Ethics and Compliance

Ghella is a leading Company in the construction of major infrastructure projects worldwide.

We build excellence in a sustainable and innovative way to leave a better World to the next generations.

We value and believe in our people. We operate at the highest standards of behaviours and ethics.

We provide active leadership and foster trust, openness and collaboration to develop best teamwork.

Innovation is imperative. We maintain internal challenge to continually deliver new solutions for a progressive World.

In respect of our tradition, as infrastructure builders, we are always a step ahead on safety.

We act for the future and strive to protect the environment minimizing our footprint.

Successful engagement and approach to communities and stakeholders is of main focus, contributing to the achievements and consensus of our Projects.

Our Policies and Guidelines, together with the Code of Ethics, set the standard for our Company and all the stakeholders worldwide.

   

 

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Our mission is to build excellence in a sustainable and innovative way.
Our attitude is to get it right the first time.

Ghella guarantees a suitable, adequate and effective quality management system, continuously improving performance and developing sustainability while applying our risk management approach across the delivery of our construction services.

This policy is a formal management declaration implemented by a quality management system compliant with the requirements of ISO 9001.

Our compliance with all requirements is ensured through:

  • Adhering to statutory obligations, standards, specifications and codes of practice;
  • Exceeding the expectations of the client and all stakeholders, delivering state-of-the-art work;
  • Ensuring transparency and communication of lessons learnt, aiming for continual improvement;
  • Implementing an effective and efficient quality management system to achieve our Quality goals, regularly measuring our performance;
  • Maintaining continuous control of the entire production process through detailed planning, followed by compliance and quality control tools;
  • Undertaking research and development of innovative technologies to optimise quality;
  • Providing suitable and skilled resources to develop, maintain and spread our Quality culture.
  • Establishing the infrastructure and the provision of financial resources to allow the quality management system to achieve its intended outcomes.

This policy is communicated to our employees as part of the mandatory induction process and it is available to all stakeholders via the company’s website and the intranet.

It is reviewed annually during management system reviews to ensure it is consistent with the company's mission and vision..
 

Giandomenico Ghella
Chairman, March 2019

This policy is a formal management statement to comply with the principles of Health & Safety in the workplace, implemented by a management system that complies with the requirements of ISO 45001.

In respect of our tradition, as infrastructure construction experts we are always a step ahead on safety.

Health & Safety is imperative: our goal is Zero Harm.

Ghella guarantees a suitable, adequate and effective Health & Safety management system (H&SMS), continuously improving performance and developing sustainability while applying our risk management approach across the delivery of our construction services.

We are committed to ensuring the Health & Safety of all our people through:

  • Complying with all legal, contractual and local requirements;
  • Promoting a safety culture, always preferring preventative measures to protective measures;
  • Guaranteeing healthy working conditions and a safe work environment and infrastructure, including machine safeguarding;
  • Minimising the likelihood of incidents, injuries and occupational diseases;
  • Utilising innovative technologies in our production processes, and providing suitable and skilled resources in order to eliminate hazards and reduce risks to workers' health and safety;
  • Involving, consulting and engaging workers in risk management process, making them active and responsible participants;
  • Continuously training workers and providing consistently updated information, instruction and supervision to embed a positive Health & Safety culture;
  • Full cooperation with local communities, stakeholders and regulatory bodies to ensure information transparency and two-way communication.

This policy is communicated to our employees as part of the mandatory induction process and it is available to all stakeholders via the company’s website and the intranet.

It is reviewed annually during management system reviews to ensure it is consistent with the company's mission and vision.
 

Giandomenico Ghella
Chairman, March 2019

Protection of the Environment is a priority. We operate at the highest standards of sustainability.

Ghella guarantees a suitable, adequate and effective environmental management system (EMS), which provides a framework for the continuous improvement of our environmental performance and developing sustainability, while applying our risk management and life cycle approach throughout the delivery of our expert construction activities.

This Policy is a formal management declaration implemented by a management system that complies with the requirements of ISO 14001.

