Corporate Governance
GROUP CODE OF ETHICS AND CONDUCT
The SACBO Group pursues the primary objective of assuming at every level and in every circumstance a corporate image and reputation based on the utmost integrity, correctness, loyalty, transparency, impartiality and objectivity in the conduct of its business and activities.
Compliance with these principles and the existing regulatory framework, together with the values of the SACBO Group - excellence, balance, value creation and responsibility - constitute the basic element of the corporate culture and guarantee the preservation of the solid reputation achieved in the airport business.
It is therefore essential that all those who work with the SACBO Group act in compliance with these principles and values, which have become our "genetic" heritage over time.
With this aim, in 2024 the Board of Directors of SACBO replaced the previous “Group Code of Ethics” with the “Group Code of Ethics and Conduct” in order to identify, not only the set of general ethical values and principles that must constantly inspire the Group’s actions, but also to identify specific rules of behavior that must be observed by all those who work with the Group (directors, corporate bodies, employees, collaborators, partners, suppliers, customers, etc.).
The Group Code of Ethics and Conduct represents one of the essential components of the Organization, Management and Control Model adopted by the individual Group Companies, pursuant to Legislative Decree 231/2001.
ORGANISATION MANAGEMENT AND CONTROL MODEL
The Organization, Management and Control Model, adopted by the Board of Directors of Milan Bergamo Airport effective from July 2003 pursuant to Legislative Decree 231/2001 on the subject of administrative liability of entities, is an integral part of the internal control system and corporate governance.
Its primary purpose is to prevent illicit behavior by its directors, employees and collaborators in various ways, through prevention protocols designed to limit the potential risk of committing the crimes provided for by Legislative Decree 231/01 to the advantage and/or interest of the company.
The Model is composed of a General Part, downloadable from the link below, which outlines its principles, composition, architecture and purposes and Special Parts that identify the prevention protocols aimed at minimizing the risk of occurrence of the types of crimes provided for by Legislative Decree 231/01.
The company’s Board of Directors has appointed a Supervisory Body, with autonomous powers of initiative and control, which has the task of supervising the functioning and compliance with the Model, ensuring its effectiveness and adequacy and ensuring its periodic updating. The general part of the Model describes the composition, responsibilities, functions and information flows to and from the Supervisory Body.
ANTI-CORRUPTION MODEL
The SACBO Group, also in consideration of the strategic importance of the sector in which it operates and the relevance of the legal and social context in which the business is rooted, has adopted a Group Anti-Corruption Policy with which it undertakes to comply with regulations, guidelines and best practices in the field of anti-corruption, as well as to prevent and prosecute any corrupt behavior in the performance of its business.
SACBO sets out these principles in the “Anti-Corruption Model”, a special section of the Organization, Management and Control Model 231, with which it collects in an organic framework the rules of conduct and procedures in order to prevent acts of corruption to the advantage and in the interest of the Group (active corruption) and to the detriment of the Group (passive corruption), both towards the Public Administration and between private individuals.
The functioning of this system is ensured by the Group Anti-Corruption Ethics Committee and by the possibility of reporting any illicit conduct or violations through the Whistleblowing platform.
WHISTLEBLOWING
S.A.C.B.O. considers the whistleblowing reporting tool an effective instrument to ensure integrity and lawfulness, as it gives the possibility to report unlawful conduct or violations of the Organization, Management and Control Model of the company, which became known in the work context, pursuant to Legislative Decree 24/2023. These reports can be submitted, with the outmost confidentiality, through an IT platform, reachable by the link https://milanbergamoairport.segnalazioni.net/en/
Anonymous reports, i.e. made without identifying the reporting party, may also be taken into consideration, provided that they are adequately detailed and provided in great detail, i.e. where they are able to bring out facts and situations by relating them to specific contexts.
For further information, please refer to the “Whistleblowing Procedure” available on the platform at the following link: https://milanbergamoairport.segnalazioni.net/en/pages/policy
