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 Organisation, Management and Control Model (OMM) is a structured and harmonised prevention, dissuasion and control system aimed at:
- informing people who, either directly or indirectly, work in sensitive areas (directors, managers, employees and collaborators) that they may be liable to committing an offence;
- preventing or limiting the Company’s administrative liability.
The Model, which was last updated by the Board of Directors on 28 September 2023, consists of a “General Part” and individual “Special Parts” regarding the various categories of offences regulated by the Decree.
The "General Part" contains an introduction on the Decree and its applicability to the Company, as well as the rules and general principles of the Model.
The "Special Parts" illustrate the rules relating to the various categories of offenses, exemplifying unlawful conduct, the sensitive processes carried out at the Company and the control mechanisms adopted by the same.
The task of supervising the operation and compliance with the Organisation, Management and Control Model and ensuring its updating has been entrusted to a Supervisory Body (SB), made up of five members identified as follows:
- all the members of the Control and Risks Committee, who are independent and non-executive directors;
- one or two additional third-party member(s) with adequate professional skills and expertise, or a senior manager of the Company in charge of the Audit Department or the Compliance and Anti-Money Laundering Department.