For ICM Group, it is essential for each company activity to be guided by ethical values and principles, all of which are defined in the Code of Conduct that each of the Group Companies must adopt to guide their actions. Such Code of Conduct is based on the principles of correctness, transparency, honesty and integrity in compliance with the highest national and international standards and guidelines in the management of the activities in which the Companies belonging to the Group operate. In such general picture, strict compliance with the current legal regulations, loyalty, correctness and transparency when acting, close attention for the high quality of the business activity, strict respect for human dignity, the protection of physical and moral integrity, as well as the appreciation of its own staff represent General Principles and, consequently, conduct standards by which all the individuals involved in the business activities must abide. Taking inspiration from the conviction that all activities are also conducted in favour of society, the Code of Conduct is reflected in the convinced adherence to conducts in line with its contents and, consequently, each of the Maltauro Group Companies adopts the Group Code of Conduct as a document aimed at regulating the conducts of employees, collaborators, the management and the entire Senior Management of the different Companies. Through the application of the Code of Conduct contents, each company of the group undertakes to abide by and ensure compliance with the general and specific principles established therein as well as to spread its contents by means of an internal continuous training process.

    Code of Conduct ICM Group
    Integrated Policy ICM Group


    To implement the Group Code of Conduct, ICM Group has adopted its own Legality Protocol and its own Anti-Corruption Protocol, which – through the application of a strict system of conduct and corporate procedure standards – are aimed at fighting mafia infiltration attempts in the work sites and plants of the Group Companies, and at preventing corruptive conducts from being adopted in favour of the Group Companies.
    Document attached:
    - Legality Protocol of ICM Group
    - Anti-Corruption Protocol ICM Group

    Legality Protocols
    Protocollo di Legalità del Gruppo ICM

    Anticorruption Protocol
    Protocollo Anticorruzione del Gruppo ICM


    Wherever Public Administrations have signed specific Legality Protocols with territorially competent Authorities, such protocols shall be strictly applied by the Group Companies operating in such contexts.

    Legality Protocols Metropolitana di Napoli
    Protocollo di Legalità Metropolitana di Napoli

    Legality Protocols Line 1 Metronapoli
    Protocollo di Legalità Linea 1 Metronapoli

    Operating Protocols for Financial Monitoring Line 1 Metronapoli
    Protocollo Operativo per il Monitoraggio Finanziario Linea 1 Metronapoli

    Legality Protocols Line 6 Metronapoli
    Protocollo di Legalità Linea 6 Metronapoli

    Operating Protocols for Financial Monitoring Line 6 Metronapoli
    Protocollo Operativo per il Monitoraggio Finanziario Linea 6 Metronapoli

    Cosenza Agreements
    Protocollo d'intesa di Cosenza

    Legality Protocols BCA Scarl Augusta
    Protocollo di Legalità BCA Scarl Augusta

    Legality Protocols BCA Scarl Catania
    Protocollo di Legalità BCA Scarl Catania


    PREVENTIVE MEASURES PURSUANT TO ITALIAN LEGISLATIVE DECREE 231/2001 To follow the ethical values from which the activities of ICM Group take inspiration, the Group Companies have adopted a procedural system that is able to guarantee the prevention of crimes in full compliance with and adherence to Italian Legislative Decree 231/2001. The Management, Organisation and Control Model adopted by the Group Companies implements all the general and specific principles established by the Group Code of Conduct turning them into their own principles in a compatible and effective manner with respect to the particular activities conducted by each of them, transforming them into a set of procedures that constitutes a strict code of conduct that all the individuals operating in the interest of the single Companies must observe.

    The ICM Group Organisational Model
    Modello organizzativo del Gruppo ICM

    Integra Organisational Model
    Modello organizzativo Integra


    ICM S.p.A. has been active since 1921 as a general construction company in both the private and public sector carrying out civil, road, hydraulic and infrastructural works in general. The technical-administrative structure, the equipment, the organizational and the productive experience allow the company to deal with tasks of any kind and size, both in Italy and abroad. ICM S.p.A. intends to act as a center of coordination and application of experiences and productive synergies of the whole ICM Group. The implementation of new industrial and environmental regulations and policies in the construction sector, the growing globalization of the market, the increasingly important presence of European competitors and the downturn recorded by the domestic market due to a negative economic situation, together with the awareness that the environment can no longer be understood as a mere passive receptive space but should rather be seen as an asset to be enhanced and protected with the work/structure to be carried out in the context in which it is included, all this requires a rapid transformation and adaptation of the companies active in the construction industry.

