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Editors

Harry Cassin
Publisher and Editor

Andy Spalding
Senior Editor

Jessica Tillipman
Senior Editor

Bill Steinman
Senior Editor

Richard L. Cassin
Editor at Large

Elizabeth K. Spahn
Editor Emeritus

Cody Worthington
Contributing Editor

Julie DiMauro
Contributing Editor

Thomas Fox
Contributing Editor

Marc Alain Bohn
Contributing Editor

Bill Waite
Contributing Editor

Shruti J. Shah
Contributing Editor

Russell A. Stamets
Contributing Editor

Richard Bistrong
Contributing Editor

Eric Carlson
Contributing Editor

Benchmarking Alert: Taking Ferrari’s anti-corruption policy for a spin

The Italian luxury sports car maker has persevered from humble beginnings to become the tenth largest automaker in the world. Its stylish designs and powerful engines have fueled envy from adults and millions of posters on bedroom walls of children (of all ages). How does the Prancing Horses’ anti-corruption policy compare?

1. No free F1 tickets. 

By way of example, it is explicitly forbidden to give or promise to give money, a supply contract, a car, a F1 car or a show car (or even to apply special conditions for those vehicles), F1 tickets or events participation, in exchange or return of any improper advantage, benefit or anything of value.

2. A risk-based approach to training. 

The training programs will be targeted to employees who will be identified according to their roles in Ferrari Group and their related exposure to the risk of corruption, and will support participants and take them through presentation of questions and practical situations that can occur throughout the company’s business.

3. Facilitation Payments? No, grazie.

Ferrari Group explicitly prohibits Facilitation Payments or “grease payments” – i.e. illegal or unofficial payment made in return for services that the payer is legally entitled to receive without making such payment.

This is similar to Kraft Heinz, Burberry, Disney, Unilever, Carlsberg, Apple, Novartis, Microsoft, Volkswagen, Airbus, GM, 3M, and Pfizer that all ban facilitating payments. Coca-Cola, Tesla, and ExxonMobil might approve some facilitating payments. Walmart doesn’t mention facilitating payments at all.

4. Extortion.

Extortion payments must be authorized by the Group Compliance Function; if it is not possible to report the demand and seek approval, the payment shall be promptly notified through a report indicating the date, place and amount paid and the description of the objective circumstances of serious and imminent violence, or threat, in which the payment was made. Extortion payments must be accurately recorded in Ferrari Group books and records.

This is similar to Kraft Heinz, Disney, Unilever, Carlsberg, GM, Microsoft, Pfizer, and ExxonMobil the only other mentions of extortion we’ve seen.

5. Be careful who you hire. 

No direct or indirect benefit or advantage (whether financial or not financial) shall be obtained in any recruitment process by any directors, officers and employees of Ferrari including but not limited to the HR Department and/or relevant managerial functions.

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View the full eleven-page Ferrari anti-corruption compliance practice.

View more anti-corruption policy benchmarks here.

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