Page 80 - Ratti Group - Sustainability report

CH. 6 | GOVERNANCE AND PROCEDURES
Organisational Model 231
The regulations require the adoption of an organisational model, commonly known as Or- ganisational Model 231, which aims to prevent the company from being administratively liable for particular o ences that could be committed by senior management or by persons managed or supervised by senior management, when carrying out their duties in the inter- ests of or to the advantage of the Company.
From 2006, the Ratti Group has therefore adopted an organisational, management and con- trol Model which complies with Italian Legislative Decree 231/2001 (MOG231/01) and has appointed a Supervisory Body.
Organisational Model 231
SUPERVISION, UPDATING, INFORMATION AND TRAINING
DISCIPLINARY MEASURES AND PENALTIES
INTEGRATION OF MANAGEMENT SYSTEMS
DOCUMENT AND PREVENTION SYSTEM
EFFORTS TO PREVENT OFFENCES
ORGANISATIONAL CHOICES TO ENSURE LEGALITY
GUIDANCE AND SUGGESTIONS FOR BEHAVIOUR
ORGANISATIONAL MODEL
231
REGULATIONS, RULES AND PROCEDURES
78
The current Model 231 was approved by the Board of Directors on 7 October 2014.
The Model identifies the processes and business areas at risk of crime and the organisational control and monitoring mechanisms that prevent o ences from being committed.
It consists of nine parts: a general introductory part and special parts which describe the de- tails of the o ence, recipients, general principles regarding behaviour in the areas of activity at risk, as well as sensitive activities, control protocols, and the duties of the Supervisory Body. Finally, there is the Code of Ethics and the list and description of o ences stipulated in Italian Legislative Decree 231/2001, which is an integral part of the Model.
The Code of Ethics responds to the need to clearly define the ethical principles which under- pin the Ratti Group and is the reference document that regulates relations with a range of stakeholders including employees, customers and suppliers.
All recipients must be familiar with the document and must comply with its contents. MOG 231/01 may be consulted by accessing the Procedures area of the Company’s intranet and is also published (only the general part) on the page www.ratti.it/it/societa/investitori/tipolo- gia/procedure-e-codici/2014. A project to update MOG 231/01 was launched in 2018.