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Home » Compliance » Anticorruption and Anti-Bribery Policy

Anticorruption

WYDE complies with international anti-bribery regulations and, in particular, with the legislation of the European Union. EU legislation plays a fundamental role in supporting anti-corruption efforts by establishing high and consistent legal standards through both dedicated anti-corruption measures and anti-bribery provisions embedded in broader regulatory frameworks.

We prioritize ethical business practices and maintain a zero-tolerance approach to all forms of bribery and corruption, whether active or passive. Our Code of Ethics outlines the core principles that guide our actions, and we foster a culture of openness where employees and stakeholders are encouraged to speak up and report potential misconduct.

Our reputation is one of our most valuable assets, and we are committed to protecting it. We conduct our business responsibly, ethically, and in full compliance with applicable laws and internal policies. We strive to uphold not only the letter of the law but also its spirit. All WYDE personnel, including members of the Board of Directors, are expected to uphold this responsibility and reflect these principles in their daily work. Our approach is guided by our global integrity and compliance program, which defines our standards and overall governance framework.

We believe our success is built on the quality of our services. We do not offer, promise, or provide improper payments or other undue benefits to influence third parties or obtain an unfair business advantage, regardless of the country or business environment in which we operate. Likewise, we do not allow anyone to exert improper influence over our decisions, and we are committed to avoiding even the appearance of inappropriate conduct. Our Global Anti-Bribery Program establishes the standards, procedures, and training necessary to ensure ongoing compliance.

We expect the same commitment to lawful and ethical conduct from our business partners. We select our partners carefully and require them to uphold the same high ethical, social, and environmental standards that we apply to ourselves. This enables us to ensure that neither WYDE nor its stakeholders are exposed to unnecessary risks arising from unethical or unlawful activities, wherever they may occur.

Code of Conduct

Integrity and compliance are embedded in everything we do and in the reasons why we do it. This ensures that our mission drives positive change and contributes to a better future for everyone.

Our Code of Conduct summarizes the core principles that guide our actions.

WHISTLEBLOWING: REPORTING MISCONDUCT

Reports of misconduct that violate applicable laws, regulations, or WYDE’s internal policies and procedures are a vital source of information, enabling the company to take lawful and independent action while upholding the highest standards of integrity and compliance.

Substantiated reports concerning employee conduct provide the basis for internal investigations, the application of disciplinary measures where appropriate, and the implementation of actions aimed at preventing future misconduct. WYDE handles all reports in accordance with its internal procedures governing investigations into misconduct and the protection of whistleblowers.

 

PROTECTION OF THE WHISTLEBLOWER’S IDENTITY AND OTHER RELEVANT INFORMATION ABOUT THE WHISTLEBLOWING SYSTEM

Who can submit a report?

The whistleblowing procedure is available to all employees and third parties who possess information regarding potential violations or questionable conduct involving WYDE personnel. It is intended for reporting misconduct by WYDE employees, users (including temporary staff), or suppliers and their employees working with WYDE.

Reports must be submitted electronically through the online reporting form.

The entity authorized to receive and manage reports is WYDE’s Supervisory Body (Organismo di Vigilanza – Legislative Decree 231/2001 Model) and the Technical Secretariat supporting the Supervisory Body.

Go to the Whistleblowing Form

Legislation

The European Union develops new legislation and works to prevent corruption within the framework established by the Treaty on the Functioning of the European Union (TFEU).

  • The EU is required to ensure a high level of security, including through the prevention and combating of crime and the approximation of criminal laws (Article 67 TFEU).
  • Article 83 TFEU defines corruption as a Eurocrime—a particularly serious offence with a cross-border dimension—for which the EU may, under certain circumstances, establish common minimum rules.
  • The legal basis for combating fraud and any other illegal activity affecting the EU’s financial interests is Article 325 TFEU, which requires both the European Union and its Member States to protect the Union’s budget.

 

Anti-bribery legislation and policies

Modernizing the EU anti-bribery framework

In her 2022 State of the Union Address, European Commission President Ursula von der Leyen announced an update to the EU’s anti-corruption legislative framework to strengthen the prevention of and fight against corruption across the European Union.

On May 3, 2023, the European Commission presented a new proposal to combat corruption through criminal law. While bribery remains at the core of the proposed legislation, it also addresses many other forms of corruption that threaten citizens and undermine society.

Among its objectives, the proposed legislative framework aims to:

  • Strengthen prevention by raising public awareness of the harmful impact of corruption, addressing risks before they arise or escalate, and fostering a culture of integrity.
  • Expand the definition of corruption offences beyond the traditional concept of bribery to include, for example, embezzlement, trading in influence, abuse of office, obstruction of justice, and illicit enrichment linked to corruption offences.
  • Introduce minimum criminal penalties for different corruption offences to ensure a level playing field across all Member States.
  • Extend limitation periods for prosecuting corruption cases before the courts.
  • Ensure that law enforcement authorities and public prosecutors have adequate investigative tools and resources to combat corruption effectively.

