The Group is aware of the corrosive effects corruption has on societies, and its impact undermining democracy and the rule of law. To ensure the highest standards are met, principles of fairness, transparency and integrity have been included in detail in the relevant guidelines (Business Ethics and Anti-Corruption Guidelines and Conflict of Interest Guidelines) and, together with the requirements of local law, they are to be adhered to by all employees, agents, suppliers and other individuals and entities that have a business relationship with the Group. The Fiat S.p.A. Guidelines specifically address:
- the prohibition of gifts to public officials, politicians or military personnel aimed at obtaining economic advantages for Group companies
- the need to include clauses in outsourcing and joint venture agreements that specify the consequences of violating anti-corruption laws
- the prohibition of gifts and benefits-in-kind for the purpose of gaining preferential treatment
- the possibility of donations for charitable purposes only and the requirement that contributions to political parties must be approved by top management
- full compliance with laws applicable to the export of goods and services.
Compliance with business ethics standards, including those that relate to corruption, is checked through regular audits conducted by the Fiat S.p.A. Internal Audit & Compliance department based on the annual risk assessment. Over a five-year period, the audit cycle will cover all consolidated Group entities (excluding Chrysler Group).
All Chrysler Group functional areas are subject to analysis on an ongoing basis to detect risks related to corruption both through audits of the area itself and the management process governing each area. In addition, the Legal Compliance Questionnaire (LCQ) is distributed annually to the operating areas as required by Chrysler Group’s Legal Compliance and Ethics Program, managed by the Office of the General Counsel (OGC). It contains 39 general questions and up to 150 area-specific questions to ensure full awareness and compliance with Chrysler Group’s anti-corruption policies and procedures. In the event an issue is identified, the OGC will work with the Business Practices Office to investigate and resolve the issue.
In order to avoid conflicts of interest, the company’s Operating Agreement provides that Chrysler Group cannot enter into any new agreement with its members or any of their affiliates that involves aggregate payments in excess of $25 million without approval of the Chrysler Group Board of Directors. Additionally, Chrysler Group has a written Conflict of Interest policy prohibiting officers, employees and their family members from personally participating in transactions that conflict with business interests or that might influence employees’ business judgment. The Chrysler Group Business Practices Office interprets the policy, issues advisories, oversees investigations and reports non compliance to the Chrysler Group Board of Directors’ Audit Committee.