Italian Legislative Decree 231/2001 and Supervisory Committee
Pursuant to the Italian Legislative Decree no. 231 on the administrative liability of
companies, General Noli S.p.A has implemented an Organisation, Management and
Control Model which ensures accuracy and transparency when conducting business
and aims to prevent crimes committed in the interest of or to the advantage of the
company.
According to Italian Legislative Decree no. 231 of 8 June 2001, companies and all
organisations in general may be called to respond in criminal proceedings, and
therefore incur sanctions, to any crimes committed in their interest or benefit by the
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directors, employees and other parties who operate in the name or on behalf of the
organisation or company. In particular, the Decree considers crimes in relationships
with the Public Administration, corporate crimes, crimes linked to safety in the
workplace and the environment, organised crime, terrorism, cyber crime, crimes
against industry and commerce, crimes against individuals etc. To minimise the risk of
these crimes being committed, each company is obligated to implement an
“Organisation and Management Model”, that is, a set of regulations and procedures,
including the adoption of a Code of Ethics and set of Anti-Corruption Guidelines, the
establishment of a Supervisory Board and implementation of a control and sanctions
system. The adoption and effective implementation of the Model and the appointment
of the Supervisory Board allow the organisation to benefit from the hold harmless
clause in the event of crimes.
The General Noli “Model 231” is a dynamic and shared document. It is dynamic
because it is sensitive to all regulatory and organisational changes. It is shared because
its creation involves all of the company population, both in the phase prior to drafting,
via the risk assessment, and in the implementation phase, through training and
information.
Supervisory Board of General Noli S.P.A
The Supervisory Board of the Company (hereafter referred to as SB) is a collective
body, provided with powers of initiative and control, whose members, selected by the
Board of Directors, must possess the traits of autonomy, independence,
professionalism, continuity of service and integrity. The SB is tasked with duties of
supervising compliance with the provisions of the Model, the effectiveness of the
Model and the opportunity to update it, in addition to operative duties linked to the
application of the Model.
The Board of the Company General Noli S.p.A. is composed of three members, who are
all external:
- Chairman: Dr. Michele Gucci
- Member: Rag. Roberto Tofani
- Member: Dr. Luca Porciani
Monitoring and updating the Model
All areas at risk of crimes being committed pursuant to Italian Legislative Decree 231
and the rules of conduct in the Model are the product of an analysis of corporate
documentation and meetings with personnel, in order to adapt the Model to the
characteristics of the Company.
The General Noli Model undergoes continuous assessment to evaluate its efficiency
and guarantee it is updated according to internal changes (in the organisational
structure, in business activities…) and external changes (legislative changes, best
practices…).
Training and information
The training of personnel is an essential element for the efficient implementation of
the Model. Therefore, a training plan has been devised which includes both classroom
sessions and e-learning modules with diversified content based on the addressees and
which uses concrete examples. For the purposes of evaluating the quality of teaching,
upon completion of the courses, tests will be distributed on the subjects of the lesson.
Reporting Violation of the Organisational and Management Model
Reports of violation of Model 231 can be sent electronically to:
organismodivigilanza@pec.generalnoli.it or via post through the internal channel
activated by the Company and indicated in the “Whistleblowing Procedure”.
