Anti-Bribery Policy

ADMINISTRATIVE LIABILITY POLICY

Anti-bribery Management Systems ISO 37001


Theras Lifetech S.r.l. unipersonale (Organization) aims to place itself as one of the main realities operating in their branch, through the adoption and the fulfillment of a Management System for Administrative Liability pursuant to the D.Lgs. 231/01 and of the Anti-bribery (UNI ISO 37001-2016).

Such System integrates the Company Policy (PO_01), which identifies the Organization intentions within the product quality assurance and the procedures implemented in compliance with the ISO: 9001 - ISO: 13485 standards and the CE marking of medical devices of its own manufacture.


This Policy establishes the following main guidelines:

  • Seek customers and patients’ full satisfaction by providing services and products, trying as much as possible to use every available resource in order to guarantee the compliance with the duty of diligence, good faith and transparency;
  • Operate to meet contractual requirements and needs of Customers, including patients;
  • Make use of means and resources to:
    • provide services and supply products in total conformity of the agreements stipulated, and in full compliance with the current regulations on the matter;
    • pursue the best possible workplace health and safety;
    • operate observing the environmental protection requirements, which make up a crucial role of our civil society
  • Determinate the internal and external basics which are relevant to the established purposes, which may condition the possibility of pursuing and achieving the goals of the Anti-bribery Management System.

The objectives set by the Organization can be very briefly defined as it follows:

  • Systematically implement the principles and the requirements set out by the Organizational Model of Management and Control pursuant to Legislative Decree 231/2001, concerning corporate liability;
  • Increase its market share working to obtain full customers and patients’ satisfaction;
  • Act ensuring effectiveness, efficiency and reliability of services and products offered in relation to the requirements/conditions expressed in the contractual documents;
  • Pursue the best possible safety and health conditions at the workplace, operating also observing the environmental protection requirements, with reference to the principles of prevention and continuous improvement;
  • Comply with all applicable laws, rules and regulations related to the areas in which the Organization carries out its activities;
  • Follow the applicable legal requirements and other regulations that the Organization endorses, apropos its environmental, health and safety aspects;
  • Increase its professionalism, enhancing the outward image;
  • Work according to the principles of the 231 System, as in integral part of the business management the disclosure of which must be guaranteed to the employees, to the corporate bodies, and to anyone who works in partnership with the organization;
  • Operate in order to constantly improve the 231 System;
  • Avoid unnecessary wastes of energy and natural resources, including water;
  • Apply, whenever possible, environmental criteria in the choice of packaging materials and consumables;
  • Reduce waste production, with reference to hazardous waste, starting from the source in each manufacturing/procedure and encourage waste management according to a priority scale that endorses, where possible, the re-use, recycling, and recovery of raw materials
  • ensure the adoption of appropriate environmental behavior by suppliers and by the companies working on behalf of the Organization, in accordance with the practices and procedures adopted;
  • Increase the security level on the workplace and in the company;
  • Increase the level of involvement of corporate functions within the 231 System;
  • Increase the level of involvement of workers on subjects such as health and safety at the work environment, including through the help of its representatives;
  • Adopt the best techniques and procedures for emergency prevention and avoidance;
  • Raise awareness to pursue an effective prevention action;
  • Strive for the highest level of hygiene, safety and health in working environments;
  • Work to ensure that the personnel and heads of departments, within the limits of their respective responsibilities, are made aware and trained to carry out their tasks according to the company procedures and to the regulations in the protection of health and safety of the workers;
  • Pursue an open and constructive attitude toward the community, Public Authorities and stakeholders;
  • Prohibit bribery in all areas;
  • Always require, both within as well as towards the public, the compliance and the application of anti-bribery laws;
  • Encourage the reporting of suspicions in good faith, or on the basis of a reasonable or confidential belief, without fear of retaliation;
  • Increase efforts to constantly improve the anti-bribery management system;
  • Instruct employees of the tasks, authorities and independence of the Compliance Function for the anti-bribery;
  • Explain what impact and consequences non-compliance actions to the anti-bribery policy may have for the Organization.

These objectives are not always constantly monitored during the work, but also analyzed and reviewed during the re-examination of the anti-bribery management system with the representatives of each function and the corporate bodies.

As per the short-term goals, the Company has prepared an appropriate document in order to determine specific indicator of the 231 System.

The data recorded on these documents are analyzed during the review of the system and, when necessary, updated and integrated with new targets and/or indicators.

To achieve the company’s objectives, the General Management is committed to:

  • Ensure that the anti-bribery policy is supported at all levels of the Organization;
  • Communicate the policy directly to both the staff as well as the stakeholders which represent a bribery risk above the lower levels
  • Properly publish the policy through internal and external communication channels;
  • Provide necessary resources to reach goals;
  • Encourage the continuous improvement of individual abilities of each employee or associate, to improve the company’s atmosphere;
  • Re-examine periodically anti-bribery policy in order to ensure a continued adequacy;

The distribution and the disclosure of this Policy, as well as the objectives and the implementation programs, take place through the publishing of this document, together with the documentation of Company 231 System and the anti-bribery management system.

The requirements and the implementing arrangements of the System outline the Company Organization, for which full observance is required from all employees, within the respective competences and responsibilities, always keeping in mind that the way in which relevant activities are carried out is a specific task and duty of a those who performs them, and not of the person who controls them.

The company has established the institutional channel anticorruzione@theras-group.com, where it is possible to reach out to the person in charge of the Anti-corruption compliance function (Eng. M. Losa) for every aspect related to this policy or the anti-bribery management system implemented by Theras Lifetech S.r.l. unipersonale



Salsomaggiore Terme, 18/05/2020

Theras Lifetech S.r.l. unipersonale
The Directorate

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