    Aware of the market evolution and the resulting constraints, ICM has decided to propose and implement a competitive model based on the highest quality, as well as on professionalism, sustainability, and social responsibility. It achieves this goal by maintaining, on one hand, an effective integrated management system complying with the UNI EN ISO 9001, UNI EN ISO 14001, UNI ISO 45001, UNI 39001, UNI ISO 37001, and SA 8000 standards and, on the other hand, a corporate organization system complying with the Italian Legislative Decree 231/2001 based on internationally recognized ethics and compliance principles. The goal is to ensure the ongoing quality of its services and the compliance of its activity with the provisions of the laws in force, with the RTS (Road Traffic Safety System) objectives it has set, with the ILO international conventions, and with the contracts in force, with reference to the following field of application:

    Design and construction of: civil works including protected cultural heritage, infrastructural works for mobility, hydraulic networks. Installation of Mechanical, Electrical and Plumbing systems. General contractor activities carried out pursuant to TITLE III of Legislative Decree 50/2016 coordinated with the corrective Legislative Decree 56/2017 and subsequent amendments (EA 28;35)

    ICM has always been inspired by the principles of legality, honesty, fairness, transparency, and confidentiality, as well as by the respect for human dignity and the environment in which it operates. Moreover, it pays utmost care to the protection of occupational health and safety and of human rights with reference to both its employees and those who work within the competence field of the organization, as well as to road safety issues and to the prevention of corruption, which is subject to continuous and constant attention in order to assure the identification and the compliance with the relevant requirements and to comply with the applicable legislation and regulatory provisions.

    The primary targets of ICM are oriented towards:

    • the satisfaction of its customers and the quality of the provided services and of the manufactured products;
    • the strict compliance with laws and regulations in all Countries in which the company operates;
    • the diligence and accuracy in the execution of tasks and contracts;
    • the respect for the employee labor and human rights;
    • the protection against children exploitation;
    • the compliance with the principle of equal opportunities;
    • the provision of guarantees for a safe and healthy workplace;
    • the reduction of hazards and the elimination of safety risks at the workplace;
    • the mitigation of risks when they occur, as well as the remarkable decrease of road accidents and fines incurred by the employees;
    • the promotion and protection of the environmental context in which it operates, involving also Clients, Suppliers, Subcontractors, Authorities and Stakeholders;
    • the protection of the physical and moral integrity of all collaborators;
    • the responsibility towards the community in conducting business, respecting the environment, the local and national communities, as well as the regulations in force established by the law and otherwise;
    • the promotion of the consultation and participation of the employees and their representatives;
    • the involvement of all the personnel in order to improve the "Social Performance";
    • the promotion of a systematic and consistent reduction in energy and water consumption;
    • the minimization of waste production by optimizing the recycling and recovery of the same;
    • the fairness of the Group Companies and the individuals that operate on behalf of them, taking decisions that affect the relationships with different stakeholders;
    • the prevention of conflicts of interest affecting the individuals acting for and on behalf of those Companies;
    • the confidentiality in the handling of the information managed by the Companies;
    • the transparency and completeness in the management of information by all collaborators, who are required to provide complete, transparent, understandable, and accurate information;
    • the continuous professional promotion and growth of human resources;
    • the assurance of equity in all relationships with collaborators;
    • the protection of the value of fair competition and of the principles from which this latter should draw inspiration;
    • the application and continual improvement of the Management System for the Prevention of Corruption, in accordance with UNI ISO 37001;
    • the guarantee of an adequate level of training and information to all personnel and their constant consultation for the purpose of improving the Management System for the Prevention of Corruption;
    • the guarantee of operating in compliance with the applicable legislation and regulations;
    • the correct management of any nonconformity detected during the implementation of the Integrated Management System, including those relating to the failure to comply with the Integrated Policy.

    The high behavioral standard of all parties involved in the business operations has been inspired by the belief that every activity is carried out also on behalf of the community and under the strict observance of the Universal Declaration of Human Rights. The Company tries, also through specific improvement programs, to preserve natural resources and minimize or eliminate negative environmental effects and risks associated with its production cycles and services, thus ensuring the customer a socially responsible product and service, pursuing the continual improvement of product performance within the framework of their entire life cycle. To this purpose, the Company applies the principles of sustainable procurement to make use of assets and services reflecting the recognized minimal environmental criteria or standards and to promote their search, as well as to use alternative processes to those currently in use, in order to prevent pollution, and to decrease the consumption of natural resources and the resulting production of waste; the Company is also recycling the materials used at the end of their life cycle, whenever possible.

    The training, professionalism and moral integrity of the personnel are fundamental principles for our Company. These principles are implemented by providing our personnel with the necessary knowledge, in order to allow them to always work at the highest level of professionalism, safely and in full compliance with all laws and regulations, to assure the best possible quality level for the provided product/service.

