Governance policies

Related parties

The aim of the present regulations is to highlight rules of behaviour for all interested parties, so that they may communicate to the Company their relevant position in carrying out operations with Reply S.p.A.; and, for Reply S.p.A., to set operational rules for the fulfilment of said operations.

The stipulations are currently only available in Italian.

Ethic Code

An integral part of the Organization Model 231 is the Code of Ethics, which has been updated according to the provisions of the same Decree and has the purpose of defining the fundamental ethical principles and rules of behaviour that must be respected, thus creating the appropriate conditions that will guarantee that Reply's activity will be inspired by the principles of fairness and transparency, and reducing the risk that the crimes listed in the Decree might be committed.

The Code of Ethics is currently available in Italian and English.

Organization Model 231

The coming into force of the Legislative Decree 8 June 2001 Nr.231 introduced into the Italian legal system a new set of rules on "Administrative liability, ascertained in the criminal law proceedings", chargeable to legal persons for some crimes committed by administrators, managers, employees or external collaborators in the interest or to the advantage of the company (among others, corporate crimes and crimes against Public Administration).

Model 231 is a specific Italian stipulation. Thus this set of rules is currently only available in Italian.

Whistleblowing Policy

Reply issued the whistleblowing policy to provide its shareholders, employees, collaborators, customers, and generally to its stakeholders with a channel to report any action taken by anyone that constitutes or may constitute a violation of laws and/or regulations, principles enshrined in the Reply Code Of Ethics, company policies, rules and procedures that can give rise to economic, financial or reputational damage for Reply Group companies.

Modern Slavery Statement

The Modern Slavery Act 2015 is an Act of the Parliament of the United Kingdom. It is designed to tackle modern slavery as a crime and a violation of fundamental human rights taking various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain.

The Reply Ltd Group is committed to preventing slavery and human trafficking in its corporate activities and supply chains.

Shareholder Agreements

Essential information of shareholder's agreement disclosed to Consob pursuant to art. 122 of d.lgs. No. 58, 24.2.1998.

Procedure for privileged information, insider register and internal dealing

Internal Dealing documents 2024

Policy for managing dialogue with shareholders