ESRS disclosure: ESRS G1 \ DR G1-3

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  • Provide a detailed description of the procedures currently implemented to prevent, detect, and address any allegations or incidents of corruption and bribery, as required under Disclosure Requirement G1-3.
  • Question Id: G1-3_01

    The Ferrari Group strives to uphold the highest standards of integrity, honesty, and fairness in all internal and external affairs and does not tolerate any kind of bribery. The laws of virtually all countries in which Ferrari operates prohibit bribery and any violation of anti-bribery and anticorruption laws would entail serious consequences for both companies and individuals, which can result in significant fines, imprisonment of individuals and reputational damages. These principles are laid down in the Code of Conduct and the Anticorruption Compliance Practice, which officially entered into force in 2020 and applies to the entire Ferrari Group pursuant to local legislation. In particular, in line with our impacts, risks, and opportunities, the Practice aims to define principles and provide rules of conduct and controls to all Ferrari Group people in the most at-risk activities (i.e. dealing with Public Officials, dealing with suppliers and third parties acting on behalf of the Ferrari Group, Gifts & Hospitalities, Non-profit Initiatives, Mergers, Acquisitions and Disposals, etc) in order to prevent corruption-related crimes and ensure compliance with Anticorruption Laws to which Ferrari is subject. Such rules are further enhanced in internal Procedures regulating those specific areas deemed at risk from an anticorruption perspective. These Procedures include, among others: the Gifts and Entertainment Expenses Procedures; the No-Profit Initiatives Procedure; the Procedure governing relations with Public Officials and Relevant Private Entities; the various Procedures governing the selection of Third Parties (e.g. suppliers, dealers, sponsors) and the related anticorruption due diligence. The practice covers the following risk: “Potential non-compliance with Anticorruption Laws requirements due to external context or internal elements”. Ferrari’s policy applies to every director, officer or other employee, consultant, agent, representative, supplier or business partner. It entails that none of these shall, directly or indirectly, give, offer, request, promise, authorize, solicit or accept bribes or any other perquisite (including gifts or gratuities, with the exception of commercial items universally accepted in an international context of modest economic value, permitted by applicable laws and in compliance with the Code of Conduct and all applicable practices and procedures) in connection with their work for Ferrari at any time or for any reason. The Internal Audit and Compliance functions periodically review the Anticorruption Practice and monitor its implementation to ensure it operates with effectiveness. The Compliance function is entrusted to oversee the design and implementation of the Anticorruption Practice, to provide advice and guidance to personnel on Anticorruption Laws and issues relating to bribery and corruption, to monitor the related risk and to provide support in training activities. The most senior level in the Ferrari Group that is accountable for the implementation of this practice is the FLT. The Practice has been drafted in line with the ISO 37001:2016 standard and is consistent with the United Nations Convention against Corruption. Practices and procedures are drafted with the precautionary principle in mind and are functional to the pursuit of the interests of stakeholders, who are therefore the main reference point considered in their drafting. The Anticorruption Practice has been adequately circulated, publicized and disseminated by Ferrari both internally and externally, also through its inclusion in the relevant contractual agreements and arrangements. Please refer to the Ferrari corporate website at the following link https://www.ferrari.com/en-EN/corporate/practices. The Anticorruption Practice includes a specific section dedicated to training. Accordingly, mandatory training programs are periodically developed by the Compliance function with the support of the Human Resources department. These trainings have the objective of providing the necessary knowledge of Anticorruption Laws and the instructions to recognize any potential criticalities to avoid questionable actions from an ethical standpoint. Please refer to the “—Whistleblowing” section, where information on reporting and addressing concerns related to business conduct is included. In 2024, there were no convictions and no fines for violation of anti-corruption and anti-bribery laws, therefore, no action has been taken to address breaches in procedures and standards of anti-corruption and anti-bribery. In 2024, there were no incidents in Ferrari’s value chain directly involving the Company or its employees.

    Report Date: 4Q2024
  • Is the investigating committee or the investigators distinct from the management chain responsible for the prevention and detection of corruption and bribery?
  • Question Id: G1-3_02

    The Internal Audit and Compliance functions (to be collectively intended as the “Whistleblowing Team”) are independent from the chain of management involved in the report, and attend periodical training sessions to properly manage the Whistleblowing process. However, if one of the members of the Whistleblowing Team is in a situation of potential conflict of interest, he/she shall promptly declare the existence of such a situation to the other members of the Whistleblowing Team, abstaining from any activity related to the report and not being made aware of the subsequent developments of the relevant activities. The report itself will be managed exclusively by the other members of the Whistleblowing Team. In the event that all members of the Whistleblowing Team are in a situation of potential conflict of interest, the Audit Committee will be informed of the situation and, to guarantee the same level of independence required, the report will be handled by the identified corporate functions, in accordance with the Whistleblowing Procedure.

    Report Date: 4Q2024
  • Provide detailed information regarding the nature, scope, and depth of the anti-corruption and anti-bribery training programs that are either offered or mandated by your organization, as stipulated under Disclosure Requirement G1-3 for the prevention and detection of corruption and bribery.
  • Question Id: G1-3_06

    During 2024, dedicated trainings and awareness initiatives on various compliance topics such as anticorruption have been provided to our employees, with the aim to promote the consistency of their behaviors with the applicable anticorruption laws and regulations. We believe that every employee shall be informed on the applicable Anticorruption laws, so to be aware of the risks, the relevant personal and corporate responsibilities and have a clear understanding of the actions needed to tackle bribery and any potential violation of such laws. Mandatory induction training programs are delivered to all new joiners both in person and through a specific e-learning platform with the support of the Human Resources department. These trainings provide the necessary knowledge of Anticorruption laws and the instructions to recognize any potential criticalities. Nevertheless, the Compliance function monitors the level of awareness on anticorruption - and all other compliance topics, among which antitrust, privacy, and confidentiality, of the entire Ferrari population, including the FLT. Indeed, every year, for all compliance topics, the Compliance function assesses the level of risk of exposure of each area, function and activity. According to the results of this assessment, in-depth training is deployed to the at-risk functions on the specific compliance topic. The training programs are targeted to employees who are identified according to their roles in Ferrari and their related exposure to the concerned compliance risk.

    Report Date: 4Q2024