Our environmental commitment is displayed through:

  • Ensuring compliance with all legal, contractual and local requirements;
  • Providing the financial and infrastructure resources to ensure the effective management of the environmental management system;
  • Preventing pollution, working on the direct and indirect impacts that can be controlled and/or influenced by our own operations, and by applying a risk management approach;
  • Mitigating negative impacts on surrounding communities;
  • Fully cooperating with local communities and regulatory bodies to ensure information transparency and two-way communication;
  • Protecting the local environment, protected areas and endangered species;
  • Reducing the consumption of natural resources and raw materials;
  • Reducing - and optimising the management of - waste through reuse and recycling;
  • Reducing energy consumption and promoting renewable energy while minimising greenhouse gas emissions;
  • Applying the most suitable technical and organisational measures to protect and preserve ecosystems and biodiversity;
  • Safely managing and reducinghazardous substances;
  • Providing continuous training to embed an environmental culture that prevents potential negative impacts;
  • Utilising suitable resources and innovative technologies in our production processes.

This policy is communicated to our employees as part of the mandatory induction process and it is available to all stakeholders via the company’s website and the intranet.

It is reviewed annually during the management system reviews to ensure it is consistent with the company's mission and vision.
 

Giandomenico Ghella
Chairman, March 2019

Ghella’s mission is to build excellence in a sustainable and innovative way.
We work with our clients to provide efficient infrastructure that creates social and economic value for the communities where we operate and we strive to achieve this in the most responsible way, towards the environment as well as society.
Our commitment to sustainability is demonstrated in the following areas, where we:

Ethics and Transparency

  • Hold compliance with all legal, contractual and local requirements as a priority;
  • Have zero tolerance for corruption and provide reporting channels for breaches, as outlined in our Code of Ethics, Anti-corruption Guidelines and Whistleblowing policy;
  • Respect the human rights of all employees and others affected by our operations, as outlined in our Human Rights Guidelines.

Local Communities and Stakeholders inclusion

  • Engage with all stakeholders and proactively listen to the legitimate expectations of local communities to leave a positive legacy behind our projects;
  • Protect and promote the wellbeing, human capital and environmental, historical and cultural heritage of local communities.

Staff Wellbeing and Development

  • Ensure health, wellbeing and safety to the highest standards in all workplaces and promote a ‘Zero Harm’ culture, as outlined in our Health and Safety Policy;
  • Value and promote equality and inclusion in our workforce and do not tolerate any discrimination or inappropriate behaviours, as outlined in our EDI Policy and Appropriate Workplace Behaviour Policy;
  • Develop the skills of our people and promote a healthy work-life balance.

Environmental Protection

  • Evaluate, monitor and reduce our environmental footprint and, where possible, create environmental benefits, as outlined in our Environmental Policy;
  • Adopt eco-design principles in our projects, where appropriate.

Supply Chain engagement

  • Work with suppliers to ensure an ethically and environmentally sustainable supply of goods and services for our business, as outlined in our Sustainable Procurement Policy;
  • Give preference to materials and services with the greatest circular-economy benefit.

Innovation and continuous improvement

  • Promote innovation by creating a sustainability culture integrated at all levels, where ideas are freely expressed and considered;
  • Strive to be at the forefront of technological, design and management innovation;
  • Continuously improve our standards, policies and procedures to enhance the implementation of the principles expressed in this policy.

This policy is communicated to our employees as part of the mandatory induction process and it is available to all stakeholders via the company’s website and the intranet.

It is reviewed annually during management system reviews to ensure it is consistent with the company's mission and vision.

 

Giandomenico Ghella
Chairman, March 2019

Ghella’s mission is to build excellence in a sustainable and innovative way.

Our commitment to delivering sustainable outcomes, through the infrastructure we contribute to create, extends beyond the boundaries of our direct operations to the supply of materials, works or services provided by third parties. To this end, where relevant and proportionate, together with our designers and our supply chain we aim to:

  • Ethical Sourcing – source products, materials and services ethically through recognised credible standards, including procuring fairly traded goods where available, and request that our ethical and anticorruption principles are subscribed by our supply chain;
  • Circular Economy and Resource Efficiency – minimise waste and material use by giving preference to materials, products and services with greatest circular economy benefits;
  • Environmental footprint – consider the carbon and water footprint of key materials and products and purchase low carbon/less water intensive alternatives, where available;
  • Biodiversity and Environmental Protection – work with suppliers that actively manage their impact on habitats and on the environment;
  • Eco-design – where possible, apply innovative eco-design principles to our projects with the aim to minimising the impacts associated to the procurement of materials and energy;
  • Community engagement – offer local businesses and social enterprises the opportunity to be part of our supply chain;
  • Labour Standards – implement a proactive approach to tackling hidden labour exploitation in our supply chain, including subcontractors working on our sites;
  • Supplier diversity – work with suppliers that actively manage diversity and inclusion in their workforce;
  • Supply Chain Engagement – adopt a collaborative approach in our relationships with suppliers and subcontractors to make them part of our sustainability journey.

