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model 231

model 231

By resolution of its Board of Directors, on 15 December 2016, Officina dell’Ambiente S.p.A (“Officina dell’Ambiente” or the “Company”) adopted its Organisational, Management and Control Model (the “Model”) under Italian Legislative Decree No. 231 of 8 June 2001 (“Italian Legislative Decree No. 231/2001”) for crimes against the Public Administration and environmental crimes.
The Model was developed consistently with the guidelines prepared by the Confederation of Italian Industry or Confindustria, together with the concerned trade associations.
The adoption of the Model, as well as a response to the requirements set out in the above Decree, is an act of social responsibility effected by the Company, creating benefits for a variety of parties: members, managers, employees, creditors and all other entities whose interests are linked to the life of the company.
Officina dell’Ambiente implements the Model in its organizational context, based on its own characteristics and in consideration of the activities conducted by it in risk areas.
The Model consists of a “General Part” and a “Special Part” and comprises – among other things –a Code of Conduct and an organised set of procedures, together with the related control activities.
The Model includes a structured body of principles, procedures and provisions which:

  • affect the internal operation of the Company and the way in which it interacts with the external environment;
  • regulate the diligent management of a system for the control of sensitive activities, seeking to prevent the perpetration or attempted perpetration of crimes that are of relevance for the purposes of the administrative liability of entities.

The rules adopted by Officina dell’Ambiente and the principles by which the actions of all those who act in its interest must abide are described, among other things, in the Code of Conduct.
The implementation of the Model is constantly monitored by Officina dell’Ambiente’s Supervisory Body, which is responsible for verifying its correct operation, including by determining breaches, and ensuring it is effectively applied and continuously updated, including in consequence of any modifications to Italian Legislative Decree No. 231/2001. Breaches and/or suspected breaches of the Model and/or information regarding the implementation of the Model are to be reported to the Supervisory Body.
Reports may be sent:

  • in paper format, in a sealed envelope, to Officina dell’Ambiente’s registered address, for the attention of the Supervisory Body;
  • in paper format, to the Supervisory Body’s professional practice address, as recorded in the current roll of attorneys;
  • by e-mail to organismodivigilanza@matrixoda.it.