2017 Sustainability Overview | Prysmian Group

35 ESTABLISHING AN ANTI-TRUST CULTURE Prysmian's leadership in its industry strengthened in 2016, thanks to our inclusion in the principal and most strategic global trade associations. Prysmian adopted and constantly implements a number of specific actions to prevent corrupt practices within the Group. They include: A MANDATORY DUE DILIGENCE to be performed during the agent selection process, before signing the contracts, and updated every 3 years, in accordance with the Group policy. THE SUPPLY OF PERIODIC INFORMATION to the Supervisory Body from each area: New Prysmian agents, Results of due diligence, Commission payments above a certain threshold. E-LEARNING ACTIVITIES for compliance with the anti-bribery rules applicable to all Group personnel. In particular, during 2017, specific classroom training sessions were held, aimed at the Group's sales force, organised in collaboration with external lecturers and legal consultants. In 2017, 82 white collar employees were trained in compliance and anti-corruption through online courses and 120 through classroom courses. IMPLEMENTATION OF ACL TOOLS with the definition of a number of key indicators for the “General/Ledger” and “Accounts Payable” processes. The system can also be used to monitor the high transaction risks associated with agents. A CENTRAL DATABASE of all agents, in order to guarantee the collection and filing of agency contracts, so that specific checks can be carried out on the related payment transactions. In 2017 the Group decided to further strengthen the monitoring and central focus on compliance issues by launching an Anti-Bribery Compliance Program inspired by the guidelines set by the ISO 37001: 2016 "Anti-bribery management systems". SPECIFIC ACTIONS AGAINST BAD PRACTICES Prysmian has adopted an Anti-trust Code of Conduct that all directors, executives and employees of the Group are expected to know and comply with in the performance of their duties and in relations with third parties. During 2017, Prysmian has introduced an anti-trust training programme, titled Integrity First, designed to increase awareness among those who work in the name and on behalf of the Group, so that during their activities they comply with the rules safeguarding competition. The Antitrust Code of Conduct is an integral part of this training programme, as it seeks to describe the issues relating to the application of Italian and EU competition policy with regard to cartels and the abuse of dominant positions. The specific situations arising must be assessed against this framework on a case-by-case basis. This action, stimulating knowledge and making individuals more aware of their professional duties and responsibilities, represents a further step in establishing an "anti-trust culture" within the Group.