We have a structured process in place to qualify and, where appropriate, monitor our suppliers and subcontractors against the sustainable procurement principles outlined above. In addition, we share with our supply chain relevant policies and guidelines developed for our own operations, with the aim of ensuring a common approach to sustainability and ethics through our value chain.

This policy is communicated to our employees as part of the mandatory induction process and it is available to all stakeholders via the company’s website and the intranet.

It is reviewed annually during management system reviews to ensure it is consistent with the company's mission and vision.
 

Giandomenico Ghella
Chairman, March 2019

Human Resources are our key competitive and development factors.

We value and believe in our people. We provide active leadership and foster trust, openness and collaboration to develop best teamwork and results.

Our commitment is revealed through:

  • Attracting, retaining and promoting talented employees;
  • Encouraging a good working environment, continuously increasing motivation, collaboration, engagement and trust between people;
  • Ensuring the best working conditions for all employees, granting rates and working hours in line with international and national standards and regulations, and providing specific social welfare;
  • Providing training and development plans in order to give our people the best development tools to better realise their own potential;
  • Developing technical skills, according to our business trends and values;
  • Implementing skills assessment and acquisition pathways in order to develop our people so they can achieve their maximum potential;
  • Maintaining a constant and respectful dialogue with workers’ representatives and trade unions in order to guarantee a favourable working environment that is based on collaboration and communication;
  • Ensuring fair and adequate remuneration;
  • Including transparency in recruitment processes, matching our strategic needs with the motivations, expectations, attitudes and abilities of candidates;
  • Promoting health, safety and welfare in the workplace, according to our Health and Safety Policy;
  • Not discriminating on the basis of age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, religion or belief, or sexual orientation.

This policy is communicated to our employees as part of the mandatory induction process and it is available to all stakeholders via the company’s website and the intranet.

It is reviewed annually during management system reviews to ensure it is consistent with the company's mission and vision.
 

Giandomenico Ghella
Chairman, March 2019

Ghella is an equal opportunity employer that endevours to maintain a safe and productive work environment where people are treated with dignity, courtesy and respect. Inappropriate behaviours in the workplace are not acceptable and are not condoned by Ghella. They can also be unlawful under local legislation and may expose the persons concerned and Ghella to liability.

Inappropriate behaviour may occur by way of insults, comments, gossiping or spreading of rumours, social isolation or targeting, physical acts, intimidation or emotional manipulation. Inappropriate behaviours may be constituted by:

  • Bullying - a repetitive anti-social or unreasonable behaviour that offends, degrades, intimidates or humiliates a person, including continuously and deliberately excluding someone from workplace activities, withholding information essential for effective work performance or setting unreasonable deadlines or tasks unreasonably below or beyond a person’s skill level, denying access to information, supervision, consultation or resources such that it has a detriment to the worker, spreading misinformation or malicious rumours, changing work arrangements, such as rosters and leave, to deliberately inconvenience a particular worker or workers or excessive scrutiny of work.
  • Discrimination - when a person is treated less favourably than another because of a particular attribute (directly or indirectly). Our Equality, Discrimination and Inclusion policy provides more details on these aspects.
  • Harassment - behaviour which, because of its severity or persistence, is likely to create a hostile or intimidating environment and detrimentally affects a person's participation or engagement and includes, offensive, belittling, humiliating, intimidating or threatening, unwelcome and unsolicited and is of the type that is usually unreciprocated and can usually be expected to be repeated, makes the work environment unpleasant, humiliating or intimidating, and can make it difficult for work to be effectively completed.
  • Sexual Harassment - any behaviour of a sexual nature, which is unwelcome. It may involve a single incident or a series of incidents. Sexual Harassment may include physical contact (e.g. touching, patting, pinching, kissing or embracing someone, sexual assault and rape), verbal comments and non-verbal actions (e.g. leers, stares, displays of sexually explicit material, offensive body and hand movements, suggestive letters, drawings and emails, indecent exposure or stalking), including the unwelcome or inappropriate promise of rewards in exchange for sexual favours or adverse employment decisions as a result of denied sexual favours.
  • Victimisation - when a person targets, exploits or treats another person unfairly including taking action, bullying or intimidating a person because they have made a complaint, denying promotion opportunities without reasonable consideration of their objective merits or reasonable requests for flexible work arrangements being denied due to a personal dislike of the person making the request.

