In implementation of the Legislative Decree no. 231/2001, the Company has adopted an Organization, Management and Control Model (“Model 231”) aimed at preventing and mitigating the risk of committing crimes-assumption from which a liability may derive from the Company, divided into:
- Code of Ethics: represents the inwit charter of values and the corpus of principles to which the behavior of INWIT people is informed. The Code of Ethics is therefore a tool through which the Company directs its business activities for a conduct of business based on ethics and compliance, health and safety, human resources, community, communication, competition and service excellence.
- General Part: containing a brief description of the Company, the contents and purposes of Model 231 and the methodology used for its implementation, the functions of the Supervisory Body and the whistleblowing system adopted. In the general part, the initiatives for the dissemination and knowledge of Model 231 and the disciplinary system are also recalled.
- Special Parts: each special party identifies a risky process in which sensitive activities and related predicate offences are identified. In addition, control standards are reported, divided into general principles of behavior and specific control principles.
Model 231 is a dynamic tool, which affects company operations and which, in turn, must be constantly verified and updated in the light of the application findings and the evolution of the reference regulatory framework. INWIT’s Model 231 was last updated by resolution of the Board of Directors of 14 June 2022 in order to incorporate the organisational and regulatory changes that have taken place in the medium term.
In implementation of art. 6 of Decree n. 231/01, the Company has also entrusted the task of supervising the functioning and compliance with Model 231 and of updating it to a special Supervisory Body which, in its current composition, sees the presence of an external component with the functions of Chairman, two members of the Board of Statutory Auditors and an internal member, identified in the head of the Audit function of the Company.
The transmission, receipt and management of reports of potential violations of Model 231 are governed by the Whistleblowing Procedure adopted by the Company, available on this website – governance section.