Organisational Model ex Legislative Decree 231/01 (Ita)
The corporate decision to adopt an Organisation, Management and Control Model in compliance with the requirements of Legislative Decree 231/01 (Ita), constitutes an act of social responsibility of G&A towards its stakeholders, to guarantee conditions of correctness and transparency in the management of corporate activities.
The company management has adopted this Model together with the Code of Ethics and the Disciplinary Code. It has been also integrated with the procedures of the ISO 9001 Quality Management System. This is the program to ensure effective prevention and detection of violations of laws, as well as the set of corporate governance tools aimed at allowing healthy and consistent management of the company with the objectives set.
G&A is also determined to ensure that the above corporate governance standards adopted are constantly adequate to prevent the commission of corporate offences. To this end, G&A continuously verifies the effectiveness of the Model adopted with respect to its own organisational and business reality as well as any amendments to Legislative Decree 231/01, and any criticalities that have emerged in the application of the Model itself.
In particular, in the context of the periodic updating activities carried out on the Model, G&A considers not only the inclusion of new types of offences connected with the evolution of the reference legislation. It also considers the occurred corporate events and any signs of risk identified and relevant for the application of the above legislation.
Precise internal rules are used to organise the system of powers and delegations, to regulate and prepare the protocols of the activities of G&A, to regulate the various information flows between the various functions and bodies.
The adoption of the Model also ensures that G&A personnel, employees, external collaborators and partners are informed of the severe administrative sanctions applicable to G&A in the event of the commission of crimes. Through the continuous control of all areas of activity at risk and the training of personnel in the correct execution of their tasks, G&A makes it possible to ensure the prevention of offences, including criminal offences, within the sphere of its activities.
Purpose of the Model
With the adoption of this Model, G&A proposes to formalise principles and rules of conduct, directed internally and at the subjects with whom it operates. These are based on transparency, correctness and legality, on the distinction of roles and functions and on the clear assignment of tasks and responsibilities, with the following purposes:
- promote a business culture based on the principles of legality and respect for social utility, safety, freedom and human dignity;
- to promote awareness of Legislative Decree 231/01 and the rules referred to therein and to inform the recipients of the Model that, in the event of violation of the provisions contained therein, they may incur penalties, including for G&A;
- identify the activities carried out by the individual company functions which, due to their particular type, may entail a risk of offence as per Legislative Decree 231/01;
- analyse potential risks with regard to the possible methods of committing offences in relation to the internal and external operating context in which the Company operates;
- define a system of rules that sets out the general (Code of Ethics) and specific (organisational procedures) lines of conduct aimed at regulating company activities in ” critical ” sectors;
- establish a system of authorization and signature powers to ensure punctuality and transparency.
Representation of the decision-making process and implementation of decisions
- prepare a structured and comprehensive system of monitoring, prevention and control, aimed at reducing the risk of commission of offences connected with company activities, with particular regard to those for which Legislative Decree 231/01 applies;
- affirm the principle of non-tolerance of unlawful conduct, even if it is to the advantage or in the interest of G&A;
- inform all those who operate for any reason in the name, on behalf or in the interest of G&A that the violation of the provisions contained in the Model will result in the application of appropriate sanctions including the termination of the contractual relationship.