231 model implementation

Italian Legislative Decree No. 231 of 8 June 2001 regulates Corporate Liability; pursuant to this Decree, companies may be held liable, and therefore punished, for some offences perpetrated or attempted by directors or employees in the interest or to the advantage of their respective companies. Corporate liability shall not apply if the Company has adopted and effectively implemented, before any offences are perpetrated, organisation, management and control models that are fit to prevent such offences and has set up a body, “Organismo di Vigilanza” responsible for supervising proper operation of and compliance with the models.

Our Company has adopted a 231 Model aimed at preventing any offences perpetrated in its interest or to its advantage and has set up an “Organismo di Vigilanza”, the body provided for by Legislative Decree 231 and vested with independent decision-making and control powers as regards offence prevention, in compliance with the aforementioned legislation.

The members of the Organismo di Vigilanza are external to the Company in order to ensure transparency and third party impartiality, as well as specific skills, so that the Organismo can effectively perform its duties.

The Organismo di Vigilanza shall be the Supervisor of the Code of Ethics and shall be responsible for promoting the Code implementation, circulation and knowledge. Furthermore, the Supervisor shall be responsible for examining any reported alleged breaches of the Code of Ethics and for carrying out all appropriate verifications.