• The Group Compliance Office interacts with  all corporate departments to ensure that internal rules, processes and corporate activities constantly comply with the applicable regulatory framework and Ethical Code
  • Revision of the “231” Compliance Programmes
  • In 2010, the Code of Conduct was also revised and amended.
  • The Internal Control System monitors the efficacy and efficacy of business operations

The Group Compliance Office – under the supervision of the General Counsel, Corporate Affairs and Group Compliance Department – interacts with all corporate departments to ensure that internal rules, processes and corporate activities constantly comply with the applicable regulatory framework and Ethical Code.
The Group Compliance Office actively participates in identifying the risks of non-compliance with internal and external rules, thereby playing a key role in preventing judicial and administrative penalties or major financial losses, including damage to reputation.
The principal projects implemented in 2010 by the Group Compliance Office include:

  • the revision of the “231” Compliance Programmes, adopted by the Group in accordance with the spirit that characterises Pirelli, for continuous reinforcement of its own corporate governance and, in particular, its internal control system mechanisms, including in consequence of the new “presumed offences,” the liability of companies for offences committed by their employees and/or collaborators that have recently been enacted by lawmakers. All employees were notified of the launch of the project through the company intranet. Furthermore, the following individuals at the Group received personal notice of the launch of the project: executives of Italian companies, officers of Italian companies, middle managers of Italian companies and expatriate employees of Italian companies working abroad;
  • methodological support under Law 262/05 for the “Corporate Financial Reporting Manager” and assistance for Group companies to ensure that corporate activities are operated in compliance with Law 262/05;
  • In 2010, the Code of Conduct appended to the “231” Compliance Programmes and applicable to all Group companies were also revised and amended. The Code of Conduct set out the operating application of the principles of the Ethical Code and introduce specific rules to avoid the establishment of environmental situations favourable to the commission of offences in general and acts of corruption and administrative offences in particular as envisaged in Legislative Decree 231/2001. The Guidelines will be distributed to all employees in their local language in 2011. Specific training activities will also be planned during the year.

In regard to corruption and related offences, as set out in the Ethical Code and in the Code of Conduct, Pirelli has a clearly stated position of not tolerating “corruption in any guise or form, or in any jurisdiction, or even in places where such activity is admissible in practice, tolerated, or not challenged in the courts. For this reason,” the Code continues, “Addressees of the Code are prohibited from offering complementary gifts or other benefits that could constitute a breach of rules, or are in conflict with the Code, or might, if brought to public notice, damage the Pirelli Group or just its reputation.” The Code also states that Pirelli

  • “defends and protects its corporate assets, and shall procure the means for preventing acts of embezzlement, theft, and fraud against the Group”;
  • “condemns the pursuit of personal interest and/or that of third parties to the detriment of social interests.”

The Whistleblowing Procedure, described in the following section, is a tool used for enforcing compliance with Group rules.

In turn, the Internal Control System relies on an integrated process of identification, measurement, management and monitoring of major risks, monitors the efficacy and efficacy of business operations, while guaranteeing that documents and decisions are traceable; the reliability of accounting and operating information; compliance with laws and regulations; the protection of company assets.