Anti-bribery Policy

ISS International SpA, a company specialized in technical consulting and integrated engineering services, offers companies highly qualified solutions, providing support in technical, managerial and operational areas, in order to optimize processes and business systems of client companies.
ISS International SpA is headquartered in Italy but operates at a Worldwide level through four companies, two divisions and eight secondary offices located in different international geographical areas, with the mission of providing Integrated Services Solutions within the energy sector.
The Company’s strengths are: Dynamism, Flexibility, Professionalism, Competitiveness and Honesty, in the belief that human beings and systems are economically, politically, socially, culturally and spiritually interdependent.
With the aim of guaranteeing an ever-higher level of professionalism of its human resources and quality of services provided, Company Management have decided to pursue a management path approach oriented to the Management System for the Prevention of Corruption in accordance with ISO 37001: 2016 applicable to the following fields:

Design and provision of training, technical assistance services, QHSE and PMC consulting services for the oil & gas, petrochemical, ecological, energetic and infrastructure sectors. Design and provision of pre-comissioning, commissioning, start-up, operation & maintenance, engineering and safety services.
Design of civil and industrial works, project & construction management, provision of integrated engineering services.

Commitments:
In the pursual of the prevention of corruption, towards which continuous and constant attention is directed, towards ensuring the identification and compliance with requirements and meeting the applicable legislative and regulatory provisions is considered a priority. The Management intends to provide services that comply with the new methodology also under an organizational growth profile.
To this end, continuous activities of engagement, personnel training and updating are planned and implemented at all levels, in particular to those engaged in activities related to the processes that influence and are involved in the prevention of corruption.
Within their specific areas of competence, personnel are requested to respect the requirements of the Management System Manual for the Prevention of Corruption and those documents referenced within.
With a view to preventing corruption, macro objectives are defined as part of the commitment to continuous improvement.

In particular, the Management undertakes to:

• prohibit corruption;
• ensure the review of the Company Policy (at least annually) taking into consideration legislative changes and any other company requirement;
• ensure the verification of the effectiveness of the Integrated Management System and the improvements to be made to the structure (at least annually);
• to encourage the reporting of suspected cases of corruption, or based on a reasonable and confidential belief, ensuring not to proceed with disciplinary / sanctioning measures or retaliation of any kind;
• ensure the verification of compliance with legislative requirements.

Failure by an employee to report a known or suspected wrongdoing of which the latter has become aware, will subject the employee to possible disciplinary sanctions as referred to in the Organizational Model, whose application is also foreseen for functions involved in cases of reports considered to be well founded.

General objectives:

• to actively maintain and continuously improve the Management System for the Prevention of Corruption, in accordance with ISO 37001: 2016;
• guarantee an adequate level of training and information to all staff, their constant consultation with the aim of improving of the Management System for the Prevention of Corruption;
• operate in compliance with applicable legislation and regulations;
• guarantee the correct management of any Non-Conformities detected during the implementation of the Management System for the Prevention of Corruption, including those relating to non-compliance with the Corruption Prevention Policy.

For this purpose, the Management gives full mandate to the Head of Prevention of Corruption, in order to pursue the objectives contained within this policy, by virtue of the authority and independence given to him for:

• supervise the design and implementation of the Management System for the Prevention of Corruption;
• provide guidance and advice to staff on issues related to corruption and the Management System for the Prevention of Corruption;
• ensure compliance of the Management System for Corruption Prevention with ISO 37001:2016;
• report on the performance of the Management System for the Prevention of Corruption to the Governing Body and Top Management in correct and appropriate manner.

Everyone, whether employed in an operational or a support area, is responsible for achieving adequate levels of corruption prevention, it is the firm aspiration that the Management System for the Prevention of Corruption be an integral part of the company management and that this policy be disseminated to all staff members, to anyone who works on behalf of ISS International SpA and to anyone who further requests that employees / collaborators are made aware, and to inform all stakeholders of our commitment to minimizing the risk of corruption.