Model 231

In 2014 the Board of Directors of Finarvedi resolved to adopt its own Organisational, Management and Control Model pursuant to Legislative Decree no. 231 of 2001 (hereinafter “Model 231”) in order to prevent offences as defined by the afore-mentioned Decree from being committed.

Model 231 is constantly updated with any new legislation issued in relation to the responsibilities of legal entities as per Legislative Decree no. 231 of 2001. On 12th September 2019 the Board of Directors of Finarvedi approved the latest update of Model 231.

An integral part of Model 231 is the Code of Ethics which clearly and transparently defines the values which inspire us and has been drawn up to set clear rules of professional behaviour. In particular, the Code of Ethics offers each of us a reference framework of behaviour and ethics able to direct our conduct in response to the demanding and sometimes difficult choices which at times we have to make.

At the same time as Model 231 was adopted, a Supervisory Board was appointed, with the power to act and control independently, the aim of which is to supervise the functioning and respect of Model 231 and promote its constant updating.

The Chairman and sole member of the Supervisory Board is Mr Andrea Pedroni.

The Code of Ethics and the short version of Model 231, distributed throughout our organisation, are available in PDF format.

It is important that whoever interacts in any way with our Company views this material to make the principles of Model 231 and the Code of Ethics real and concrete.

Each one of us may and is invited to report behaviour that is not in line with the principles of Model 231 and the Code of Ethics through the Supervisory Board ([email protected])), not anonymously, with the full protection of confidentiality.