Anti-Corruption Prevention Policy
Recrytera S.r.l. is aware that corruption represents an obstacle to economic, political, and social development, as well as a significant source of distortion in fairness, transparency, and the proper functioning of the market. Therefore, in carrying out its activities, the company is committed to fully respecting the anti-corruption principles reaffirmed in its Code of Ethics, principles that form the foundation of its anti-corruption management system, certified according to the ISO 37001:2025 standard.
In particular, our commitment focuses on:
Absolute prohibition of corruption
Within our organization, corruption is strictly forbidden and absolutely not tolerated in any form. The organization expressly prohibits attitudes and behaviors influenced by facilitation payments and/or motivated by the prospect of advantages unrelated to the regular functioning of economic activity and business operations.
Compliance with the law
All transactions, relationships, internal and external interactions, and contracts must comply with the principles of transparency and honesty mandated by our legislation and with the legal requirements established by our Constitution and regulated by the Civil Code in all areas: labor, corporate matters, commerce, tax matters, etc.
Appropriateness to the objectives
The purpose of the anti-corruption management system, established and maintained by Recrytera with the aim of ensuring overall compliance with the law, can be summarized as follows: Prevent corruption within the organization so that no corrupt actions occur.
Framework for objectives
With reference to this Policy, which provides direction for all efforts undertaken by the organization within the system, the specific objectives pursued focus on:
- Compliance of the system with the Standard and the requirements established in the procedures;
- Suitability of human resources to manage the system, in relation to their training, awareness, and level of involvement in communication and compliance;
- Adequacy of prevention processes in addressing the level of risk identified;
- Effectiveness in managing corruption risks arising from the organizational context, from the business partners involved in the activities, and from the projects undertaken by the organization.
Satisfaction of system requirements
The entire anti-corruption management system adopted by Recrytera has been rationally designed to reduce the level of risk the organization must address. To ensure that this purpose is achieved, the organization emphasizes the importance of each individual’s commitment to meeting system requirements. Fully meeting all requirements constitutes the fundamental strategy of our organization.
Encouraging the reporting of suspicions, without fear
Although conceived rationally to achieve its purpose, our system will never be perfect. For this reason, the organization asks everyone to report any suspicions regarding the behavior of staff members or external persons who work with the organization. In this way, the organization will be able to prevent corrupt acts and protect everyone from the negative effects they would cause. The governing body and top management assure whistleblowers full discretion and total protection from any retaliatory actions.
Commitment to continuous improvement
The variability of the context in which we operate and events attributable to “chance”—those that the organization cannot identify as “influencing or hazardous factors”—require us to consider a degree of uncertainty that we refer to as “chaoticity.” In this regard, our management system includes a continuous improvement process, in which the organization intends to involve the commitment of all internal personnel and, when appropriate, external personnel as well.
Authority and independence of the compliance function
Supervision of the effective application of the system within our organization is entrusted to the compliance function. The governing body and top management have granted this body the authority to verify and inspect all processes included within the scope of the system, business processes, and projects undertaken by the organization. The governing body and top management recognize the autonomy and independence of this body in deciding the timing, methods, depth, and extent of controls, within the limits of the budget established for this purpose.
Consequences of non-compliance with the policy
Behaviors that do not comply with this prevention policy will be subject to investigation, potential internal sanctions, and, in cases of criminal offenses, will be reported to the judicial authorities.
Chieti
24/11/2025
Management
