Our commitment against corruption

CAP Holding is the first integrated water service company to obtain UNI ISO 37001 certification relating to its Anti-corruption management system.

The certification of CAP Holding's anti-corruption management system was issued upon the conclusion of an independent verification process carried out by RINA, an accredited certification body, confirming CAP Group’s commitment and determination in the development of an effective anti-corruption policy.

Corruption prevention and transparency plan

On 31 January 2023, the Company's administrative body approved the “Three-Year Corruption Prevention and Transparency Plan for the Years 2023 – 2025”, pursuant to Italian Law no. 190/2012 and Italian Legislative Decree 33/2013.

The Board of Directors of CAP Holding appointed Gian Luca Oldani, Internal Auditing Manager, as Corruption Prevention Manager with powers, pursuant to art. 43 of Italian Legislative Decree 33/2013, also as Transparency Manager, until 31 December 2020.

Regulatory provisions

At the meeting of 30 January 2018, the Board of Directors of CAP Holding appointed the Internal Audit Manager, Gian Luca Oldani as the Manager responsible for monitoring compliance with the rules on non-transferability and incompatibility pursuant to Italian Legislative Decree 39/2013.


Article 54-bis of Legislative Decree No 165 of 30 March 2001, introduced by Law No 190/2012 and amended by Law No 179/2017, introduces the "Provisions for the protection of whistleblowers who have become aware of crimes or irregularities in the context of a public or private employment relationship".

In order to implement these regulatory provisions and in continuity with the measures already adopted, Gruppo CAP has joined the WhistleblowingPA project promoted by Transparency International Italy and Whistleblowing Solutions, providing a new channel of communication. Specifically, Gruppo CAP has equipped itself with an IT platform that also allows third parties to report incidents of corruption, non-compliance or irregularities within the organization so that the company can intervene in a timely manner.

The objective is to involve all stakeholders in an activity of law enforcement, through an active and responsible participation to allow to intercept in time, to intervene and correct illegitimate behaviour and irregular actions that constitute damage to society and/or third parties. Each reporting is handled confidentially and the identity of the whistleblower is not disclosed without his or her consent. The personal data that may be present are processed in compliance with the current Privacy legislation (D. Lgs. 196/03 and EU Regulation 2016/679) and stored for the period of time strictly necessary for the management of the report.

The following are the main points of the new reporting mode:

- the report is made by completing a questionnaire and can be sent anonymously. If anonymous, it will be taken over only if properly substantiated;

- the report is received by the RPCT and managed by him while maintaining the duty of confidentiality towards the reporting agent;

- at the time the report is sent, the reporting agent receives a 16-digit numeric code, which he must keep in order to be able to access the alert again, verify the RPCT’s reply and enter into dialogue in response to requests for clarification or further information;

- the signal can be made from any digital device (pc, tablet, smartphone) both from inside the Company and from outside. The protection of anonymity is guaranteed in all circumstances.




We are as transparent as our water: that's why we are always available for any need.