Internal Control and Compliance
The Group’s Code of Ethics, to be applied to all the companies that are wholly owned by Rekeep, was resolved on by the BoD of Rekeep on 18 December 2018.
On the same date, an Ethics Committee was also set up to monitor the dissemination and implementation of the Code of Ethics and to receive and verify all reports of any violation thereof.
The Code of Ethics lays down the principles and values underlying Rekeep and its wholly-owned subsidiaries’ activities and the conduct of their business, in addition to the set of rights, duties, rules of conduct and responsibilities with respect to all the persons and organizations with whom they enter into a relationship with a view to the attainment of their corporate purpose.
Code of EthicsThe term SA8000 refers to the international standard framed by SAI (Social Accountability International), an American entity, created with the aim of ensuring the fairest and most decent working conditions. This Ethical Certification is an accredited standard that places the emphasis on organisations’ commitment to distinguishing themselves in the field of sustainable development, paying particular attention to social issues.
The standard is based on principles laid down in international sources in the matter of human rights in general and those of workers, sources such as the Universal Declaration of Human Rights, United Nations Conventions on the Rights of the Child and on ILO (International Labour Organization) Conventions.
For Rekeep Rail S.r.l., it is fundamentally important to interact with Customers and other parties involved that show an interest in issues dealt with in SA8000 and a desire to collaborate with regard to these issues.
We have published the following for this purpose:
- the Integrated Policy, setting down the principles that guide Rekeep Rail S.r.l.’s actions;
- the Summary of the SA8000 Reassessment;
- Guidance for Ethics Reports, containing the active channels of communication for sending messages to the Company regarding SA8000 topics.
Rekeep Rail S.r.l. has adopted an organizational, management and control model, Model 231, to prevent the commission of criminal offences in the interests of or to the advantage of the company.
Legislative Decree 231 of 8 June 2001 introduced rules on “Corporate liability for unlawful administrative acts resulting from criminal offences” into the Italian legal system, on the basis of which companies may be deemed “liable”, and are therefore punishable, for certain criminal offences committed by representatives of the top management (persons referred to as being in “top positions” or simply “at the top”), and by personnel subject to their management and oversight, in the interests of or to the advantage of the companies themselves.
The Company is not liable, however, if it has adopted organizational, management and control processes and has effectively implemented them before a criminal offence of this type has been committed, if the processes are adequate to prevent such criminal offences and if it has formed a Board responsible for overseeing the functioning and observance of the processes.
Rekeep Rail S.r.l. has adopted Model 231 and has appointed a Supervisory Board which has independent powers of initiative and control and which has been entrusted with the duties of overseeing the functioning and observance of the process and seeing that it is kept up to date.
Organizational, management and control model under Legislative Decree 231/2001
