In implementation of the Legislative Decree no. 231/2001, INWIT has adopted an Organization, Management and Control Model (“Model 231”) aimed at preventing offences from being committed in the interest of or to the advantage of the Company with consequent liabilities for the latter, divided into:
- General Part: containing a brief description of the Company, the contents and aims of Model 231 and the methodology used for its implementation, the functions of the SB and the whistleblowing system adopted. The General Part also refers to the initiatives for the dissemination and awareness of Model 231 and the disciplinary system.
- Special Part: describing in detail, with reference to the specific Sensitive Processes and the types of offence associated with them, the map of Sensitive Activities, as well as the system of controls put in place to monitor and protect these activities.
- Code of Ethics: representing INWIT’s charter of values and the body of principles on which the conduct of INWIT’s people is based. The Code of Ethics is, therefore, a tool by means of which INWIT directs its business activities towards the performance of business based on principles of ethics and integrity.
The Model 231 is a dynamic instrument, which affects the corporate operation, which in turn must be constantly checked and updated in the light of its application, as well as the evolution of the regulatory framework. INWIT’s Model 231 was most recently updated by resolution of the Board of Directors on 7 March 2024 in order to incorporate the changed organisational structure and the regulatory changes occurring in the meantime.
In implementation of art. 6 of Legislative Decree 231/01, the Company has also entrusted the task of supervising the functioning and compliance with Model 231 and of keeping it updated to a special Supervisory Body (hereinafter the “SB”), which, in its current composition, sees the presence of two external components, of which one with the function of Chairperson, and an internal member, identified in INWIT’s Internal Audit Director.
The transmission, receipt and management of reports of potential violations of Model 231 are governed by the Whistleblowing Policy adopted by the Company, available on this website – governance section.