Through this proposal, the EU modernizes the current fragmented framework, which predates the Treaty of Lisbon, and implements the international obligations established by the United Nations Convention against Corruption (UNCAC).

The new EU Anti Corruption measures include:

  • Communication on the fight against corruption.
  • Proposal for a Directive of the European Parliament and of the Council on combating corruption through criminal law.
  • A new EU sanctions regime specifically targeting corruption.

Until the new Directive is formally adopted, the primary legislation remains:

  • The 1997 Convention on the fight against corruption involving officials of the European Communities or officials of the Member States.
  • Council Framework Decision 2003/568/JHA on combating corruption in the private sector, which criminalizes both active and passive corruption.
  • Council Decision 2008/852/JHA establishing a network of contact points against corruption

 

Protection of the EU’s financial interests

Legislation aimed at combating fraud and corruption affecting the financial interests of the European Union is a fundamental pillar.

  • Directive (EU) 2017/1371 (PIF Directive) establishes rules on the definition of criminal offences and sanctions to combat illegal activities affecting the EU budget.
  • Under Regulation (EU, Euratom) 2020/2092 on the conditionality regime, the European Commission may propose the suspension of EU funding for Member States where breaches of the rule of law, including corruption, put the sound financial management of the EU budget at risk.
  • The European Public Prosecutor’s Office (EPPO), established by Regulation (EU) 2017/1939, has the mandate to investigate and prosecute cases of cross border corruption affecting the EU’s financial interests.
  • The European Anti Fraud Office (OLAF) conducts administrative investigations in accordance with Regulation (EU) No. 883/2013 to combat corruption and fraud.

 

Sector specific legislation

The fight against corruption is supported by EU legislation in several key areas:

  • Anti money laundering (AML): The Fifth Anti Money Laundering Directive requires Member States to establish central registers of bank accounts and beneficial ownership. An updated Sixth Anti Money Laundering Directive was proposed in July 2021. Directive (EU) 2018/1673 establishes corruption as a predicate offence for money laundering.
  • Asset recovery and confiscation: Includes rules for recovering the proceeds of crime, such as Directive 2014/42/EU and Regulation (EU) 2018/1805 on the mutual recognition of freezing and confiscation orders.
  • Whistleblowing: Directive (EU) 2019/1937 concerns the protection of persons who report breaches of Union law and aims to strengthen the detection of corruption.
  • Public procurement: EU rules are designed to prevent corruption in public procurement procedures.
  • Tax evasion: Directives 2010/24/EU and 2011/16/EU provide for mutual assistance between Member States in combating tax evasion.

Monitoring and improvement

WYDE is committed to ensuring that its anti corruption measures remain effective and up to date. To achieve this, the company adopts the following activities:

  • Periodic reviews: We carry out regular reviews of the company procedures most exposed to risk, such as payment management and supplier relationships, to ensure transparency.
  • Analysis of reports: We monitor the Whistleblowing channels to promptly identify any irregularities or areas for improvement, while always ensuring the protection of the reporting person.
  • Policy updates: This Policy is reviewed annually or whenever regulatory changes occur, such as updates to the 231 Model, to reflect international best practices.
  • Training: We assess the effectiveness of employee training programs to ensure that a culture of integrity is fully shared across all levels of the organization.

Roles and responsibilities

The effectiveness of this Policy depends on the involvement of every level of the organization. WYDE defines the following responsibilities:

  • Directors (CEO): have primary responsibility for promoting a culture of zero tolerance towards corruption, approving the guidelines, and ensuring that the company operates with integrity.
  • Supervisory Body (OdV): monitors the implementation of the Policy, manages reports of misconduct through the Whistleblowing system, and provides support for updating the protocols of the 231 Model.
  • Department Managers: are responsible for ensuring that the activities of their teams, particularly in procurement, sales, and relations with Public Administration, are carried out transparently and in compliance with company procedures.
  • All employees, collaborators, and business partners: are required to understand and comply with the principles of this Policy, avoid situations involving conflicts of interest, and promptly report any suspected misconduct.

Approval, validity and policy updates

This Policy has been approved by the Board of Directors of WYDE and enters into force with immediate effect. The document forms an integral part of the Organization, Management and Control Model pursuant to Legislative Decree 231/01 and will be subject to periodic review to ensure its continued alignment with regulatory developments, organizational changes, and the findings of the monitoring activities carried out by the Supervisory Body.

Policy sharing and communication

The Anti Corruption Policy is shared with everyone working at WYDE through internal communication channels in order to ensure transparency and promote the adoption of responsible conduct.

Last updated: 06/03/2026