Transparency and Business Management Systems

Co.De.Bri. is one of the most important and well-established s ocial and vocational training services enterprises in the Lom bardy region. The high degree of transparency and accountability towards stakeholder s that characterizes Co.De.Bri. is the result of substantial investments in the programming, management, monitoring, and evaluation systems, whi ch are all integrated in a structural and time management perspective.

Co.De.Bri. (Table 1) has today transformed into an 'Azienda Speciale Consortile' (Special Consortium Enterprise) (Art. 114, Legislative Decree 267/00) providing services to mainly the residents of the six member municipalities, which include guidance, vocational training, integration of people with disabilities in the workplace, personal, social, residential and healthcare, and management services.
The training activities, homecare services as well as the management, administrative and staff offices are based at the headquarters, while seven regional offices house the day centres, the social health community, the integrated day centre for the elderly, and a neutral space for children.  Co.De.Bri. is still seen as an organization of people -most have been with the enterprise for many years -who have always proven reliable and trustworthy, with a high sense of belonging and responsibility towards the organization. These key factors have furthermore been 'certified' in numerous surveys on organizational welfare and in employee-satisfaction questionnaires annually administered since the beginning of 2000.
In addition, prior to the regulations on transparency and corruption prevention, the enterprise's strength has always rested on being perceived as an 'ethically oriented' organization, an environment permeated by the 'observance of the rules' with the central value of 'good administration'.
In other words, a system of values constructed and established over the years in the organization's culture that decisively distinguishes Co.De.Bri's operations. From the management perspective, all this is reflected in the search for ever-more effective management tools. A final important element concerns the organisation's soundness from a financial point of view and the results achieved: in the last decade, in correspondence with the increase in services managed, Co.De.Bri's turnover has more than doubled from just over four million euro in 2004 to ten million in 2014, an increase of 140%. The equilibrium achieved is perhaps the best indicator of the organization's credibility in the territory and its ability to achieve the objectives while containing operating costs to the maximum extent possible.

The Path towards Transparency
In the various and successive anti-corruption and transparency plans (Piano Triennale per la Prevenzione della Corruzione e della Trasparenza -P.T.P.C.T.) from 2014 to today, continuously invoked as central to Co.De.Bri is the link with the enterprise's organizational performance cycle. Specifically, guaranteeing a systematic link between the above-mentioned plans and the business plan, the main business planning instrument, both strategic and operational. Such link is guaranteed by: -The P.T.P.C.T. objectives, which are formulated in accordance with the guidelines contained in the enterprise's planning tools. -Periodic monitoring of the state of implementation of the P.T.P.C.T.
objectives that occurs with the same periodicity and means foreseen for the other objectives reported in the enterprise's programming tools. System and business management tools have long existed in Co.De.Bri. as well as formal regulations designed to provide standards of conduct and indications on the way to carry out the managerial, administrative, and operational tasks. Table 2 and Figure 1 illustrate the general value instruments (business management systems) and the way the interaction between the management systems is safeguarded by integrated control systems, in line with the objectives and characteristics of the management and control systems applied in Co.De.Bri. In addition to these systems, a particular element supporting the planning and programming framework and consequently the management is the set of information systems, fundamental in relation to both the content of the operational activities and financial and accounting type elements.

Quality Management System and Business Processes
The Desio-Brianza Consortium is certified since 2003 in compliance with CISQ/CERTYQUALITY n. 6269, Certificato IQNET, Settore EA 37, EA 38 i .
The Quality Management System (QMS) has undoubtedly been the point of departure for the management systems, also configured as a form of control of the different management activities and involving all employees in a common, written, shared and applied project that enables optimising the work by improving the activities. The services have specific training/education/welfare objectives, while customers participate in personalized projects and are involved in monitoring and evaluating the pathway and the results also thanks to data made available by the QMS. A key element of the QMS is the business processes map (Table 3). These processes developed within the enterprise are formalized in procedures in the quality manual including: -Identifying, within each process, the person who has direct responsibility or a decision function, the person who follows and concludes the process as well as the person controlling the process. -Description and written evidence of each relevant step of the process.
-Adequate level of formalization. This system permeates the entire control system and constitutes an effective corruption prevention tool in the same way as performance, access to information, and privacy. The QMS enables compliance with the mapped procedural regulations to guarantee legality, both in terms of corporate responsibility (Legislative Decree 231/2001), anti-corruption (Legislative Decree 190/2012), and transparency (Legislative Decree 33/13).

