Organization and Management Model
The Model defines the rules of behaviour and identifies the controls to be adopted in order to prevent the offences governed by Italian Decree 231 of 2001 from being committed.
We have adopted an Organizational and Management Model that sets out rules of conduct and the monitoring that must be adopted to prevent the risk of committing the crimes provided for by Legislative Decree no. 231/2001 and to exclude or limit the consequent administrative liability of the Entity.
In addition, we have appointed a Surveillance Body to oversee the functioning and effective implementation of the Model. In particular, the Model, approved by the Board of Directors, consists of a General Section and a Special Provisions Section.
The General Section explains the rationale and principles of Legislative Decree no. 231/2001, the governance model, the internal monitoring and risk management system and outlines the components of the Model, including the role of the Surveillance Body.
The Special Provisions Sections refer to the families of crimes envisaged by the Decree and considered relevant with respect to the sensitive activities performed by the Company. The Sections also link each process with the general principles of conduct to which the Model Addressees must adhere, and the specific monitoring measures (internal rules) identified to prevent the commission of the crimes identified.
The method used to prepare the Model takes into account the most significant case law, the best practices for applying the Decree, and the category guidelines.
Fausto Salvador (Chairperson - External Member)
Any communications and reports concerning acts, facts and conduct that may constitute or result in a violation of laws, national regulations or company procedures and rules, with a potential negative impact on the values and principles set out in the Organisation, Management and Control Model pursuant to Legislative Decree 231/2001, must be sent to the Surveillance Body using the following channels:
- dedicated e-mail address: Odv231@jeniot.com
- postal address: Via Machiavelli 3, 34132 Trieste (TS), Italy, for the attention of the Surveillance Body.