social point of view.

 

The Antitrust Code of Conduct identifies an Antitrust Compliance Officer to whom any non-compliant behaviours can be reported.

Certquality
IGQ
AVD
Suststeel
ICMQ
EPD
Ramet

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