In accordance with the terms defined by the Code of Ethics and in observance of the 10th principle of the Global Compact, according to which “businesses should work against corruption in all its forms, including extortion and bribery”, the fight against corruption in Abubaker Technical Services led to the Anti-corruption Compliance System, certified as UNI ISO 37001: 2016 (Anti-Bribery Management System) compliant and consisting of an Anticorruption Model;
Guidelines and company procedures, in order to define roles and responsibilities of the subjects involved and operating methods for control processes referred to in the Anticorruption Model.

The Anticorruption Model is an element of the internal control system aimed at strengthening certain prevention protocols to eliminate active or passive corruption, ensuring compliance with the principles introduced by the anti-corruption laws in accordance with international best practices.

It provides a systematic reference framework of regulatory anti-corruption instruments and policies, which we intend to pursue, while acting as a guide against corruption risks that could arise during business activities.

To ensure effective measures capable of both assisting and advising on anticorruption, Abubaker Technical services appointed the Compliance Department to provide specialised indications on anti-corruption measures and  clarifications on:

• contents of the Model and Guidelines, Italian anticorruption laws, and laws in the countries of operation
• application of provisions in the Anticorruption Model and Guidelines, also with regard to the applicable laws of the relevant country

The Compliance Department is also responsible for the regularly revisioning and monitoring the Anticorruption Model to ensure its maximum effectiveness. It also checks to ensure that the Model is applied correctly.

The application of the Anticorruption Model is the direct responsibility of Abubaker directors, statutory auditors, managers and employees, and all those who, both directly and indirectly, permanently or temporarily, establish relations, each within his/her relevant functional area and responsibilities (the “Recipients”). All recipients are required, therefore, to comply, with the utmost care and attention, with all the principles and provisions set forth therein. Abubaker, to spread appropriate knowledge and understanding of the Model, has defined:

• a binding anti-corruption training program for Recipients, modulated according to the qualifications of the Recipients and the different levels of involvement in sensitive activities
• specific contractual “compliance” clauses, which include, among others, the obligation to comply with the principles set by Abubaker’s Code of Ethics and its Anticorruption Model

Policies and procedures contained in the Anticorruption Model and in the Guidelines are an integral part of the Anticorruption Compliance System.

Violation by Abubaker personnel of the principles and provisions of the Anticorruption Model, and, in general, of the Anticorruption System is a serious contractual breach, for which Abubaker reserves the right to impose disciplinary measures in compliance with the legal framework and/or contract that can be applied to the individual relationship, with disciplinary measures and by terminating the relationship (dismissal or termination). In any case, Abubaker reserves the right to take action for any damages incurred, pursuant to current legislation.

The Recipients are required to report any violation of the Anticorruption System in general, of Abubaker’s policies and / or of any anticorruption law of which they become aware, even indirectly, in the course of their business.

To this end, there are proper channels of communication that allow sending violation reports, even anonymously, therefore protecting the whistle-blower against any form of retaliation, discrimination or penalty, guaranteeing the confidentiality of his/her identity.

The Whistleblowing platform is one of the channels of communication through which employees, collaborators, consultants, suppliers of Abubaker technical services or any other person who has a relationship with the company can send, even anonymously, a report of violations, presumed or known, of applicable laws or regulations, the Ethics Code, the Anti-Corruption Model and/or the Organisation, Management & Control Model pursuant to the Italian Legislative Decree 231/01.