Organisation Model 231

Organisation Model 231

According to Italian regulations on "administrative liability of legal entities deriving from offences" contained in the Legislative Decree of 8 June 2001 no. 231 (hereinafter "Legislative Decree no. 231 of 2001"), legal associated entities - including joint-stock companies - may be held responsible, and consequently subject to financial penalties and/or prohibition, for certain offences, committed or attempted - in Italy or abroad - in the interest or to the advantage of the company concerned.

Finint Revalue, sensitive to the need to guarantee and promote fairness and transparency in the conduct of business activities, has deemed it appropriate to implement the Model of Organisation and Management pursuant to Legislative Decree no. 231/01 within the Company, which was approved by the Board of Directors on November 20, 2015 and subsequently updated to incorporate the legislative changes regarding the matter; simultaneously a Supervisory Body was appointed, which holds independent powers of initiative and control and has the task of supervising the functioning and observance of the Model and its updating.

In this respect, in line with the changes introduced by law no. 179/17 regarding whistleblowing, in order to sensitize all recipients of the Model to virtuous and clear conduct and to guarantee an effective and efficient governance of the Company, strengthening its internal organization and managing systems, the Company has made channels of communication available, suitable for guaranteeing receipt of information or news concerning the commission of criminal acts relevant for the purposes of Legislative Decree no. 231/01 and / or practices potentially not in line with the Model (or with the Code of Ethics).

Ethical integrity contributes significantly to the effectiveness of policies and systems of control and affects conduct which might escape from the same control systems, insofar as these are sophisticated. It was considered necessary to spread the values set at the base of correct conduct, in order to stimulate sharing these by all company stakeholders.

Starting from this premise, the Company has adopted a Code of Ethics, which is signed for acceptance by all Company employees and summarises the essence of Company conduct, through a set of values and rules, the respect and observance of which represent the fundamentals of company business. The Code of Ethics is a fundamental component of the Model adopted by Finint Revalue.

The commission or attempted commission of the violations envisaged by Legislative Decree No. 231/2001, or the violation or fraudulent evasion of the rules of the 231 Organizational Model and/or of the rules of the Ethical Code adopted by the Company, can be reported to the following email address: odv231finintrevalue@finint.com.

Supervisory Board – D.LGS 231/2001

Werther Montanari
Monica Manzini
Corrado Arnosti