Page 81 - Sustainability report 2018 Ratti Group

Cmposition Supervisory Body at 31 December 2018:
Sergio Meacci
Antonella Alfonsi Vittorio Stefano Zuccotti
Organisational Model 231
Chairman Member Member
2018 SUSTAINABILITY REPORT | RATTI GROUP
Supervisory Body
Checking the need to update the Model
Self-regulation
Use of external consultants
Supervising observance of the Model
Access to corporate documents
SUPERVISORY BODY
POWERS
FUNCTIONS
Checking that the Model is valid and adequate
Information obtained in a timely manner
Communicating with the responsible bodies
Coordinating and verifying activities to disseminate the model within the company
Supervisory body
Ratti SpA has also established a Supervisory Body, in accordance with the provisions of Legislative Decree 231/2001.
The activities of the Supervisory Body are based on criteria of autonomy and independence, as well as on professionalism and continuity of action.
With regard to the Organisational Model implemented by the legal entity, the Supervisory Body is responsible for constantly monitoring:
• its observance by all recipients;
• its actual effectiveness in preventing offences
from being committed;
• the implementation of its requirements;
• its amendment, should it become necessary
to update the model due to changes to the Company’s structure and organisation or to the legislative framework.
The Body reports on the implementation of the Model by highlighting critical points, using two reporting lines:
• the first, on an ongoing basis, directly
to the Board of Directors and the Risks Control Committee;
• the second, on a six-monthly basis, in the form of a written report to the Board of Directors and the Board of Statutory Auditors.
The Supervisory Body is obliged to promptly inform the Board of Directors, the Board of Statutory Auditors and the Risks Control Committee, with regard to provisions within their remit, of any transgressions, infractions and non-compliant behaviour that have been observed and to suggest revisions, amendments and additions that could prevent the above.
In this regard the Supervisory Body has informed the competent bodies that in 2018 an INAIL
verification procedure was concluded, as a result of which Ratti SpA was able to – working with INAIL itself – define the company’s insurance positions more accurately.
The procedure revealed a number of discrepancies that had occurred entirely in good faith – the allocation of INAIL insurance positions – which resulted in a fine of €104,000 for the entire period subject to verification (the 2011-2017 financial years). Since November 2018 the Supervisory Body has also managed the reporting flow from the new whistleblowing procedure.
The Model consists of twelve parts:
a general introductory part and eleven special parts which describe the details of the offence, recipients, general principles regarding behaviour in the areas of activity at risk, as well
as sensitive activities, control protocols and, finally, the duties of the Supervisory Body.
Since 2006, Ratti SpA has had an organisational, management and control Model which complies with Legislative Decree 231/2001 (MOG231/01) and has appointed a Supervisory Body.
During 2018 The Parent group Ratti SpA carried out a project to update the Model, which was approved by the Board of Directors on 14 November 2018.
The Model has been brought into line with the
new offences added by the legislator in the catalogue that is required due to the administrative responsibilities of bodies in accordance with Legislative Decree 231/2001, as well as with organisational changes, procedural updates and jurisprudential developments.
The Model consists of twelve parts: a general introductory part and eleven special parts which describe the details of the offence, recipients, general principles regarding behaviour in the areas of activity at risk, as well as sensitive activities, control protocols
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