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Anti-Bribery and Anti-Corruption Policy

Barrel S.r.l

Galleria delle Porte Contarine, 4

35137 Padova (PD)

REA PD-478495

Email: info@barrel.solar

Website: https://www.barrel.solar


Date: 10 Dicembre 2022

Reviewed: 21 Settembre 2024


1. Purpose and Scope

At Barrel S.r.l, we are committed to maintaining the highest standards of integrity, transparency, and accountability in all aspects of our business. This Anti-Bribery and Anti-Corruption Policy aims to establish clear guidelines for our employees, agents, suppliers, and partners to prevent bribery and corruption in any form. It reflects our zero-tolerance approach toward any corrupt practices, ensuring compliance with applicable anti-bribery and anti-corruption laws, including the Italian Anti-Corruption Law, UK Bribery Act 2010, and the U.S. Foreign Corrupt Practices Act (FCPA).

This policy applies to all employees, officers, directors, contractors, agents, consultants, and any other third parties acting on behalf of Barrel S.r.l, regardless of location.

2. Definition of Bribery

Bribery refers to the offering, giving, receiving, or soliciting of any item of value to influence the actions of an official or other person in a position of authority. Bribery includes the following acts:

• Offering or receiving any undue financial or other advantage, whether directly or indirectly, to obtain or retain business or secure any improper advantage.

• Providing gifts, hospitality, or other benefits with the intention of influencing decision-making or gaining improper advantages.

• Making facilitation payments—small, unofficial payments made to expedite or secure a routine administrative action.

3. Prohibited Practices

Barrel S.r.l prohibits all forms of bribery and corruption, whether involving government officials or individuals in the private sector. Specifically, the following practices are strictly forbidden:

Bribes: Offering, giving, or receiving any bribe in any form, including cash, gifts, hospitality, or other benefits.

Facilitation Payments: Making or offering small unofficial payments to speed up administrative actions.

Kickbacks: Receiving or soliciting a percentage of contract value as a reward for awarding contracts.

Gifts and Hospitality: Offering or accepting gifts or hospitality that could influence, or appear to influence, the recipient’s impartiality.

4. Gifts and Hospitality

While Barrel S.r.l recognizes that in some cultures, gifts and hospitality are a common part of business relationships, we have strict guidelines in place:

Acceptable Gifts: Only small, symbolic gifts or items of modest value (e.g., company-branded promotional items) are acceptable. Any gift valued over €50 must be reported to management.

Acceptable Hospitality: Reasonable business-related hospitality (e.g., meals, networking events) is permitted if it is appropriate and within local laws and customs. Lavish or excessive hospitality that could be perceived as a bribe is prohibited.

All gifts and hospitality must be declared and approved by the management team to ensure transparency.

5. Facilitation Payments

Facilitation payments are unofficial, small payments made to secure or expedite a routine governmental action, such as processing permits or issuing licenses. Barrel S.r.l strictly prohibits the offering, making, or receiving of such payments, even if they are legal in certain jurisdictions. Any employee or third party pressured to make a facilitation payment must report the incident immediately to management.

6. Political and Charitable Contributions

Barrel S.r.l does not make political donations or charitable contributions as a way of gaining an improper advantage. All contributions must be fully compliant with local laws, properly documented, and approved by the management team to ensure that they are not made to secure favorable treatment or business advantages.

7. Responsibilities of Employees and Third Parties

All employees, contractors, agents, and third-party suppliers working on behalf of Barrel S.r.l are required to:

Comply with this Policy: Understand and adhere to all aspects of the Anti-Bribery Policy.

Report Violations: Promptly report any suspected bribery, corruption, or violation of this policy to the Compliance Officer or senior management.

Refuse Bribes: Decline any bribes offered and report the incident immediately.

Training: Participate in anti-bribery and corruption training provided by the company.

8. Due Diligence and Third-Party Relationships

Prior to engaging third parties (e.g., agents, consultants, suppliers), Barrel S.r.l will conduct thorough due diligence to ensure that they have no history of bribery or corrupt practices. We require all third parties to agree to comply with our Anti-Bribery Policy as a condition of doing business with Barrel S.r.l.

9. Reporting and Whistleblowing

Any employee or third party who suspects a violation of this policy is encouraged to report the matter to the Compliance Officer or anonymously via the company’s whistleblowing system. Barrel S.r.l ensures that all reports are treated confidentially and investigated thoroughly. We guarantee that no employee will face retaliation for reporting genuine concerns in good faith.

10. Consequences of Non-Compliance

Violations of this Anti-Bribery Policy are treated with the utmost seriousness. Employees or third parties found to be involved in bribery or corruption will face disciplinary action, which may include dismissal or termination of contracts. Additionally, Barrel S.r.l will cooperate with law enforcement authorities to prosecute any violations to the fullest extent of the law.

11. Training and Awareness

All employees of Barrel S.r.l will receive regular training on anti-bribery and anti-corruption practices to ensure compliance with this policy. Training will be updated to reflect any changes in laws or regulations.

12. Policy Review

This policy is subject to regular review to ensure its effectiveness and compliance with relevant laws and regulations. Any necessary updates or amendments will be approved by the Board of Directors.


Approved by: Barrel S.r.l Board of Directors

Date: 10 Dicembre 2022

Reviewed: 21 Settembre 2024