Anti-Bribery Policy of Entaksi Solutions SpA

Entaksi Solutions SpA is committed to countering bribery in all its forms, that is “offering, promising, giving, accepting or soliciting an undue advantage of any value (which could be financial or non-financial), directly or indirectly, and irrespective of location, in violation of applicable law, as an inducement or reward for a person acting or refraining from acting in relation to the performance of that person’s duties”.

The organisation has therefore implemented an Anti-Bribery Management System (ABMS) compliant with the UNI ISO 37001:2025 standard which, through the controls derived from it, maintains the alignment of the Integrated Management System (IMS) with the applicable legislation on countering bribery. The System applies to the processes operated by Entaksi in carrying out its activities, including those of the branch Entaksi Solutions SpA – Irish Branch.

Management recognises that the effectiveness of the System depends on the spread, at all levels of the organisation, of a culture based on integrity, transparency and compliance, and undertakes to promote it actively, by leading by example, allocating adequate resources and embedding the prevention of bribery into the Company’s decision-making and operational processes.

Read the full text of the Anti-Bribery Policy

Anti-Bribery Policy

For its Anti-Bribery Management System, Entaksi has developed and undertakes to adopt the following policy, considered appropriate to the purpose of the Company and to the context in which it operates:

  1. bribery is prohibited, in any form, whether direct or indirect;
  2. the soliciting, offering and acceptance of gifts, hospitality, sums of money, complimentary items, donations, customary gratuities or similar benefits, of any value, is prohibited where these are intended to influence, or may reasonably be perceived as intended to influence, the impartiality of a decision or the exercise of the recipient’s duties;
  3. the receipt and offering of gifts, hospitality and similar benefits unrelated to the purposes referred to in the preceding point are permitted only within the limits established by a specific procedure, subject to prior authorisation and mandatory recording;
  4. compliance is required with the laws, regulations and internal provisions adopted for the prevention of and fight against bribery and with the pantouflage (post-employment restrictions) prohibition applicable to the Company;
  5. employees and collaborators are required to declare to the Anti-Bribery Function or to Management any conflict of interest, whether actual or potential, relating to their own role; declared conflicts are assessed, documented and managed in accordance with internal procedures;
  6.  the objectives of the Anti-Bribery Management System are established and reviewed annually;
  7. the Company undertakes to satisfy the requirements of the Anti-Bribery Management System and to promote a culture of bribery prevention within the organisation and in its relations with its business associates;
  8. the Company encourages the reporting, including anonymously, of attempted, suspected and actual acts of bribery, and of any breach of or weakness in the Anti-Bribery Management System, to the Anti-Bribery Function or to the designated personnel; reports are handled so as to protect the confidentiality of the identity of the reporting person and of the persons involved, and to protect against any form of retaliation, voluntarily adopting as a reference standard the safeguards laid down by Italian Legislative Decree 24/2023;
  9. the Company carries out due diligence on projects, transactions, business associates and personnel in positions at risk, proportionate to the assessed bribery risk;
  10. the Company is committed to the continual improvement of the Anti-Bribery Management System;
  11. the Company has established an Anti-Bribery Function (ABF), ensuring its authority, independence, resources and the competences required to perform the role;
  12.  the Company has established and set out in its internal regulations the sanctions applicable in the event of non-compliance with the anti-bribery policy, in accordance with the applicable national collective labour agreements.

Failure to comply with this policy constitutes grounds for disciplinary sanctions for employees and managers and for termination of the contractual relationship and/or the application of penalties for consultants, collaborators and business associates. No sanction is applied to anyone who has reported in good faith or has refused to take part in activities at risk of bribery.

Reporting concerns

The Anti-Bribery Function of Entaksi, that is the person appointed with the responsibility and authority for the operation of the anti-bribery management system, can be contacted for reports of actual or suspected bribery at the email address anticorruzione@entaksi.eu.

Reports may also be submitted anonymously. The Anti-Bribery Function guarantees the confidentiality of the identity of the reporting person, of the persons involved and in any case mentioned in the report, as well as of the content of the report and of the related documentation.

Reports are handled in accordance with the dedicated internal procedure and within the time limits set by law: the Anti-Bribery Function issues the reporting person with an acknowledgement of receipt within seven days and provides feedback on the action taken or envisaged within three months of the date of the acknowledgement of receipt.

Documentation relating to reports is retained for as long as necessary to handle them and in any case for no longer than five years from the date on which the final outcome of the procedure is communicated, in compliance with personal data protection legislation.

The Anti-Bribery Function uses the mailbox exclusively; it is not accessible to any other Entaksi personnel.

Last updated: 09 September 2026

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