The Group is committed to the highest business integrity and ethical standards. Key components of this commitment are embedded in Group codes of conduct. Fiat S.p.A. and Chrysler Group are aligned in terms of the principles and contents of their codes, following international best practices in the respect of local legal requirements.
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 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, ICT Assets and Stakeholder Engagement.
The document, available in ten languages (Italian, English, French, German, Spanish, Polish, Dutch, Portuguese, Chinese and Japanese), may be consulted and downloaded from the Group’s internet and intranet sites and is posted on company boards where employees have direct access. Copies can also be obtained from Human Resources, the Legal department or the Head of Internal Audit. 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 of, and on behalf of, one or more Group companies. Diffusion of the Code follows different steps: Corporate Officers must sign a binding document(1) expressing the commitment to abide by all of its rules; Managers must sign a letter declaring awareness and acceptance of its content; other employees receive a copy of the Code during the hiring process and their employment confirmation letter makes reference to the Code.
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. In 2013, a new Anti-Corruption Policy was approved for Chrysler Group, which updates and consolidates the company’s anti-corruption rules and procedures. The Integrity Code, Corporate Policies and Standards of Conduct can be found on the online employee portal.
The Group disseminates the principles established in these documents and the values of good governance to all employees. In 2013, a total of 43,630 Group employees worldwide were involved in training courses focused on Corporate Governance (including code of conduct), Anti-corruption and Human Rights (including non discrimination) topics. Among these training initiatives, 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.
The Group’s commitment to the respect for human rights applies across the entire organization without exception; in fact, security personnel are also trained on this topic. In 2013, 435 security personnel employed directly by Fiat Group(2) were trained in policies and procedures concerning aspects of human rights. Third party organizations which provide this service to the Group are also expected to adhere to these principles by signing contract clauses.
Aware of the importance attributed also by external stakeholders to the respect for human rights, business integrity and ethical standards, the Group extends its commitment to the promotion of the adoption of the Code as a best practice standard to 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 laws and regulations, particularly those related to anti-corruption, money laundering, terrorism and other crimes constituting liability for legal persons. In Latin America, for example, a dedicated website(3) was created to support access for all stakeholders to the Code of Conduct and to serve as an extra channel for receiving complaints, including from third parties such as suppliers and clients. Similarly, to enhance the channels for receiving alleged violations of the Code of Conduct, Fiat S.p.A. created a dedicated email address directed to the Fiat S.p.A. Chief Audit Executive(4). At Chrysler Group there are dedicated hot lines and dedicated email address(5) available to report anonymously alleged violations.
In addition, supplier self-assessment questionnaires and field audits are regularly conducted by internal Supplier Quality Engineers and/or external organizations to verify the levels of adherence to the sustainability standards required by the Group. Suppliers are required to provide references on how they manage and prevent all forms of discrimination, harassment, child labor and forced labor in the workplace, as well as any sort of bribery and corruption (public/private), and on how they protect human rights, including freedom to associate.
Under the Fiat S.p.A. Code of Conduct, Fiat Group “does not employ any form of forced, mandatory or child labor, namely it does not employ people younger than the permissible age for working established in the legislation of the place in which the work is carried out and, in any case, younger than 15, unless an exception is expressly provided by international conventions and by local legislation.” The annual survey of child labor at Group companies covered more than 99% of employees(6) worldwide, and showed that no incidents of child labor or forced and compulsory labor took place in any of the companies mapped, including those located in countries that have not ratified ILO Conventions on these issues.
The survey also confirmed that no Group company employs individuals under the minimum working age set by local legislation, apprentices under the statutory minimum age, or minors under 15 years of age in countries where the minimum age is lower.
(1) For reference, see Appendix C of the Code of Conduct.
(2) The mapped population refers to security personnel employed at Group companies in Argentina, Brazil, Italy, Mexico, Poland, Serbia and Venezuela.
(6) Including Sevel Italia.
To address the potential risk of child labor, the Group has initiated several projects in areas where we have operations. Projects aimed at advocating inclusion and promoting completion of schooling typically takes the form of job training courses in several countries.
In Brazil, for example, Group companies participate in the programs organized by the National Industrial Apprenticeship Service (SENAI) and other local institutions. Throughout the year the “Formare” program saw Magneti Marelli engaged in efforts to support four schools that provide vocational training to young people as well as an internship in the Amparo, Hortolândia, Maua and Lavras plants. Also in Brazil, since 2006 Teksid do Brasil has been a partner in the government project “Filhote” geared towards children and adolescents from the Betim region. The project offers a chance to attend laboratories in: carpentry, weaving, computer science, literature and circus performance.
In Mexico, in collaboration with the local institutions, the Fundación Chrysler I.A.P offers troubled youths a chance to continue their schooling and develop further by granting scholarships.
In India, Fiat India Automobiles Ltd (a 50-50 joint venture between Fiat Group Automobiles S.p.A. and Tata Motors Ltd), in collaboration with “Don Bosco Vyawasaik Prashikshan Kendra (DBVPK)” (Pune), started the Program called “Diksha” aimed at providing educational paths and technical training for the youth of the country with the primary objective of offering a decent living to orphans, disadvantaged and poor students who otherwise may be deprived of good educational facilities. The company has financially supported the establishment of the skill training center “Fiat & Don Bosco Experiential Skill Training Center” at Chinchwad (Pune) to offer vocational training to students interested in a career in manufacturing. The program, certified by Fiat and Don Bosco, is recognized as equivalent to all the courses of the Government of India and is licensed by the National Council for Vocational Training - New Delhi. During 2012-2013, 349 students participated in the program and more than of 90% of qualified students are now employed in the automobile sector.