231 Policy

The company has strengthened its corporate organisation through the adoption of the Organisational and Management Model provided for by Article 6 of Italian Legislative Decree 231/2001. This was done with the specific aim of ensuring the highest standards of safety, fairness and transparency within its organisation, in the performance of its activities, and in its relations with employees, suppliers and business partners.

The company has also adopted the best practices in the field of business ethics and sustainability, including through the adoption of its Corporate Code of Ethics. This instrument establishes that all business activities must be carried out in compliance with the law, within a framework of fair competition, with honesty, integrity, fairness and good faith, while respecting the legitimate interests of clients, employees, shareholders, business and financial partners, and the communities in which the company operates.

The task of supervising the proper functioning of the Organisational and Management Model and the Code of Ethics has been entrusted to a single-member Supervisory Body, represented by Lawyer Michele Bonsegna, to whom any communication may be sent at odv231@studiolegalebonsegna.com regarding:

• requests for clarification or interpretation of the contents of the Organisational and Management Model and the Code of Ethics;
• suggestions concerning the application of the Organisational and Management Model and the Code of Ethics;
• reports of violations of the Organisational and Management Model and the Code of Ethics, whether directly or indirectly identified.

With a view to ensuring maximum transparency and verifying compliance with the principle of legality by senior management, employees and third parties who work with or for the company, anyone who has or intends to establish relations with the company is required to read and comply with the contents of the Organisational and Management Model and the Code of Ethics set out below.