Integrated Management System for quality, environmental protection, occupational safety and corruption prevention

INNOVO S.R.L. is an engineering, construction, and equipment rental company operating globally in the renewable energy, communications, offshore energy, maritime, and industrial and civil works sectors. It offers custom-designed and rental products, including hoisting systems, modular pontoons and cable-laying equipment, as well as engineering solutions for subsea and offshore applications and decommissioning services. Innovo is committed to supporting the global energy transition from fossil fuels to renewable energy by gearing its design, construction and operational processes in this direction.

Confirming the above, INNOVO S.R.L. has equipped itself with an Integrated Quality, Environment, Occupational Safety and Corruption Prevention Management System in order to be able to improve the service and products it offers and to become a guarantee of fairness and competence in the area for customers and stakeholders, aiming to become a leader in the industry with an approach that focuses its attention on customer satisfaction, continuous improvement and compliance with industry regulations on Environment, Occupational Health and Safety and Corruption Prevention.

In particular, the company is committed to the following goals:

  • Identify and meet the requirements of customers, users, local authorities and stakeholders;
  • Understand customers' needs and plan their activities to fully meet them;
  • Comply with applicable legislative requirements and other requirements that the company subscribes to;
  • Identify different activities as processes to be planned, controlled, and continuously improved while at the same time best activating resources for their implementation;
  • Plan their processes with Risk-Based Thinking (RBT) approach in order to implement the most appropriate actions to assess and deal with risks associated with the processes;
  • Exploit and reinforce identified opportunities;
  • Qualitatively improve services with respect to the Environment and Occupational Safety by identifying and assessing related risks, knowing that this improves the effectiveness and efficiency of services provided;
  • Determine significant Environmental and Safety impacts;
  • To spread the culture of Environmental Protection, Occupational Safety and Corruption Prevention to the various levels of the organization and to prevent, through actions of awareness, empowerment and continuous training of employees, potential incidents that could have negative impacts on them;
  • Promote at all levels an appropriate sense of proactivity in managing their own risks;
  • Use processes and technologies to improve service quality, to prevent and reduce risks to the Safety of workers and users;
  • Prohibit all forms of corruption by adopting a zero-tolerance approach to it;
  • Implement and maintain the "Anti Bribery" System in order to ensure continuous improvement of its performance;
  • Supervise the enforcement of the internal Code of Ethics regarding the regulation of business conduct;
  • Encourage the reporting of suspects in good faith, or on the basis of reasonable and confidential belief, without fear of retaliation;
  • Make this Policy public and accessible;
  • Maintain the integrated management system adequate, efficient and effective in order to be able to adapt quickly to changing circumstances and/or constraints external to the organization;
  • Adapt this Policy to industry regulatory changes and needs arising from requirements defined in the management system with a view to continuous improvement.

Senior management provides all human and economic resources in order to enable the maintenance and achievement of prevention objectives on corrupt acts in relation to the processes of the organization.

In addition, towards customers, during the course of service, INNOVO S.R.L. is committed to transparency and continuous monitoring of satisfaction in order to continuously and effectively improve the service provided.

Purpose of the policy

It is part of the purposes of this policy to:

  • To be aware of the responsibilities of the company and those of those who work for the organization, and to maintain an irreproachable attitude toward corruption;
  • to provide information and assistance to those who work for that organization on how to recognize and deal with aspects and behaviors attributable to corruption.

It is a CRIME to offer, promise, give, demand or accept "bribes." Individuals found guilty of this offense are punishable by imprisonment of up to ten years and/or a fine. An Organization unable to prevent corruptive behavior, in addition to incalculable reputational damage, may be imposed an action and exclusion from participation in public procurement. Therefore, the Management takes its legal responsibilities very seriously.

INDIVIDUALS REQUIRED TO COMPLY WITH THE POLICY

This policy applies to all individuals working for and on behalf of INNOVO S.R.L., in the broadest sense of the term: employees at all levels, managers, officers, seconded personnel, volunteers, trainees, contractors, external consultants, representatives of third parties and business partners, sponsors, business associates or any other associated individual, wherever located.

This policy is not part of the employment contract and may be changed at any time.

Policymakers

Each employee/collaborator/business associate/partner etc. is required to read, understand and comply with the provisions contained in this policy. Prevention, detection and reporting of possible acts of corruption are the responsibility of everyone working for or under the control of INNOVO S.R.L.. Any behavior that can be seen as a possible violation of this policy should be avoided. It is the responsibility of top management to verify that this policy complies with legal and ethical duties and is respected by all stakeholders, which is why the position of Integrated Management System Manager (RSGI) of INNOVO S.R.L. has been established, having the task of supervising the design and implementation of the anti-corruption management system, implementing it, monitoring its use and effectiveness, settling any issues related to it and constantly monitoring the internal control systems and procedures aimed at countering possible corrupt acts.

Management at every level should ensure that all persons under its responsibility are aware of the policy and comply with it, and receive adequate and ongoing training on the subject. Every employee is invited to comment on the policy and on the Anti-Bribery management system in general and to suggest possible improvements. Any comments, suggestions, and questions should be forwarded under the observation of the RSGI.

In this policy, the term "Stakeholder" means any individual or organization with whom you come into contact in the course of your work: actual and potential customers, business associates, suppliers, professional contacts, consultants and government agencies, including their advisors, representatives and officials, political figures and parties, employees, partners, collaborators, etc.