The Measurement and Performance Evaluation System
2014 saw a major review of the Co.De.Bri. performance measurement and evaluation system. The system was designed in a stakeholder-oriented and trifocal approach (organizational performance on the level of the enterprise, the single organizational unit, and the individual) and entailed a review of: -The organisational chart in line with the enterprise's development in recent years and a more coherent redistribution of organizational responsibilities. -The indicators (standards and target performance) that have almost entirely replaced the QMS objectives. -The program plan, orienting it rather than on the services provided to the various internal and external stakeholders, and the aims and objectives related thereto. The organizational reconfiguration, intended as a whole, was essential to achieve the rationalization and cost reduction objectives. In particular, a flexible organisation whose professional skills are valued and recognized by objectives, providing the basis to support the increasing level of competition between service management entities that are part of education and vocational training, work and territorial welfare systems.
In the context of the reorganization, the program plan -an instrument envisaged by the legislation itself alongside the budget -has become the essential instrument enabling: -Representing the enterprises expected organizational performance.
-Planning and programming, as well as the prerequisite for proper strategic control and management. The performance measurement and evaluation system has also identified an implementation timeframe (by 30 September), during which intermediate monitoring is carried out on the degree of achievement of the goals and objectives, and defining corrective actions. The indicator framework, built with standards and performance targets, has provided a total of around 100 indicators on all services.
These indicators, in verifying the results and final evaluation each year, are audited in relation to their significance and, consequently, modified, eliminated, or confirmed.

The Organizational, Management, and Control Model
In 2010, Co.De.Bri adopted the model pursuant to Legislative Decree 231/2001, implementing the regional guidelines for the definition of the organizational, management, and control models as an essential aspect for accreditation of education, training, and employment services.
The purpose of the 231 organizational model is to ensure compliance with the regulations specifically concerning the administrative liability of legal persons (Legislative Decree 231/2001) and limiting the risks. This organizational model has been subject to substantial updating in order to: -Make it fully compatible with the anti-corruption provisions subsequently issued with Legislative Decree 190/12 and with the national anti-corruption plan -Simplify the framework without losing effectiveness, seeking greater integration with other enterprise management systems. In essence, with the same systems integration logic, the 231 model has been transformed into a tool that maps the organization of Co.De.Bri. without defining another organizational model that is detached from the business reality. With reference to this second aspect, model 231 aims to: -Describe the organizational structure, the regulations, instruments, and procedures adopted. -Focus on the types of violations that are truly relevant to the Co.De.Bri context and reality. -Enhance existing management and control systems and intervening only if and when deficiencies are detected. In this sense, the definition of specific prevention and control systems within the special parts of the 231 model presents a systematic link between the violations foreseen by Legislative Decree 231/01 according to the risk area disciplined by each special part, and the processes mapped into the enterprise quality management system. This ensures full compliance and effective implementation of the general principles that should characterize the system of violation prevention and control.
The code of ethics and behaviour and the P.T.P.C.T. are an integral and coordinated part of the 231 model.

The Triennial Corruption Prevention and Transparency Plans
On 28 November 2012, Legislative Decree 190/2012, titled 'Provisions for the prevention and repression of corruption and illegality in public administrations' came into force aimed at strengthening the effectiveness and efficacy of measures to counteract the corruption phenomenon by also introducing an organic anticorruption system on two levels: the 'national' and the 'decentralized'.
Co Decree 190/2012. The enterprise then further integrated its own anti-corruption system through drafting the transparency plan foreseen by Legislative Decree 33/13.

Transparency Management
Introducing a transparency safeguarding system in a functional way required activating an internal engagement path across the entire organization. A facilitating factor in this sense was the aforementioned review of the performance measurement and evaluation system, which coincided with the beginning of the transparency compliance obligations. In fact, when the introduction of new requirements to ensure greater corporate transparency came into force, the mission and corporate values, the construction of the stakeholder maps and indicators in a stakeholder-oriented approach were in the process of being redrafted.
To motivate staff and disseminate the knowledge of the aims and content of the new transparent system to the greatest extent, the management focused on: -Strong stakeholder involvement in drafting the first triennial transparency and integrity plan, the triennial corruption prevention plan, and the subsequent integration of these documents. -Training all enterprise employees and collaborators. -A permanent internal coordination group for transparency and anti-corruption, which together with the Director General and the Administrative Director, constitute the engine of safeguarding transparency. This group, in its minimal composition, saw all central functions involved in the management of information flows aimed at managing the 'Transparent Administration' website.
In the motivation task, especially in the training initiatives, the enterprise's founding concept as 'ethically oriented' has been accentuated. Above all, in the presence of norms that aim to make public activities transparent and prevent maladministration, the concept of social and ethical responsibility is fundamental, particularly in an organization that has as its main mission the provision of a 'common good' and 'social value' through services for people in prevailing conditions of fragility.
The investment that has thus been largely internal will in the future see the greater engagement of external stakeholders that to date have only been substantially involved through the publication of data and information on the 'Transparent