Adoption of the Organizational Model 231 and Whistleblowing System
On [●], the Company’s Board of Directors approved the Organization, Management and Control Model pursuant to Legislative Decree 231/2001.
The Model has been adopted with the aim of strengthening the Company’s governance system and preventing the risk of the offences provided for by the applicable regulation.
The full document is available at the following link:
[Insert link to Model 231]
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Reports to the Supervisory Body (OdV)
In compliance with the provisions of Legislative Decree 231/2001 and Legislative Decree 24/2023, the Company has enhanced and implemented a whistleblowing system that allows the reporting, in a confidential and protected manner, of any unlawful conduct or behaviour not in line with the principles of the Model.
Reports can be submitted through the following channel:
[Insert WB platform/link]
In accordance with Legislative Decree 24/2023, reporting persons may also use the external reporting channel made available by the Italian National Anti-Corruption Authority (ANAC), accessible at the following link:
[Insert ANAC link]
The use of the external channel is permitted in the following cases:
1. the reporting person has already submitted an internal report and it has not been followed up;
2. the reporting person has reasonable grounds to believe that, if an internal report were submitted, it would not be effectively followed up or that it may give rise to a risk of retaliation;
3. the reporting person has reasonable grounds to believe that the violation may constitute an imminent or obvious danger to the public interest.
