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Octo considers corruption to be an intolerable obstacle to business efficiency and fair competition. To this end, Octo considers ethical integrity, full respect of the law and regulations and fairness to be constant commitments of all of its personnel.

In accordance with Octo’s Code of Ethics, Octo is committed to conducting our business fairly, honestly, and lawfully. As part of this commitment, Octo has a zero-tolerance policy towards bribery and corruption of any kind. This means Octo must comply with all applicable anti-bribery and corruption (“ABC”) laws that govern both our domestic and international operations, including:

– the Italian Decree 231/2001, and,

– the UK Bribery Act 2010 (“UKBA”), and

– the U.S. Foreign Corrupt Practices Act (“FCPA”.

The Antibribery & Corruption Policy, replacing the previous 2016 one, has been approved by the Board of Directors on October 29, 2020.

No questionable or illegal practice can ever be justified or tolerated, and no performance goal should be imposed or accepted if it can be achieved only by compromising ethical standards. Octo Personnel who violate the ABC Policy and/or anti-corruption applicable laws will be subject to discipline, up to and including termination and to any other legal action to the extent necessary to protect Octo’s interests. No Octo Personnel will be subjected to demotion, penalty, or any other adverse consequence for refusing to make a prohibited payment, even if such refusal results in a loss of business or other adverse consequence to the business.

In compliance with the provisions of Octo’s Whistleblowing Policy (see below), Octo Personnel will not be discharged, demoted, suspended, threatened, harassed, or discriminated against, in any manner based upon any lawful and made in good faith reporting activity of such employee with respect to reporting of concerns regarding compliance with the current ABC Policy and/or the Anti-Corruption Laws.


As a completion of the definition of “Compliance” pillars, together with the Octo Code of Ethics and the Antibribery & Corruption Policy, Octo adopted a “Whistleblowing Policy”.

In compliance with Octo’s Organisational, Management and Control Model, pursuant to Italian Legislative Decree. n. 231 of 2001, and internal anti-corruption regulations, we have adopted a system for the management of whistleblowing reports that enables us to manage whistleblowing reports received, including anonymously. The Policy, replacing the previous 2016 one, has been approved by the Board of Directors on October 29, 2020.

We guarantee the management, analysis and handling of whistleblowing reports that are sent by or transmitted form anyone, stakeholders, Octo’s People or other third parties, also when confidential or anonymous. We consider a whistleblowing report any communications concerning behaviours that relate to Octo’s People in violation of the Code of Ethics, any laws regulations, provisions of authorities, internal regulations, 231 Model that may cause damage or prejudice to Octo.

These include cases of fraud, against the company assets and/or in financial reporting, illegitimate behaviour pursuant to Italian Legislative Decree. n. 231 of 2001, Code of Ethics violations, possible corruptions, or violations of anti-corruption regulatory instruments. Investigation are carried out by the Internal Audit Department on the reported facts and results are presented to internal inter-functional bodies dedicated to managing whistleblowing reports, the Board of Statutory Auditors and the 231 Supervisory Board.

Octo guarantees the strict confidentiality on the persons and facts reported and anonymity of whistleblowers to ensure that they are not subject to any form of retaliation.

Communication channels are included into Octo Code of Ethics.

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