Relations with contractual partners are governed by the following documents:
- Ethical Code for suppliers of the Generali Group, approved in December 2011 by the Board of Directors of the parent company;
- The Code of Conduct Guidelines for Procurement, approved in 2014;
- An internal One Procurement Group Guideline in 2018, to address and harmonize group wide Procurement practices; and
- An internal Group Policy, which is closely linked to the Group's Code of Conduct, designed to ensure the proper management of current and future outsourced activities.
In the Ethical Code for Suppliers of the Generali Group, we have set out how risks and opportunities relating to the management of relationships with suppliers should be addressed and managed. This is aimed at ensuring the integrity of the supply chain with regard to principles on human and labor rights, anti-corruption and the environment, which we strive to adhere to in all our activities. To this end, the Code 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 financial crime as well as implementing automatic controls in order to mitigate bribery and corruption, financial 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 Guideline and the related implementing measures. The automatic controls implemented at group level include the screening of the suppliers against sanctions, terrorism, reputational risk, politically exposed individuals 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 Group policies and ensure compliance at all levels of their supply chain;
- operate according to the principles set out in the document: fairness and honesty, transparency and impartiality, prevention of conflicts of interest, fair competition, confidentiality, protection of workers and the environment;
- 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 Universal Declaration of Human Rights and the rules and standards of the respective business segments.
We ask our internal people to:
- commit to Group Values and Group Standards as detailed in our guidelines and procedures
- undertake specific training courses to fully understand and acknowledge the content of applicable laws and Group Standards
- all above mentioned for partners
Specific procurement procedures have been published to provide employees with clear instructions on how to manage Vendor Management processes (qualification, risk assessment, supplier performance evaluation) and how to manage sourcing procedures (type of negotiations, number of suppliers to be involved in sourcing events, evaluation criteria, awarding rules, contract management)
Compliance with the requirements that we request of our suppliers is ensured through appropriate monitoring procedures that take into account the risk profiles of different supplier categories.
If instances of non-compliance with the above principles are detected, Generali Group collaborates with the contractual partner to find a solution through close co-operation and dialogue. Where an agreement cannot be found, or if serious breaches are discovered, the Group will impose appropriate sanctions, that may go as far as cancellation of the contract.
In the Code of Conduct Guidelines for Procurement, signed by all Group employees who are responsible for purchasing or who have business relationships with suppliers, we have formalized strict standards of conduct and instructions regarding the prevention of conflicts of interest and any form of corruption, as well as regulations concerning the acceptance and/or offering of gifts of any kind, and the handling and use of confidential information. These provisions have been implemented in the various countries where we operate, also taking account of local legislation and practices.
The Generali Group Code of Conduct and the Organization and Management Model ex D. Lgs. 231/01* of Assicurazioni Generali regards corporate administrative liability of:
- persons having representative, administrative or executive functions within one entity or one of its business units having financial and functional autonomy, as well as by persons who de facto manage and control the entity;
- persons subject to the guidance or supervision of the individuals described above.
Main underlying crimes include: crimes against public administration, corruption among private parties, corporate crimes, market abuse, IT crimes, health safety and environment.
The Model takes into account the most significant pronouncements of the jurisprudence, the best application practices of the Decree, the ANIA Guidelines for the insurance sector and the operational suggestions with which the trade association has identified both the procedures to be followed to adopt the models and some of the possible tools for detecting and preventing crimes considered by Legislative Decree 231 of 2001.
The update of the Model and its effective implementation is overseen by a special supervisory body, consisting in a collegial form, chaired by an independent member, outside the Group, the Compliance Officer and the Internal Audit Supervisor. The Supervisory Board has its own budget and can employ external professionals and internal structures to carry out its activities.
The Company, in order to facilitate reports of violations of the Model, even potential, provides the following communication channels:
- a dedicate e-mail box: OdV231@generali.com;
- an address to which written reports can be sent: Piazza Duca degli Abruzzi, 2, 34132 Trieste (TS), Italy to the attention of the “Responsabile dell'Organismo di Vigilanza”
In the Outsourcing Group Policy, we have established rules and guidelines for activities and relationships with partners, which must be managed in a structured and compliant way across all Group entities. 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.
* The Italian Parliament issued Legislative Decree no. 231 (hereinafter also “Decree”) containing “rules on the administrative liability of legal persons, companies and associations, even without legal personality”, by aligning the Italian laws on corporate liability to certain international conventions