Transmed has adopted the Code of Ethics and has entrusted the functions of guarantor to its Watch Structure.
Transmed has adopted the Anti-corruption Guideline, a document that contains the principles governing the prevention and fight against corruption, and the internal rules regarding the ethical and transparent conduct of business activities.
The Anti-corruption Guideline specifies the actions that must be taken in compliance with both national and international regulations regarding the prevention of corruption, ensuring that all Transmed's operations and activities are conducted in accordance with the highest standards of integrity and legality.
Corruption includes any behavior aimed at offering, promising, giving, receiving, or soliciting undue advantages of any kind in order to obtain or maintain a business or undue advantage.
The Anti-corruption Guideline provides a specific procedure to identify, prevent, and manage corruption risks, defining roles and responsibilities to ensure compliance with legal obligations and to promote a corporate culture based on transparency and integrity.
Model 231
Legislative Decree 8 June 2001 n. 231 introduced rules and regulations concerning the administrative liability of entities into the Italian legal system.
According to this regulation, companies can be held responsible, and consequently sanctioned, in relation to certain offences committed and attempted in the interest or to the advantage of the company itself by its directors or employees. Companies can, moreover, adopt organization, management, and control models suitable to prevent these offences.
The Model 231 consists of an organic set of principles, rules, and provisions functional to the creation and management of a control and monitoring system of sensitive activities to prevent the commission of the offences envisaged by Legislative Decree n. 231 of 2001.
Transmed's Model 231 was originally drawn up in 2011 and subsequently updated to adapt it to the progressive expansion of the list of offences envisaged in relation to the administrative liability of companies, up to the new formulation approved by the Board of Directors on 9 March 2023.
Transmed has adopted a Guideline for the reporting, including anonymously, of alleged irregularities, implementing specific communication channels for their receipt. Personnel and third parties may make written or oral reports of violations of which the whistleblower has become aware in the work context.
Transmed ensures the receipt and analysis of each report by applying criteria of utmost confidentiality suitable, inter alia, to protect the honourability of the persons reported and the effectiveness of the investigations, consistent with the legal provisions on whistleblowing. Anyone who receives a report outside the prescribed channels shall promptly forward it through the prescribed communication channels.
Communication channels provided:
Transmed has adopted the Privacy and Data Protection Guideline, a document describing the general principles to be observed for the correct application of personal data protection regulations and the rules aimed at ensuring, within the company organisation, the correct management of activities related to the processing of personal data.
The Privacy and Data Protection Guideline defines the fulfilments and specifies the actions to be taken in compliance with both national and European legislation with regard to the processing and protection of personal data, so that the processing of personal data is carried out with respect for the fundamental rights and freedoms of natural persons and, in particular, for the right to protection of personal data.
In particular, the Privacy and Data Protection Guideline identifies a 'data protection' management system based on the subdivision of roles and responsibilities, as well as of the related tasks and powers, at corporate level, among the persons involved in personal data processing operations, in order to ensure, in compliance with the timeframes indicated by the GDPR 2016/679, compliance with legal obligations.
In addition, the Privacy and Data Protection Guideline provides for specific procedures aimed at implementing, within the company organisation, the various obligations provided for by the legislation on the protection of personal data, including a special procedure for handling any breaches of personal data (so-called 'data breach').