Anti Bribery Management (standard ISO 37001)


Dear Customer,

Dear Collaborator,

Dear Supplier,

Dear Business Partner,


We have built our success in compliance with the principles of ethics, legality, transparency.

Operating in compliance with these principles is mandatory for us. We therefore ask the same commitment to all our stakeholders (suppliers, collaborators, business partners, consortium members, investee and associated companies).


Our business  context

We are a founding and participating company of Minerva Group Service (MGS) that is the hub of a network of controlled, participated and business partner companies.

Our mission is to provide professional services to businesses (consultancy, training, audit and business assurance). We support our customers in the delicate task of ensuring compliance of their business with mandatory and regulatory, technical, contractual and internal requirements.

Due to our business name, we are subject to auditing both by a ministerial auditor and by a statutory auditor.

We operate both in Italy and abroad. Our customers are mainly companies operating in different industries and belonging to the private sector and the public sector. Our critical suppliers are mainly professionals and companies that provide consulting, training and audit services.


Our commitment for antibribery

With this policy we expressly prohibit any attempt at bribery by all those who work on our behalf, even if this may bring significant interest or advantage to our company. This with regard to the so-called "active bribery” (that is, by subjects that operate on our behalf towards external subjects) and with regard the so-called "passive bribery” (that is, by external subjects towards subjects that operate on our behalf).

We are committed to ensuring the full and systematic compliance of all the services provided to our customers with the mandatory, regulatory, contractual, technical requirements applicable to anti-bribery.

We have adopted an ethical code for the prevention of the offenses envisaged by Legislative Decree 231/01, including corruption offenses. This code of ethics is available on our website

This policy is communicated to all our stakeholders and is available on our website


Our antibribery Objectives

Our commitment

We are committed to pursuing information antibribery objectives in accordance with the applicable mandatory requirements. Our objectives include:

1. objectives of compliance with the mandatory and regulatory requirements applicable for the anti-bribery;

2. anti-bribery objectives set in relation to specific categories of business associates (customers, suppliers, business partners, collaborators, investee companies, consortium members, public officials, supervisory and control authorities).

3. objectives of transparency and ethics in financial management, in commercial and operational management, in stakeholder management.

Our control objectives

In order to pursue our antibribery objectives, we plan and pursue operational control objectives for the treatment of bribery risks.

Our Antibribery Management System

In order to pursue our antibribery objectives, we have adopted an antibribery management system compliant with the ISO 37001 standard.

Our Antibribery Management System has been integrated into the more general corporate management system and has been planned in order to consider aspects of Governance and Internal Control System, Risk Management aspects (with reference to the guidelines of the ISO 31000 standard) and Compliance aspects (with reference to the guidelines of the ISO 19600 standard).

We have appointed an antibribery compliance function with responsibility and authority for the anti-bribery management system, for providing advice, information and awareness to the stakeholders for the prevention of corruption, for ensuring the compliance of the anti-bribery management system to the requirements of the ISO 37001 standard, for reporting on the performance of the anti-bribery management system to top management and the governing body. We have appointed a qualified and independent subject that directly report to top management and governing body.

We are committed to adapting and continuously improving our antibribery Management System and to make aware and train our stakeholders on its correct application.


The penalties

Violations of this policy and of the Antibribery Management System imply the application of disciplinary measures, including the termination of existing contractual relationships.

Our contact channels

For any report of improvement, alert, non-conformities, violation you can contact our antibribery compliance function at the following email address: We are committed to ensuring the confidentiality of reports and to prohibit any form of retaliation against reporting agents.


Alpemi Consulting