Ghella encourages employees to try to initially resolve issues directly and informally through a process of discussion and conciliation. However, it is crucial that employees do not ignore inappropriate behaviours they may experience, witness or become aware of as this may give the impression that these behaviours are acceptable. Managers are tasked to provide support for informal grievances and complaints or trigger formal investigations/escalation as appropriate.

Ghella provides access to confidential reporting channels that may be used for cases of inappropriate behaviour in the workplace. Our Whistleblowing policy provides more details on this.

Ghella requires that its business partners, suppliers and subcontractors align to the appropriate workplace behaviour principles expressed in this policy.

This policy is communicated to our employees as part of the mandatory induction process and it is available to all stakeholders via the company’s website and the intranet.

It is reviewed annually during management system reviews to ensure it is consistent with the company's mission and vision.
 

Giandomenico Ghella
Chairman, March 2019

Ghella is an equal opportunity employer and strives to support an inclusive culture of collaboration where people can express their views freely within the context of our values. We believe a diverse workforce is key to attracting the best talents and to motivate and develop outstanding people, regardless of their characteristics. We recognise the benefits that a diverse workforce can bring in understanding the needs of a diverse client base and consider embracing differences to be conducive to creativity and innovation. We strive to demonstrate our commitment to EDI principles in a number of areas:

  • Equal opportunities
    We are committed to be a fair, transparent and inclusive employer which bases all recruitment and employment decisions solely on merit, while introducing reasonable adjustments to enable all individuals to perform their duties and access the same professional opportunities. In particular, we strive to promote and improve female participation in our company and achieve gender equity.
  • Workplace behaviour
    We will not tolerate unlawful discrimination against an individual on grounds of age, disability, injury, ethnicity (including race, colour and nationality), gender or gender reassignment, religion or belief, sexual orientation, marriage and civil partnership, carers’ responsibility, pregnancy and maternity.
    We promote a culture of respect for EDI principles among our staff with the aid of specific training and we take discrimination very seriously, including disciplinary measures when inappropriate behaviours are reported. Our Appropriate Workplace Behaviour policy provides more details on this and our Whistleblowing policy describes our reporting procedures.
  • Inclusive workforce and supply chain
    Where possible, we aim to invest in local employment and to increase the use of local suppliers to ensure our workforce and our supply chain are reflective of the countries where we operate.

Ghella requires that its business partners, suppliers and subcontractors align to the EDI principles expressed in this policy by subscribing to our Code of Ethics and related policies in the qualification and contractual phases.

This policy is communicated to our employees as part of the mandatory induction process and it is available to all stakeholders via the company’s website and the intranet.

It is reviewed annually during management system reviews to ensure it is consistent with the company's mission and vision.
 

Giandomenico Ghella
Chairman, March 2019

Ghella is committed to prevent and act promptly to events that may undermine its values and vision. For this reason, Ghella has established a whistleblowing process to encourage and guide the reporting of any inappropriate / unlawful conduct,or violation of Ghella’s Code of Ethics, Anti-Corruption guidelines, Human Rights guidelines, Organizational Model ex D.Lgs. 231/01 or additional local compliance policies of other Group companies (hereinafter “Compliance Program”) and to guarantee a fair, impartial, prompt and confidential evaluation of potential claims by our full- and part-time - employees, interns, subcontractors, suppliers and consultants.

What to Report

Whistleblowing reports should specifically concern breaches to Ghella’s Compliance Program and to Ghella’s internal procedures or illegal conduct pursuant to local legislation applicable to Group companies.
Reports may be:
a) communications of alleged breaches / violations of the Compliance Programs, internal procedures requirements or local legislation applicable to Group companies;
b) requests for clarification on topics expressed in the Compliance Program.
Should the nature of the report fall outside the scope of this policy, a more relevant Ghella policy or process, where available, will be indicated by the recipient of the report.

