Organisational and Management Model (OMM)

In the context of a structured and organic system for prevention, deterrence and control, each Group company has adopted an Organisation and Management Model, respecting the guidelines of the Parent Company.

Pursuant to Legislative Decree 231/2001, the Organisational and Management Model (OMM) is a structured and organic system of prevention, dissuasion and control, aimed at:

  • developing awareness, among the individuals who directly or indirectly operate in the context of sensistive activities, (directors, managers, employees and others working with the Company) of the potential for an offence to be committed, and
  • protecting the Company against Corporate Administrative Liability.

As part of its corporate reorganisation process and of the broader range of initiatives aimed at strengthening aspects of its idenitty, values and corporate governance, the Unipol Gruppo S.p.A. decided to launch a project aimed at setting up a new Organisational and Management Model.

A new model

This Model, which was approved by the Board of Directors of 22 December 2016, consists of a 'General Section' and individual 'Special Sections' drawn up for the various categories of offences identified in the Decree.

The 'General Section' contains an introduction dediated to explaining the structure of the Decree and its applicability to the insruance and banking sectors, as well as the general rules and principles of the Model.

The 'Special Sections' provide and explanation of the rules for the various categories of offences, giving examples of the relevant conducts, sensistive activities within the Group's companies and the monitoring and control tools adopted by the Company.  

The task of supervising the functioning and observance of the MOG (i.e. Organisational, Management and Control Model) and its updating has been entrusted to a Supervisory Board (SB) formed by three members of the Control and Risks Committee, non-executive independent directors, and an additional two members representing top management as heads of the compliance and auditing departments.