The Fiat S.p.A. Code of Conduct represents a set of values recognized, adhered to and promoted by the Group, which believes that conduct based on the principles of transparency, integrity and fairness is an important driver of social and economic development. The Code of Conduct is a pillar of the governance system which regulates the decision-making processes and operating approach of the Group and its employees in the interest of stakeholders.
The latest version of the Fiat S.p.A. Code of Conduct, which took effect in February 2010, is a revision of the 2003 version that replaced the Code of Ethics published in 1993.
The Code of Conduct expands on aspects of conduct related to the economic, social and environmental dimensions, underscoring the importance of dialogue with stakeholders.
Explicit reference is made to the United Nations’ Universal Declaration of Human Rights, the principal Conventions of the International Labour Organization (ILO), the OECD Guidelines for Multinational Enterprises and the US Foreign Corrupt Practices Act (FCPA). Specific guidelines, which are an integral part of the Code of Conduct, were created concerning the following aspects: Environment, Health and Safety, Business Ethics and Anti-Corruption, Sustainability for Suppliers, Human Capital Management, Human Rights, Conflict of Interest, Community Investment, Data Privacy and ICT Assets.
Employees are informed of the content of the Code in the manner most appropriate to local practices. The document, available in Italian and eight other languages (English, French, German, Spanish, Polish, Dutch, Portuguese and Chinese), may be consulted and downloaded from the Group’s internet and intranet sites. Copies can also be obtained from Human Resources, the Legal department or the Compliance Officer. The Code applies to the members of the Fiat S.p.A. Board of Directors, to all employees of Group companies and to all other individuals or companies that act in the name and on behalf of one or more Group companies. The Group disseminates the principles established in the Code of Conduct and the values of good governance to all employees (including security personnel), whatever their level or role, through periodic training and other information channels.
Fiat S.p.A. promotes the adoption of the Code as a best practice standard for the business conduct of partners, suppliers, consultants, dealers and others with whom it has a long-term relationship. In fact, Group contracts worldwide include specific clauses relating to the recognition of and adherence to the principles underlying the Code of Conduct and related guidelines, as well as compliance with local regulations, particularly those related to corruption, money laundering, terrorism and other crimes constituting liability for legal persons.
In 2003, Fiat S.p.A. adopted a Compliance Program in Italy (pursuant to Italian Legislative Decree 231/2001), which incorporates Article 2 of the OECD Convention of 1997 on bribery of foreign officials in international business transactions and is constantly updated to reflect legislative changes. Potential bribery and corruption are monitored continuously by the Compliance Program Supervisory Bodies (pursuant to Italian Legislative Decree 231/2001) at Group companies in Italy and, more generally, by sector Compliance Officers for Group companies worldwide.
In 2011, Italy formally implemented EU Directives 2008/99/EC and 2009/123/EC, which determine criminal liability for companies in the event of harm to the environment. Moreover, environmental crimes became part of Italian Legislative Decree 231/2001. The Fiat S.p.A. Audit & Compliance department performed a risk assessment of the sensitive processes possibly affecting the environment. As a result, the Compliance Program pursuant to Italian Legislative Decree 231/2001 has been updated to include these processes.
Finally, when starting up, operating or closing a business activity, it is standard practice for the Group to evaluate the economic, social and environmental impacts through the relevant corporate functions and established procedures.
Chrysler Group has an Integrity Code available in several languages and Standards of Conduct that are applicable to all employees. Together with the Chrysler Corporate Policies and Procedures, these documents represent the company’s firm commitment to high business and ethical standards and contribute to creating a corporate culture that is characterized by integrity, transparency and accountability. The Integrity Code details rules of conduct for employees, including dealing with third parties such as suppliers, customers, government officials and business partners, as well as conflict of interest and internal control issues. The Corporate Policies are a collection of approximately 50 company statements that support the Integrity Code and cover topics such as Discrimination and Harassment Prevention; Workplace Violence Prevention; Employee Health and Safety; and Environmental Protection; among others. The Standards of Conduct describe actions or behavior which violate Chrysler Group’s standards and which may result in disciplinary actions. The Integrity Code, Corporate Policies and Standards of Conduct can be found on the online employee portal.
Each year all salaried Chrysler Group employees complete the Ethics and Integrity Code web-based awareness training and acknowledge they have read and understood the Code, and that they know whom to contact for questions or concerns. Completion of the training is documented and reported to senior leadership team members. This training includes instruction on the Foreign Corrupt Practices Act and, where pertinent, management is required to participate in training focused on this legislation.