Definition of corruption

It is bribery to offer, promise, give, or accept a financial or other benefit in order to induce the recipient, or another individual, to perform his or her duties improperly, or to give him or her a reward of any kind for acting inappropriately, or when the recipient behaves improperly by accepting the benefit. Benefit includes money, gifts, loans, honoraria, hospitality, services, discounts, the award of a contract or any valuable asset. Misconduct occurs when an individual acts unlawfully, contrary to ethics or expectations of good faith or impartiality related to his or her position, or abuses his or her position of trust. Misconduct may involve any activity within the organization or professional, public functions, actions in the performance of one's job, or any other activity performed by, or on behalf of, an organization of any kind.

Impermissible behaviour

It is not permitted for any employee/collaborator/business associate/partner, etc., or anyone acting on their behalf to:

  • give, promise or offer money, gifts or hospitality with the expectation or hope of receiving a business advantage, nor reward in any way a business advantage already obtained;
  • giving or accepting gifts or hospitality while business negotiations or tenders are in progress, if such conduct could be perceived as a desire to influence the outcome;
  • accepting money, gifts or hospitality from a third party of whom we know or suspect that he or she has made the offer with the expectation of obtaining a business advantage for himself or herself or anyone else in return; and
  • accepting hospitality from a third party in exaggeratedly expensive places or situations;
  • offering or accepting a gift to/from a government official or his/her representatives, or political figures or parties, without prior authorization from Management;
  • carrying out threats or retaliation against an individual who has refused to commit an act of bribery or has reported its occurrence;
  • taking any action that could be construed as a violation of this policy.

Facilitation payments and bribes

No facilitation payments or "bribes" of any kind are paid or accepted within INNOVO S.R.L.. Facilitation payments, or "bribes," are small sums of money paid under the table to secure or expedite a service (usually from or to a public official). "Bribes" are payments made in exchange for a favor or business advantage. Conduct involving the making or acceptance, by or on behalf of personnel, of a facilitation payment or "bribe," or that suggests its offer or acceptance, must be avoided at INNOVO S.R.L. If you are asked to make a payment on behalf of the organization, pay close attention to why it is being made and whether the amount requested is commensurate with the goods or services provided. Always ask for a receipt containing the reason for the payment. If you have suspicions, concerns or doubts about a payment, refer the matter to the RSGI.

Gifts, hospitality and expenses

This policy permits expenditures on hospitality or entertainment events (whether offered or received), the incurrence of which meets the criteria of reasonableness, aimed at:

  • enhance or maintain the image or reputation of the Organization;
  • offer its services more effectively.

You are not permitted to accept or give a gift to/from a third party (except of minor significance and with the consent of Management). You are allowed to give or receive to/from customers, suppliers and business partners, small promotional gifts, such as stationery bearing the Organization's name. Reimbursing a third party's expenses, or accepting an offer of reimbursement (for example, costs incurred in attending a business meeting) is generally not considered corrupt behavior. However, overpayment compared to the norm (such as, for example, an extended hotel stay) is not acceptable.

Donations

INNOVO S.R.L. does not fund political parties. If necessary, the company makes donations for charitable purposes, which are legal, ethical and in accordance with local regulations and practices. No donations may be offered or made without prior authorization from Management.

Accounting records

INNOVO S.R.L. has adequate internal and external controls in place to justify any payments made to third parties. Employees are required to declare and keep written records of all hospitality expenses and gifts, whether offered or received. Such records will be subject to review by the RSGI. Claims for reimbursement of expenses incurred for hospitality, gifts, or payments to third parties shall be submitted as required by policy, stating and recording the reason for the expense. All reporting, invoices and other records regarding transactions with third parties, including suppliers and customers, should be done in detail and with the utmost accuracy. The establishment of "slush funds" aimed at facilitating or concealing illicit payments is not permitted.

Reporting suspicions

Any Stakeholder may contact the RSGI immediately if he or she believes or suspects that any behavior is, or may be, in conflict with the provisions of this policy: for example, if a participant in a competition or potential participant offers you something in exchange for a commercial advantage, or expressly states that a gift or payment is for an advantage to other corporate entities.

Protection

Dialogue is encouraged within the organization and support is given to anyone who expresses in good faith reasons for concern in relation to this policy, even if they prove to be unfounded. Senior management ensures that no one suffers discriminatory treatment for refusing to be complicit in corrupt acts or for reporting in good faith the occurrence or possible occurrence of such conduct. Discriminatory treatment means dismissal, disciplinary measures, threats or other punitive behavior as a result of reporting. Anyone who believes he or she is a victim of such a situation may promptly inform the RSGI.

Training and communication

Updating on this policy is part of the ongoing training of all individuals working for INNOVO S.R.L. and shall be ensured on an ongoing basis. The zero-tolerance attitude towards corruption shall be communicated from the beginning of the relationship to all suppliers, contractors and business partners and reiterated throughout the relationships.

Violations of this policy

Employees who violate this policy are subject to disciplinary sanctions that may result in dismissal or prosecution for misconduct as set forth in the Disciplinary Regulations of INNOVO S.R.L. The organization has the authority to terminate relationships with other individuals and organizations working on our behalf at any time if they are guilty of violating this policy.

Supply chain

INNOVO S.R.L. procures from its own historical, qualified suppliers, on which it performs continuous checks so that the material and means used always meet expectations and do not compromise the final result of the activity.

For its own operations INNOVO S.R.L. outsources part of the services to external companies (collaborators) ensuring constant control over the same. The organization also directly monitors the Environmental and Occupational Safety aspects managed by the enterprises themselves.

Contact

If you have any questions relating to this policy, please contact us at info@innovoteam.com.

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