How to make a Report

Formal reports should be made in writing, using the dedicated reporting channels available for all Ghella companies (see Annex 1) and should include a detailed description of the breaches/violations raised.
Minor concerns may be resolved, without the need for a formal report, by talking directly to the person whose conduct is causing concern. If this is not possible concerns/requests for clarifications should be raised with line managers or alternatively with Compliance Managers.

Handling and analysis of reports

Supervisory Body (Organismo di Vigilanza- OdV) or the Compliance Managers are formally responsible for receiving and handling Whistleblowing reports and have the duty to ensure appropriate follow-up.
Each report will be considered carefully, and a confidential and accurate analysis will be conducted by the relevant Supervisory Body or Compliance Manager, who will obtain information by the departments concerned and/or by other individuals involved. Should a report not contain sufficient details, the Supervisory Body or Compliance Manager may request additional information by the whistleblower. In order to keep track of communications, ensure transparency and facilitate a formal assessment, written communication is to be preferred throughout the process. The analysis and investigation phases will be addressed and processed within 90 days, unless the nature of the reported issue requires additional time.
Supervisory Body and Compliance Managers will keep reporting individuals informed on the progress of their claim. In particular, they will notify them when the claim has been duly processed and when the investigation has been concluded. Where possible, Ghella will provide feedback to the whistleblower on the outcome of investigations. It should be noted, however, that it may not be possible to give detailed information regarding the actions taken by the Group as this could infringe legal duties, including the privacy and data protection rights of the persons involved or trade secrets or confidentiality undertakings previously accepted by the Group.

All reports must be recorded and all attached documents, including those produced or acquired during the analysis phase, will be appropriately filed.
In the unlikely event of all available internal reporting channels failing to provide a reasonable or efficient remedy to the reported breach, as a last resort, a good faith report to the police or state prosecutors may represent an alternative potential option to report a breach. Appropriate counselling is advised before taking such step.
All recipients of reports mentioned in this policy have the duty to treat sensitive information such as personal data in line with the General Data Protection Regulation (GDPR) and Data Protection Laws.

Whistleblower Protection and disciplinary measures

Reports and the information within them, as well as the identity of the individuals submitting the report (if this has been shared), will be treated confidentially. The identity of the whistleblower will not be revealed without their prior written consent, unless required otherwise by law.
It is also acceptable to report anonymously, without disclosing any personal data. It should be noted, however, that this choice may hinder the resolution of the reported issue, as feedback may be needed for a successful investigation.
Ghella is fully committed to protect whistleblowers from repercussions or any form of disadvantage or discrimination at the workplace linked to or resulting by submitting a report.
Any whistleblower that reports internally a concern in good faith, will not be prosecuted and no action will be taken against him/her in case of the information supplied cannot be proven or becomes irrelevant or insufficient to address the report. If additional relevant information emerges after a report is made, the whistleblower is encouraged to report this to Ghella immediately, regardless of whether this information supports or invalidates the original report.

Ghella will also take appropriate disciplinary measures in case of bad faith reports, violation of the internal procedure system or relevant applicable laws, and/or for carrying out threats or retaliation against individuals submitting reports.
Disciplinary measures will be proportionate to the extent and severity of the misconduct ascertained and may go as far as termination of employment.

This policy is communicated to our employees as part of the mandatory induction process and it is available to all stakeholders via the company’s website and the intranet.

It is reviewed annually during management system reviews to ensure it is consistent with the company's mission and vision.
 

Giandomenico Ghella
Chairman, March 2019

Legislative Decree no. 231/2001 introduced the criminal liability of legal entities/companies, together with that of the natural person who has materially committed the illegal fact, into the Italian legal system. Such provision adapts the Italian legislation to international conventions previously signed by Italy.

In order to increase the Company’s capability to effectively avoid the risk of committing offences, Ghella decided to integrate its own organisational systems by adopting the so-called “Model 231”. Specific crimes covered by Decree n.231 also relate to the following offences:

  • corruption;
  • crimes against industry and trade;
  • human rights crimes;
  • health and safety crimes;
  • money laundering;
  • environmental crimes;

An autonomous, independent and professional Supervisory Body is entrusted with monitoring, controlling and updating the Model and the Code of Ethics adopted by Ghella.

Model 231, drafted in accordance with international best practices, was adopted by Ghella with a Board resolution on June 27, 2006. The Model is updated regularly in accordance with legislative and organisational changes. The last update was adopted following a Board of Directors resolution on July 24, 2017.