With reference to Legislative Decree 231/2001, the Company has adopted an “Organisational Model 231” with the aim of preventing the committing of offences that could result in administrative liability for the Company if carried out in its interests/to its benefit.
The new Organizational Model 231 was adopted on March 4, 2021 by the company’s Board of Directors.
The amendments are intended to transpose the new legislation introduced by Legislative Decree no. 75 of 14 July 2020 implementing the PIF Directive (EU Directive of 5 July 2017). In particular, the amendments concern the updating: of the section on tax offences (unfaithful declaration, omitted declaration, undue compensation); the new control scheme relating to the tax process with regard to new tax offences and the crime of smuggling; the catalogue of crimes presupposed through the identification of new examples of conduct resulting in the qualification of new elements of control; the catalogue of crimes presupposed and the section “Other crimes”.
The Organisational Model 231 is broken down into:
- the Code of Ethics and Conduct, which indicates the general principles (transparency, correctness, loyalty) that drive the Company in the performance and conduct of its business
- the “general principles of internal control” as a reference for achieving the operating efficiency and effectiveness objectives, reliable financial and managerial reporting, respect for the laws and regulations, and the safeguarding of company assets even against possible fraud
- “standards of conduct” which consist of specific rules for relations with third parties, as well as for corporate activities and obligations
- “internal control schemes,” which describe the company processes involving offence risks, the predicate offences associated with them, the control elements and behavioural indications to prevent unlawful conduct.
The internal control schemes are prepared in compliance with the following internal control principles: (i) the separation of roles in the performance of the main activities pertaining to company processes; (ii) the traceability of choices to identify points of responsibility and the reason for these same choices; (iii) the objectification of decision-making processes so that, while decisions are being made, assessment is not merely subjective, reference being made instead to pre-established criteria.
Organisational Model 231 is a dynamic tool which affects company operations and which in turn must be constantly checked and updated in light of feedback on application and the evolution of the reference regulatory framework.
The Organisational Model 231 is an integral part of the reference compliance programme for the application of anti-corruption regulations.
The Organisational Model 231 is completed with the presence of the Supervisory Body whose task is to monitor its operation, compliance with the Model and to oversee the relative update.
The Supervisory Body reports to the Board of Directors on the checks completed and their outcome.
The Company’s Legal & Corporate Affairs Department provides the Supervisory Body with operational support.
Any reports of violations of the Organisational Model 231 can be sent for the attention of the Supervisory Body to the address
- Infrastrutture Wireless Italiane S.p.A., Via Gaetano Negri 1, 20123 – Milan
- or sent to https://inwit.segnalazioni.net/
The transmission, reception and management of reports is regulated by the Whistleblowing Procedure adopted by the Company, available on the website (in the Governance section).