.A.S.A. Track - page 29

(money
them to act for reasons other than the
fulfilment of their responsibility to the
Company.
The relationship between the FCC Group
and its employees must be based on the
loyalty
generated by common interests.
In this sense, the Group respects its em-
ployees’ involvement in other financial
or business activities, provided that such
involvement is not restricted by internal
regulations, and that the activities are
legal and do not compete with or give rise
to potential conflicts of interest with their
responsibilities as FCC employees.
Employees duties:
- Every FCC employee should
avoid
possible conflicts
between their per-
sonal interests and those of the Com-
pany. They shall therefore refrain from
representing the Company, partici-
pating in or influencing management
processes as well as decision-making
in which, either directly or indirectly,
they, or any third parties close to
them, have a personal interest.
- Any employee
who suspects a po-
tential conflict of interest
should
make it known to their line manager
and to the Compliance Office. Their
line manager should inform the Com-
pliance Office of the measures that
have been taken or that will be taken
in order to avoid the conflict. The
Compliance Office will assess the ef-
fectiveness of the proposed measures
and, in the event of any discrepancy,
shall notify the line manager of the
measures which must be adopted.
Integrity and transparency
All FCC Group employees are required to
pay close attention to any possible indica-
tion of a lack of integrity of individuals
or entities with which the company is
dealing.
Corruption and bribery
The FCC Group interprets
corruption
as
the use of unethical practices to obtain a
particular benefit. Corruption is catego-
rised as a form of fraud.
Under
no
circumstances will FCC Group
personnel engage in unethical practices in
order to
influence people outside the
company,
either for their own benefit or
that of the Group.
Duty of care:
Employees must also
remain vigilant in order to ensure that
there are no incidences of other persons
or organisations making use of these
practices in their relations with the
Company.
Duty of compliance of anti-bribery
regulations:
In their dealings with public
authorities and institutions, employees of
FCC Group shall act lawfully and in line
with international regulations for the pre-
vention of corruption and bribery.
Duty of documentation:
Any FCC
Group employee who maintain relation-
ships with public bodies should docu-
ment the decisions taken and ensure
compliance with the regulations that
the Company has put into place for this
purpose, all of which has the object of
enabling, where applicable, the review
of decisions by third parties.
Money laundering and irregularities
in payments
Duty of monetization:
1. FCC Group personnel should pay par-
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