Corruption Prevention Policy
CUSTOM S.p.A. (hereinafter also “CUSTOM” or the “Company”), based in Fontevivo (PR), integrates mechatronic technology, know-how, hardware, software and services with pre/post-sales technical support to offer innovative and turnkey solutions. CUSTOM is a leading international provider of integrated solutions for the Retail, Aviation, Ticketing and Entertainment sectors. The Company offers innovation, experience and services, as a solid and structured international technology partner and in its ability to conceive, design and manufacture, making its offer available to various markets. The CUSTOM Group has 30 proprietary patents, over 650 professionals, a presence in 76 countries and 5 production plants, located across several continents to reduce business risk.
CUSTOM is an ethically responsible company and makes every effort to prevent the risk of corrupt actions. In this regard, the Company is fully aware of the need to guarantee actions and behavior based exclusively on criteria of transparency, fairness and moral integrity, in order to prevent any attempt at corruption. Recognizing that corruption is an obstacle to economic, political and social development, and conscious of the negative impacts of this phenomenon, CUSTOM prohibits all forms of corruption and has made “Zero Tolerance” its mission. CUSTOM prohibits all forms of corrupt behavior, both active (offering, promising, giving, paying or authorizing someone to give or pay material benefits, economic advantages or other utilities to a public official, political party, political foundation or private individual, whether directly or indirectly) and passive (accepting, or authorizing someone to accept economic advantages or other utilities, or requests or solicitations for economic advantages or other utilities, from a public official, political party, political foundation or private individual, whether directly or indirectly).
Any behavior contrary to the “Zero Tolerance” policy is not only prohibited, but is vigorously opposed.
CUSTOM prohibits the request, offer or promise of money or other undue advantages to obtain or retain business, whether in direct transactions or those conducted through intermediaries. CUSTOM also pursues the objective of maximum integrity and fairness in its relationships, contractual and otherwise, with public administration, European public institutions and all entities operating for the public interest, with regard to the request for and management of public disbursements and all other undertakings. In the choice of its suppliers and consultants, and in all relations with its business partners, CUSTOM bases its activities on requirements of quality and competitiveness, drawing inspiration from the principles of procurement.
As part of its activities, the Company constantly invests in preventing and combating unlawful practices, first and foremost those of a corrupt nature. It also works to disseminate a corporate culture based, at every level, on integrity, honesty, transparency, fairness, reliability and compliance with all applicable laws, both national and international, as well as with commitments voluntarily undertaken. CUSTOM’s anti-corruption efforts have therefore led to the implementation and adoption of a framework to combat corrupt phenomena. This framework is based on the following key aspects:
- Value system: integrity, transparency, fairness and honesty;
- Awareness and training: awareness raising and training of its employees with regard to corruption prevention issues;
- Whistleblowing: encouragement to report possible corrupt actions;
- Improvement: commitment to continuous improvement of processes to manage and prevent the risk of corruption.
As further evidence of its commitment and confidence in the pursuit of its mission, CUSTOM has decided to implement a Management System for the Prevention of Corruption in compliance with UNI ISO 37001:2016 standard, in order to enhance the efficiency of the measures it implements to prevent and combat corruption, as well as to increase awareness among its employees and stakeholders of the rules and behaviors to be observed.
In pursuit of its mission, CUSTOM encourages the reporting in good faith of unlawful behavior and, to this end, provides the necessary tools to enable the timely and effective communication of suspicions while ensuring maximum protection of the reporting party, through a special communication channel provided on the company intranet and posted on the bulletin board.
In addition, CUSTOM has also established a Corruption Prevention Compliance Function, with the necessary responsibilities and authority to supervise the creation and implementation of the Company’s anti-corruption management system. The availability of human and economic resources, and above all its closeness to the “business”, allow the Function to engage in continuous dialogue with the strategic business areas most exposed to the risk of corruption. To ensure that the system is effectively implemented and observed, and can be continuously improved, it is essential for the Compliance Function to have access to the Company’s Senior Management and the Board.
27 May 2022
Chief Executive Officer
Board of Directors