- MAPPING YOUR COMPANY RISKS
Before implementing your compliance programme, you need to identify which business area may have competition risks, the likelihood of certain violations and the impacts of that competition breach may have on your company.
- GETTING THE COMPANY TRUST FOR DEVELOPING A COMPETITION PROGRAMME AS AN ESSENTIAL PART OF THE COMPANY CULTURE
In order to develop the competition culture within your company, you may decide to leverage on the huge risks the antitrust breaches may cause or to train your colleagues and top management on the positive values of a fair competition. It doesn’t matter which method matches better with your company, but to achieve the goal you are required to get involved in the business, to fully understand their needs and show them there are concrete ways for playing legally into the market. Getting the business’s trust is the first step of your compliance programme.
- LEGAL AWARENESS TAILORED ON THE COMPANY BUSINESS AND INDUSTRY
Academic lessons on what the law provides are boring and not interesting for your colleagues. Make your legal awareness programme captivating. Organise training where you simulate a real case that could happen within your company and highlight the pros and cons of that situation and how to manage it practically. Share authentic cases of your industry as lessons learned, demonstrate what you are telling them is real and not just theory.
- COMPANY COMMITMENT AND POLICY. PARTNERS CODE OF CONDUCT
Having got the trust and commitment of the top management, publish a policy to be applicable to all the company’s employees where you describe dos and don’ts of a fair competition policy. Highlight the disciplinary measures of that policy’s violation and set up an anonymous whistle-blowing channel available for everybody. Engage the partners of your company in respecting the competition law by requiring them to sign your company code of conduct.
- AUDIT
Constantly monitor the risky area you have identified during your antitrust assessment. Perform unexpected audits and in case of needed improvements, share with the business the relevant corrective measures in order to keep an up to date compliance programme.
Make your competition compliance programme possible!
Giuseppina Divono, Head of Legal, Huawei Device Italy B.D.
Giuseppina is an Italian qualified lawyer with more than 10 years of experience, highly specialized in problem solving and focused on compliance, data protection, commercial & consumers law, advertising and media law, intellectual property, antitrust law, negotiation and business strategy.
Giuseppina started her career as associate lawyer in two international law firms, then she realized to have a more business oriented attitude and she joined important multinational companies such as Cisco Systems and Sony Electronics. In January 2015 she moved to Huawei as legal counsel initially supporting the three core business of the company (carrier, enterprise and consumer) and then focusing on the consumer unit only. Recently, due to the huge increase of that department, she has been appointed as Head of Legal of Italy Huawei Device Business. Reporting to the General Manager of Italy Huawei Device Business and to the Western Europe Device Legal Director, she is responsible for all the legal issues related to terminal business, supporting in identifying the legal risks, suggesting the proper corrective measures in compliance with the law and in line with the company needs.