SeaCorridor compliance

The Code of Ethics brings together the values that the Company recognises, accepts and shares, and the responsibilities it assumes both within and outside its organisation.

Integrity, respect and protection of human rights, transparency, promotion of development, operational excellence, teamwork and collaboration, as well as innovation are the values that define who we are and what we believe in. These values guide our actions, shape our commitment and direct our behaviour and that of those who interact with us

Compliance with the Code of Ethics by SeaCorridor’s directors, auditors, management and employees, as well as by any third party collaborating or working in the name or on behalf of or in the interests of SeaCorridor, each within the scope of their duties and responsibilities, is fundamentally important for SeaCorridor’s efficiency, reliability and reputation.

SeaCorridor has adopted the Anti-Corruption Guidelines, a document containing the principles governing the prevention and combating of corruption and internal rules relating to ethical and transparent conduct in business activities.

The document specifies the actions that must be taken in accordance with both national and international regulations regarding the prevention of corruption, so that all SeaCorridor operations and activities are carried out in accordance with the highest standards of integrity and legality.

Corruption includes any behaviour aimed at offering, promising, giving, receiving or soliciting undue advantages of any kind in order to obtain or maintain business or an undue advantage. The Anti-Corruption Guidelines set out a specific procedure for identifying, preventing and managing corruption risks, defining roles and responsibilities in order to ensure compliance with legal obligations and promote a corporate culture based on transparency and integrity.

The Guidelines apply to SeaCorridor and its subsidiaries and are also brought to the attention of other investee companies in order to promote principles and conduct consistent with those expressed by SeaCorridor.

Legislative Decree (d.lgs) no. 231 of 8 June 2001 introduced regulations governing the administrative liability of companies, according to which they may be held liable, and consequently penalised, in relation to certain offences committed or attempted in the interest or for the benefit of the company by its directors or employees. The company’s liability is excluded if, prior to the commission of offences, it has adopted and effectively implemented organisational, management and control models suitable for preventing such offences (‘Model 231’) and has established a body responsible for monitoring the functioning and observance of the models (‘Supervisory Body’).

SeaCorridor has adopted its own Model 231, of which the Code of Ethics represents a general principle that cannot be waived, and ensures that it is constantly updated.

The principles and contents of Model 231 are intended for members of the corporate bodies, management and employees of the Company (if any), as well as any collaborators, consultants, partners, suppliers and counterparties in Italy and abroad and, in general, all third parties acting on behalf of the company

The principles and contents of Legislative Decree No. 231 of 2001 and Model 231 are disseminated through training courses aimed at SeaCorridor employees.

The Supervisory Body is collegial and consists of three external members. Its term of office is three years.

• Avv. Daniele Melegari (Chairman)
• Avv. Roberto Di Mario (external member)
• Dr. Riccardo Amatucci (external member)

The Company’s Supervisory Body defines and carries out the activities within its remit and, pursuant to Article 6, paragraph 1, letter b) of Legislative Decree No. 231 of 2001, is endowed with ‘autonomous powers of initiative and control’

The Supervisory Body regulates its own operation through specific regulations and also acts as guarantor of the Code of Ethics, promoting its implementation, dissemination and awareness thereof. The guarantor is also responsible for examining reports of possible violations of the Code of Ethics, encouraging the most appropriate investigations.

SeaCorridor has adopted a reporting protocol (‘Whistleblowing Guidelines’) to collect reports of alleged irregularities, including anonymous reports, and has implemented specific communication channels for receiving them. Staff and third parties may submit reports in writing or verbally regarding information about violations that the reporter has become aware of in the workplace.

SeaCorridor ensures the receipt and analysis of each report by applying criteria of maximum confidentiality designed, among other things, to protect the reputation of the persons reported and the effectiveness of the investigations, in accordance with the provisions of the law on reporting of illegal activities (‘whistleblowing’).

Anyone who receives a report outside the designated channels must promptly forward it through the designated communication channels.

• IT platform
• Direct meeting with the Internal Audit department

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SeaCorridor has adopted the privacy and data protection directive, a document containing the principles governing the proper management of privacy and internal rules relating to the processing of personal data.

The directive specifies the actions that must be taken in accordance with both national and EU legislation regarding the processing and protection of personal data, so that it is carried out in accordance with the fundamental rights and freedoms of individuals, and in particular the right to protection of sensitive data. A data breach consists of a failure to comply with security standards that may result in the destruction, loss, alteration, unauthorised disclosure or access to personal data transmitted, stored or otherwise processed (e.g. data theft). The directive provides for a specific procedure to manage data breaches, identifying roles and responsibilities in order to ensure compliance with legal obligations within the timeframes specified by the General Data Protection Regulation (GDPR).

The directive applies to SeaCorridor and its subsidiaries and is also brought to the attention of other investee companies in order to promote principles and behaviours consistent with those expressed by SeaCorridor.