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Code of Ethics

Organization, Management and Control Model
and Group Code of Ethics


IRCA S.p.A. has adopted an Organization, Management and Control Model pursuant to Legislative Decree no.231/01 and a Group Code of Ethics in the firm belief that they are appropriate tools for disseminating rules and regulations to company personnel and to all individuals acting in the name and on behalf of the Company, in order to ensure an ethically agreed conduct and to pursue compliance with the principles of legitimacy, fairness and transparency.

IRCA S.p.A. has appointed its own Supervisory Body (Organismo di Vigilanza) which has the task of supervising the correct functioning, effectiveness and observance of the Organisation, Management and Control Model and compliance with the principles of the Code of Ethics.

In 2024 IRCA S.p.A. has updated its Code of Ethics which defines rules and principles to conduct our businesses within a framework of legality, fairness, transparency, confidentiality, and respect for human dignity, in compliance with the law and regulations of the countries in which we operate.

In line with the commitments defined in the IRCA Group's new sustainability strategy, the new document reinforces the message that all Group companies are committed to supporting fair and responsible use of resources in terms of social responsibility and environmental protection.

Furthermore, as part of the activities to implement the Code of Ethics, IRCA adopted three new internal policies aimed at establishing procedures to protect the Company in its activities with third parties, namely: “Third Party Due Diligence” Policy, that governs the verification activities on third parties that must be conducted before contractually engaging; “Economic Sanctions” Policy, that governs the verification activities with regard to the management of relations with countries and individuals from certain geographical areas which will allow the Company a preventive control in order to avoid sanctions; and the “Anticorruption” Policy, that unifies and integrates in a unified framework for all group companies, both Italian and foreign, the rules and safeguards for preventing and combating corruption.

The Code of Ethics, approved by the Board of Directors, applies to all group stakeholders, members of corporate bodies and employees, as well as customers, suppliers, distributors and agents, advisers and all those who operate to pursue the Group’s objectives.

It is adopted by all IRCA Group Luxembourg Midco 4 S.à.r.l. and the companies controlled by the latter.


IRCA S.p.A. has adopted a Whisteblowing Procedure that regulates the reporting procedure concerting alleged violations and illicit conducts within the Group activities, in order for the Company to carry out all appropriate activities and measures to avoid any further occurrence.

More specifically, the Whistleblowing Procedure reflects the provisions of the Italian Whistleblowing Decree and the Directive (EU) 2019/1937 and fully regulates the matter in coordination with Decree no. 231/01.

Any report shall be submitted to the company through the dedicated platform, which ensures the confidentiality of the reporter and allows for anonymous reporting as well.


Download code of ethics

Download Whistleblowing procedure