Relations with contractual partners are governed by the Ethical Code for suppliers of the Generali Group, approved in December 2011 by the Board of Directors of the parent company; the Procurement Code of Conduct, approved in 2014; and by an internal Policy, which is closely linked to the group's Code of Conduct, designed to ensure the proper management of current and future outsourced activities.
In the Ethical Code for suppliers of the Generali Group, we have set out how risks and opportunities relating to the management of relationships with suppliers should be addressed and managed. This is aimed at ensuring the integrity of the supply chain with regard to principles on human and labour rights, anti-corruption and the environment, which we strive to adhere to in all our activities. To this end, the Code specifies the general principles that must form the basis for good relations with contractual partners: fairness and honesty, rejection of all forms of corruption, transparency and impartiality, prevention of conflicts of interest, fair competition, confidentiality, protection of workers, and environmental protection.
We ask our contractual partners to:
- act in accordance with group policies and ensure compliance at all levels of their supply chain;
- operate according to the principles set out in the document: fairness and honesty, transparency and impartiality, prevention of conflicts of interest, fair competition, confidentiality, protection of workers, and environmental protection;
- comply with all applicable laws and regulations, both on a national and international level, including the Fundamental Convention of the International Labour Organization (ILO), the United Nations Universal Declaration of Human Rights and the rules and standards of the respective business segments.
Compliance with the requirements that we request of our suppliers is ensured through appropriate monitoring procedures that take into account the risk profiles of different supplier categories.
If we find instances of non-compliance with the above principles, then the Generali Group works with the contractual partner to find a solution through close co-operation and dialogue. Where we cannot reach an agreement or if we discover serious breaches, then the group imposes appropriate sanctions that may go as far as cancellation of the contract.
In the Procurement Code of Conduct, signed by all group employees who are responsible for purchasing or who have business relationships with suppliers, we have formalised strict standards of conduct and instructions regarding the prevention of conflicts of interest and any form of corruption, as well as regulations concerning the acceptance and/or offering of gifts of any kind, and the handling and use of confidential information. We are currently implementing these provisions in the various countries where we operate, also taking account of local legislation and practices. We are also setting up an e-learning course which will be delivered in mid 2015.
In the Group Policy for Outsourcing, we have established rules and guidelines for activities and relationships with partners, which must be managed in a structured and compliant way across all group bodies. The document sets out the basic principles and the mandatory minimum standards that apply in all countries in which we operate, assigning key responsibilities and ensuring appropriate controls and adequate management structures.
We analyse all processes on a regular basis, to check that they all meet critical standards and to ensure that there is no conflict of interest.