ORGANISATIONAL, MANAGEMENT AND CONTROL MODEL UNDER LEGISLATIVE DECREE 231/01

THE GENERAL PRINCIPLES

Legislative Decree no. 231 of 8 June 2001 introduced into the Italian legal system a provision concerning the administrative liability of Legal Entities - including limited companies – for certain crimes committed by directors, executives or employees in the interest or to the benefit of the Entity.

 

THE ADOPTION OF THE ORGANISATIONAL MODEL

Corneliani S.p.A. has adopted an Organisational Model, in order to establish a structured and organic system of guiding principles, operating procedures, and other specific tools, based on sound business management criteria, and aimed, among other things, at preventing the commission of the crimes contemplated by the Decree.

 

Therefore, it is a priority of our Company to ensure all the parties who – in any capacity - work for and with Corneliani S.p.A., carry out their activity in compliance with the principles and values contained in the Model, as an essential tool to drive, promote and spread proper and consistent behaviour, which contributes to the good functioning, reliability and reputation of Corneliani S.p.A.

 

THE CODE OF ETHICS

The company has also adopted a Code of Ethics which defines the main values guiding the action of Corneliani.

All the Corneliani people, along with all those who work for its objectives, are required to comply with the principles of the Code of Ethics.

 

THE SUPERVISORY BODY

Corneliani has entrusted a Supervisory Body (made up of two members not belonging to the Company – Martina Caron, as Chairman, and Enrica Perusia, as a member – as well as of an internal member, Pierpaola Gambarota, General Counsel) with the task of monitoring compliance with the provisions of the Organisational Model, checking for actual effectiveness thereof, and assessing the need for any revisions.

 

The Supervisory Body has also been entrusted with the task of receiving the reports referred to in art. 6 paragraph 2 bis of Legislative Decree 231/01 on whistleblowing.

 

Contact addresses:

 

  • odv@corneliani.it (channel to report breaches strictly linked to the Organisational and Management Model 231, breaches or suspected breaches that can be interpreted as one of the crimes contemplated in Legislative Decree 231/01, including but not limited to the following cases: the Company bribes an advisor to obtain a certification for which it does not meet the relevant requirements/the Company bribes the personnel of a competitor Company in order to acquire confidential information on a new product).

 

  • whistleblowing@corneliani.it (channel to report breaches or suspected unlawful conduct not in line with the values and policies of the Company and with regulatory provisions, including but not limited to: conflicts of interests; illegal and/or fraudulent activities to the detriment of customers or of the company assets in general; breaches regarding the protection of workers, etc..). 

 

MOG 231_General part

 

Code of Ethics