Ethical approach

Organization, management and control model and Ethics and financial integrity

The process of adopting and implementing the Organization, management and control model (legislative decree 231/201) began in 2017 and the model has been applied since the beginning of 2018.

The application of the Model not only allows Co.Mac to benefit from the exemptions envisaged by the Decree, but also helps it to improve its management procedures and ensure that its business operations are conducted in a correct and transparent manner.

Co.Mac has assigned to a supervisory board the task of overseeing regulations of the Model of Organisation, check its real effectiveness and appraise the need for possible updates.

In 2018 the company has developed an Ethics and financial integrity which defines the relationship with all the stakeholders, internal and external, primary and secondary.

KEY PRINCIPLES OF COMAC’S CODE OF ETHICS

• Honesty
• Confidentiality
• Trust
• Privacy protection
• Safety and health of workers and general working conditions
• Transparency and completeness of information

Whistleblowing 

Whistleblowing is a tool aimed at preventing unlawful behavior committed within a public or private company. The term whistleblowing refers to the reporting of offenses or irregularities that have occurred in the workplace.

In compliance with the provisions of Legislative Decree 24/2023 containing the “Implementation of Directive (EU) 2019/1937 of the European Parliament and of the Council, of 23 October 2019, concerning the protection of persons who report violations of Union law and laying down provisions regarding the protection of persons who report violations of national regulatory provisions” and of the Organisational, Management and Control Model pursuant to Legislative Decree no. 231 of 2001 adopted by COMAC S.r.l. (“COMAC” or the “Company”), the Company has taken steps to adopt a suitable system for managing reports of violations that have occurred within the workplace.

For the aforementioned reports, the Company makes two specific reporting channels available:

• the “Report It Channel” web platform made available by the Parent Company ATS CORPORATION at the link http://www.reportit.net;
• specific local communication channels:

1. traditional mail at COMAC headquarters, with a confidential letter for the attention of the Supervisory Body;
2. by meeting in person with the Supervisory Board by sending an e-mail request to the e-mail address: [email protected]

COMAC guarantees the receipt, analysis and treatment of reports forwarded by those who are entitled to make a whistleblowing report, i.e. employees of the Company, collaborators, freelancers or consultants who collaborate with the Company, trainees and volunteers, directors and shareholders and members of the corporate bodies (Board of Directors, Board of Statutory Auditors, etc.).

COMAC, in order to promote the so-called “whistleblowing culture”, admits the receipt and management of reports made even in confidential or anonymous form.

Reports may concern violations of:

• Global Code of Conduct of the ATS Group of which the Company is a part;
• unlawful acts in the context of European Union acts concerning: public procurement; financial services, products and markets and the prevention of money laundering and terrorist financing; product safety and compliance; transport safety; environmental Protection; radiation protection and nuclear safety; food and feed safety and animal health and welfare; public health; consumer protection; privacy and protection of personal data; security of networks and information systems;
• acts or omissions affecting the financial interests of the European Union;
• acts or omissions concerning the internal market of the European Union (by way of example: infringements of competition and State aid);
• acts or behaviors which frustrate the object or purpose of the provisions contained in the European Union acts;
• the COMAC Model 231 and related corporate policies and procedures.

In compliance with the aforementioned legislation, COMAC adopts all necessary measures aimed at protecting the confidentiality of the identity of the whistleblower. Furthermore, the Company imposes an absolute prohibition of retaliatory or discriminatory acts, direct or indirect, against the whistleblower (and “facilitators” as set forth in the law) for reasons directly or indirectly linked to the whistleblowing report, with the provision of sanctions against anyone who violates these protective measures.

For further details, please read the extract of the “Whistleblowing Policy – Reporting Procedure” specially prepared by the Company, where all information useful for whistleblower are reported related to the applicable whistleblowing law and the notice channel at his/her disposal.

NOTICE: You may only use this link for the purposes indicated.

Send a report ( reportit.net )