Relations with contractual partners are governed by the following documents which are part the internal rules implemented to properly manage procurement activities:
- Generali Group Code of Conduct;
- Ethical Code for suppliers of the Generali Group;
- An internal One Procurement Group Guideline to address and harmonize group wide Procurement practices;
- Organisational and Management Model of Assicurazioni Generali;
- An internal Outsourcing Group Policy, to ensure the proper management of current and future outsourced activities.
Those internal rules define how risks and opportunities related to our suppliers should be addressed and managed. This is aimed at ensuring the integrity of the supply chain with regard to key principles, including human and labor rights, anti-corruption and the environment, which we strive to adhere to in all our activities. To this end, the Generali Group Code of Conduct specifies the general principles that must form the foundation 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 the environment.
In addition, Generali Group has adopted policies and procedures to prevent that our products or services could be misused for financial crime practices, to protect the Group and its employees against any corporate or personal liability arising under Anti-Financial Crime laws and regulations and to set a group-wide controls aimed at mitigating bribery and corruption, international sanctions and money laundering risks. Those policies include the Group International Sanctions Policy, the Anti-Money Laundering and Counter Terrorism Financing Policy, the Anti-Bribery and Anti-Corruption Group Policy and the related Group Guidelines. The automatic controls implemented at Group level include the screening of the suppliers, against international sanctions, terrorism, politically exposed persons and internal lists. Other controls have been adopted such as bank account checks to give just one example.
We expect our contractual partners to:
- act in accordance with duties and obligations deriving from Group policies and ensure compliance at all levels of their supply chain;
- operate according to the following principles : fairness and honesty, transparency and impartiality, prevention of conflicts of interest, fair competition, confidentiality and data privacy protection of workers and the environment, diversity equity and inclusion best practices;
- comply with all applicable laws and regulations, both at a national and international level, including the Fundamental Convention of the International Labour Organization (ILO), the United Nations Global Compact and the Universal Declaration of Human Rights and the rules and standards of the respective business segments.
Compliance with the requirements by our Suppliers shall also be ensured through appropriate monitoring procedures that take into account the risk profiles of different supplier categories.
In the event of non-compliance with the above-mentioned principles, Generali shall first and foremost seek a solution through a negotiation with the contract partner in order to find an agreement. Should an agreement fail to be achieved or serious non-compliance occurs, Generali shall apply the necessary remedies (contractual and non-contractual remedies) that may go as far as the termination of the contract, without prejudice to the damages claim.
We ask our internal people to:
- commit and comply with Generali Group Values and internal rules as detailed in our policies, guidelines and procedures
- undertake specific training courses to understand and acknowledge the content of applicable laws and Group Standards
Specific procurement procedures have been published to provide employees with clear instructions on how to manage Vendor Management processes (i.e. qualification, risk assessment), Sourcing Strategy processes (type of negotiations, number of suppliers to be involved in sourcing events, evaluation criteria, awarding rules) and Contract Management processes (contract drafting and signature).
In the Organization and Management Model of Assicurazioni Generali are set out rules of conduct and the monitoring that must be adopted to prevent the risk of committing the crimes provided for by Legislative Decree no. 231/2001 and to exclude or limit the consequent administrative liability of the Entity.
Main underlying crimes include: crimes against public administration, corruption, corporate crimes, market abuse, IT crimes, health safety and environment.
In the Outsourcing Group Policy, we have established rules and guidelines for activities and relationships with service providers, which must be managed in a structured and compliant way across all Group entities, according to the regulatory requirements 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 analyze all processes on a regular basis, to check that they all meet critical standards and ensure that there is no conflict of interest.