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 No. 231/2001, the Organization, Management and Control Model is a structured and well-ordered prevention, dissuasion and control system designed to:
- raise the awareness of people who may commit offenses when directly or indirectly operating in the context of sensitive activities (directors, executives, employees and collaborators);
- eliminate or limit the Company’s administrative liability.
The Model, most recently updated by the Board of Directors on 17 December 2020, is structured into a “General Section” and individual “Special Sections” prepared for the various categories of offense contemplated in the Decree. The “General Section” contains an introduction to the Decree and its applicability to the Company’s operational scope, as well as the general Model rules and principles. The “Special Sections” illustrate the rules relating to the various categories of offense, a description of conducts, sensitive activities inside the Company and control tools adopted by it.
The task of supervising the operation of, and compliance with, the Model and ensuring its updating has been entrusted to a Supervisory Body (SB) comprising three members of the Control and Risks Committee, all of whom independent non-executive directors, and two additional members, i.e. the Head of the Audit Department and the Head of the Compliance and Anti-Money-Laundering Department.