Organizational and Management Model

We have adopted an Organizational and Management Model that sets out rules of conduct and the monitoring that must be adopted to prevent the risk of committing the crimes provided for by Legislative Decree no. 231/2001 and to exclude or limit the consequent administrative liability of the Entity.

In addition, we have appointed a Surveillance Body to oversee the functioning and effective implementation of the Model.

In particular, the Model, approved by the Board of Directors, consists of a General Section and a Special Provisions Section.

The General Section explains the rationale and principles of Legislative Decree no. 231/2001, the governance model, the internal monitoring and risk management system and outlines the components of the Model, including the role of the Surveillance Body.

The Special Provisions Sections refer to the families of crimes envisaged by the Decree and considered relevant with respect to the sensitive activities performed by the Company. The Sections also link each process with the general principles of conduct to which the Model Addressees must adhere, and the specific control measures (internal rules) identified to prevent the commission of the crimes identified.

The method used to prepare the Model takes into account the most significant case law, the best practices for applying the Decree, and the category guidelines.