• STAR SARDINIA Srl manages all of his business acting honestly and ethically.
  • STAR SARDINIA Srl takes a zero-tolerance approach to Bribery and Corruption and is committed to act daily with professionality, fairness and integrity in all of its business relationships.
  • STAR SARDINIA Srl requires all staff at all times to act honestly and with integrity and to protect the resources for which they are responsible. Bribery is a threat to these resources and for this reason have to be a concern to all members of the staff.
  • STAR SARDINIA Srl don’t allow any form of corruption within the company and takes the most serious view of any attempt to commit corrupt practices by members of staff, eventual third parties involved and business partners. Cases of suspected corruption will be properly investigated and appropriate action taken, including reporting to the appropriate authorities, disciplinary action, prosecution and active pursuit of recovery.
  • In STAR SARDINIA Srl all the employees are actively encouraged to report cases of suspected corruption to the management that will take properly actions through the competent authorities.

This Policy is addressed to all STAR SARDINIA Srl staff and applies to all members of third parties involved and business partners, and shall be applied in compliance with legal requirements and regulations in force.

In STAR SARDINIA Srl is not acceptable:

  1. to offer, give or promise to give, a payment or gift with the expectation or hope of a business advantage, or to repay a business advantage already given;
  2. to offer, give or promise to give, a payment or gift to a Public Official or Third Party to facilitate or speed up a routine procedure;
  3. to accept payment from a Third Party that in return want to obtain a business advantage from STAR SARDINIA Srl;
  4. to threaten or retaliate against a STAR SARDINIA Srl employee who has refused to commit a bribery offence or who has raised concerns under this policy;
  5. to engage in any behavior that could lead to a breach of this policy.
    Reporting of any form of suspected activities are the responsibility of all Employees that have to notify it to the management as soon as possible.

All STAR SARDINIA Srl staff members have the responsibility to read, understand and comply with above policy. Any employee who will breach this policy will incur in a disciplinary action.

In STAR SARDINIA Srl is forbidden accepting a gift or giving a gift to a third party when it is made with the intention of influencing someone to obtain or retain business, to gain a business advantage, or to reward the provision or retention of business or in explicit or implicit exchange for favors or benefits. Moreover, it is forbidden if it is an inappropriate kind of gift with an inappropriate value and it is given secretly.
STAR SARDINIA Srl staff members who refuse to take part in bribery or corruption attempts, or report in good faith their suspicion about it, will be protected from eventual retaliations like dismissal, disciplinary actions, threats or other kind of unfavourable treatments.
  • STAR SARDINIA Srl will establish regular monitoring activities that have to be conducted by a staff member in accordance with the Management and will be subjected to regular audits to provide assurance that they are effective. Additional controls must be performed on a regular basis on the application of this policy.
  • STAR SARDINIA Srl management will monitor the effectiveness and review the implementation of this policy, regularly considering its suitability, adequacy and real effectiveness. Any eventual improvements identified have to be made at first opportunity.


  • STAR SARDINIA Srl management has overall responsibility for ensuring this policy complies with our legal obligations and business values, and has primary and day-to-day responsibility for implementing this policy by monitoring its real effectiveness.

Bribery: This term means a financial or other specific reward for action which is illegal, unethical, a breach of trust or improper in any way. Bribes usually can take the form of money, gifts, loans, fees, hospitality, services, discounts, the award of a contract or any other advantage or benefit that includes offering, promising, giving, accepting or seeking a bribe.
Corruption: This term means the misuse of power used for personal or private advance, of the person who corrupts or a Third Party they are associated with.  Bribery is one of the tipical form of corruption.
Conflict of Interest: This term means a situation in which a person or organization is involved in multiple interests, and serving one interest could involve working against the other.
Facilitation Payments: A form of Bribery in which small payments are made with the purpose of expediting or facilitating the performance of a Public Official, a routine governmental action or to obtain or retain business or any other undue advantage.
Gifts: This term means everything of value (money, services, loans or other benefits) that is not a business hospitality given to somebody without payment for it.
Intermediaries: The intermediaries are individuals, organizations or companies that carry out activities of introducing or developing new business by retaining existing business, obtaining licenses or permits for new business or any other regulatory necessary documents.
Kickback: This term means an amount of money that is paid to someone illegally in exchange for secret help for a business advantage.
Public Official: This term is typically used for a natural or legal person who is employed, appointed or elected to perform a public function.
Third Party: Is a joint venture/consortium partner, agent, advisor, contractor, politicians and political parties, supplier and vendor, intermediary, service providers and other third party, performing similar tasks or functions that come in contact with STAR SARDINIA Srl during the course of our work.