Legislative Decree No. 231/2001 and Code of Ethics
In 2004, the Company launched the so-called "231 Project" aimed at drawing up its organisation model within the meaning of Legislative Decree No. 231/2001 on the vicarious liability of entities for criminal offences committed by high-level company executives or persons placed under their managerial control or supervision. The activities undertaken since then consisted in the drafting of the following documents illustrating the system of procedures and checks implemented with a view to reducing the risk of the commission of the offences falling within the scope of the aforesaid Legislative Decree: the Group's Code of Ethics, the Principles and Guidelines of the Organisational, Management and Control Model and the Organisational Model.
The Organisational Model is accordingly divided into specific and distinct sections, each featuring: (i) an indication and description of the specific Article of Legislative Decree No. 231 it refers to; (ii) an illustration of general implementing principles and related rules of conduct, and where necessary, specific procedures to be followed in the areas at risk identified during assessment, as well as related support areas; (iii) specific appendices setting forth the statutory definitions of the offences to which the section refers.
The Board of Directors has resolved to appoint the following members of the
aforementioned Supervisory Body: Marco Rigotti (Adjunct Professor of Commercial Law at Bocconi
University) as Chairman, Chiara Burberi (Company’s Independent Director) and Michaela Castelli
(Secretary of the Company’s Board of Directors) and has set their mandate to last until the date on
which the Shareholders’ Meeting is called to approve the 2014 Financial Statements.