THE NEW group donations policy

Sustainability is in our DNA and is an integral part of our business across the Group’s entire organization. One of Sustainability’s goals is to contribute to the socio-economic development of the communities in which we operate, aware of the impact our business may have in the countries and economies in which we operate. 

As a result of our recent efforts, the Company has, therefore, decided to adopt a Donations Policy which includes all the measures designed to meet the needs of communities and civil society, in line with the vision, mission, values, Code of Ethics and Policies put in place by the Group itself.

Donations are defined as contributions to third parties (organizations, non-profit entities, or private individuals) as well as short-term humanitarian, cultural, social and sporting initiatives which aim to create added value in ethical, civil and moral terms.

The new Donations Policy replaces the “Corporate Citizenship and Philanthropy Policy” and it is aimed at defining common rules to identify donation activities and specifies the related approval process to be followed worldwide. 

Based on the new Policy, for any donation above 1.000 euros, an anti-corruption due diligence must be carried out on the potential beneficiary. This assessment is performed via a dedicated online platform, in accordance with the "Third Party Program" Policy and the ISO 37001 Standards as well as the Group’s Antibribery Management System.

Then, based on the monetary value of the donation and before any disbursement of funds, the following approval process must be followed: 

• for donations of less than € 50,000, the Group’s Sustainability, Compliance and Tax Functions must be properly informed via e-mail
• for donations exceeding € 50,000, the Group’s Sustainability, Compliance and Tax Functions must be properly informed via email and mandatory approval will be required from the Donations Committee. Final approval is then required by the CEO.