    The Company plans and implements continuous engagement, training and updating activities involving its personnel at all levels and targeting specifically the personnel involved in the processes that is more subject to the corruption risk. Moreover, the personnel is required to observe, inasmuch as activities under its responsibility is concerned, the Manual of the Management System for the Prevention of Corruption, the Policy for the Prevention of Corruption, and the documents referred to therein. In case of non-observance of the above, the personnel will be subject to the disciplinary measures foreseen by the National Collective Bargaining Agreement and the Code of Ethics and Behavior.

    In particular the Company undertakes to:

    • prohibit corruption, meant as the act of offering, promising, providing, accepting or requesting an improper advantage of any value (whether economic or non-economic), directly or indirectly, and regardless of the location, in violation of the applicable law, as an inducement or reward for a person to act or refrain from acting in connection with the service performed;
    • prohibit acts of corruption, meant as the act of offering, promising or granting any benefit of whatsoever value in order to inappropriately influence a person to obtain a service for ICM S.p.A.; or the act of requesting or accepting any benefit by way of compensation for an inappropriate action or the inducement to act inappropriately in order for ICM S.p.A. to be granted an order. The instruments of corruption include money, gifts, acts of hospitality, expenses, mutual favors, financing of political parties or contributions to charitable organizations, as well as any other direct or indirect benefit or consideration;
    • ensure the review of the Corporate Policy (at least annually) taking into account legislative changes and any other company requirements;
    • ensure the verification of the adequacy of the Integrated Management System and the improvements to be made to the structure (at least annually);
    • encourage the reporting of suspected cases of corruption in good faith, or on the basis of a reasonable and confidential belief, ensuring that no disciplinary/sanctioning measures or retaliations of any kind are taken;
    • ensure the verification of the compliance with legislative requirements.

    To this end, the Company gives full mandate to the Team entrusted with the Prevention of Corruption, so that it may pursue the objectives contained in this policy, by virtue of the authority and independence granted to it in order to:

    1) oversee the design and implementation of the Management System for the Prevention of Corruption;

    2) provide guidance and advice to staff on matters related to corruption and the Management System for the Prevention of Corruption;

    3) ensure that the Management System for the Prevention of Corruption complies with the UNI ISO 37001 standard;

    4) report on the performance of the Management System for the Prevention of Corruption to the Governing Body and the Top Management in the most appropriate manner.

    Everyone, in both the operational and support areas, is responsible for achieving adequate levels of corruption prevention; therefore, the Management System for the Prevention of Corruption has to become an integral part of the corporate management and this policy shall be disseminated to all personnel, anyone working on behalf of ICM S.p.A., and anyone who requests it, so as to make employees/collaborators aware and to inform all stakeholders of our commitment to minimizing the risk of corruption.

    The Company makes every effort to ensure that this corporate policy is effectively implemented, and reviewed periodically, through the verification activities foreseen by the Integrated Quality, Environment, Safety, Road Safety, Prevention of Corruption and Social Responsibility System, as well as by the Organization, Management and Control Model, in order to pursue the continual improvement.

    Thanks to this policy, ICM S.p.A. is in a position to offer a highly qualified and competitive activity and to play a leading role in the execution of important projects in the construction industry.

    The Integrated System Manager                                         The Managing Director

    Mr. Andrea Fabbri                                                                   Mr. Darik Gastaldello        






    The employee, collaborator or supplier willing to make a report or a complaint regarding the SA8000 aspects can download and fill in the form in the part: "subject of the report".  To remain anonymous, the space "reserved to the interested party" must be left blank. Once the form has been completed and sent as instructed, ICM SpA will decide on any necessary actions within one month. In case of anonymous reports, the actions taken will be published on the company's bulletin board.

  • UNI ISO 37001 CLAIMS

    Any employee, collaborator, supplier, partner or business associate who wishes to make a report in relation to anti-corruption matters or who is faced with a person or a situation which could include acts of corruption may report and/or request assistance from the Team Responsible of the Anti Bribery System by 
    - sending a letter to the address Viale dell'Industria n. 42 36100 - Vicenza - To the attention of the RSPC
    - sending an email to the address: This email address is being protected from spambots. You need JavaScript enabled to view it.
    This email address may also be used for requests for clarification or further information on the subject. 

    Team Responsible of the Anti Bribery System

Copyright © 2018. All Rights Reserved Gruppo ICM SPA - 36100 - VICENZA Viale dell'Industria 42 Tel. 0444/336111 Fax 0444/961541 P.IVA - 02526350240 - Privacy e Policy
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