The Organization, Management and Control Model in accordance with the Italian Legislative Decree n. 231/2001 consists of a range of rules, protocols, tools, and behaviours functional to providing the Company (and the Group Companies) with an effective and adequate organizational, management and control system suitable for identifying and preventing risks of committing relevant crimes pursuant to Legislative Decree 231/2001 by persons of the entity or functionally related to the entity in the interest or for the benefit of the Company. The adoption and effective implementation of Model 231 is the essential condition of exemption from administrative liability of the entity pursuant to Legislative Decree 231/2001. Adopted by the Company since 2003, the Model has been progressively updated as a result of the organizational and regulatory changes that have affected the Company over the years, with a perspective oriented to a continuous improvement.
Italcertifer S.p.A. has defined and adopted - on a voluntary basis - its own Anti Bribery & Corruption management system (ABC system) model for the prevention of corruption in a "broad" sense.
The scope of this model is preventing and contrasting acts and behaviors which constitute cases of deviation from internal rules and procedures and which may jeopardize the good performance and general interest of the Company (cases of mala gestio - "bad management" - and malfunction) even if they do not integrate a specific type of crime.
The ABC system is part of the Internal Control and Risk Management System (Sistema di Controllo Interno e di Gestione dei Rischi - SCIGR) of Italcertifer S.p.A. and, along with the Organization, Management and Control Model, is a central element of the Company's Single Anti-Corruption Framework, as the sole self-regulatory tool for the prevention of corruption.
In compliance with the provisions in force, Italcertifer S.p.A. has established a process for the management of whistleblowing reports, also in anonymous form, able to contribute to the prevention and contrast of illegal behaviours or conducts contrary to the rules, the Code of Ethics of the State Railways Group, the "Organization, Management and Control Model" pursuant to the Italian Legislative Decree no. 231/2001 and the Anti Bribery & Corruption Management System of Italcertifer S.p.A.
This process guarantees the protection of the whistleblower, ensuring the confidentiality of his identity, the facts reported and the identity of the persons reported.
Whistleblowing reports can be addressed to the Ethics Committee (Comitato Etico) and/or the Supervisory Body (Organismo di Vigilanza - OdV) of Italcertifer S.p.A. through the following channels:
Reports can also be made personally to the Ethics Committee and/or to the Supervisory Body of Italcertifer S.p.A. by a declaration issued by the whistleblower at a specific deposition stated in an official document and undersigned.