ALBINI&PITIGLIANI S.p.A, in compliance with the provisions set down in Italian Legislative Decree No. 231 of June 8, 2001, on the ‘Discipline of the administrative responsibility of legal persons,’ by resolution of the Board of Directors on September 14, 2023, has adopted an Organization, Management and Control Model pursuant to Legislative Decree No. 231/2001.
The 231 Company Management Model, composed of a General Part and a Special Part, identifies the operating procedures that the company ALBINI&PITIGLIANI S.p.A. adopts to reduce the risk that apical and subordinate persons commit offences to the benefit of the company. The 231 Model of ALBINI&PITIGLIANI S.p.A. is a document the preparation of which has examined each company department, allowing a preliminary analysis of ‘sensitive’ activities, considered to be at a potential risk pursuant to Italian Legislative Decree 231 /2001, establishing the general principles of conduct, the elements of prevention and the essential control measures dedicated to the prevention or mitigation of offenses. ALBINI&PITIGLIANI S.p.A.'s Model 231 is a dynamic document that is updated to any regulatory and organizational changes in order to ensure its adequacy and suitability.
The Code of Ethics of ALBINI&PITIGLIANI S.p.A. is an integral part of the Model 231 and defines the set of values and principles underlying the activities of ALBINI&PITIGLIANI S.p.A. and the ALPI Group, establishing the rules of conduct for relations with Collaborators, Customers, Suppliers and Partners.
The adoption of the 231 Model is a necessary prerequisite to allow ALBINI&PITIGLIANI S.p.A. to be exempt from administrative liability in the event of the commission by its directors and employees, as well as by individuals acting in the name and on behalf of ALBINI&PITIGLIANI S.p.A. itself, of the types of offences provided for in Legislative Decree No. 231/2001.
The Board of Directors of ALBINI&PITIGLIANI S.p.A. has also appointed a Supervisory Board (OdV – Organismo di Vigilanza), endowed with autonomy of action and specific powers, with the task of verifying compliance with the regulations of Model 231, taking care of its updating, and reporting to the Board of Directors all possible situations of non-compliance with the provisions of said Model 231.
Reporting procedure - Whistleblowing
Whistleblowing represents an additional and essential element of the security system of ALBINI&PITIGLIANI S.p.A. and enters within the field of the internal control tools adopted to fight corruption, ensure fairness and transparency in the conducting of business and the activities carried out, protecting the Company’s position and reputation.
The company body responsible for handling reports is the Supervisory Board (OdV – Organismo di Vigilanza). Reports are handled transparently through a predefined process. The entire process ensures that whistleblowers are protected from pressure and discrimination, whether direct or indirect, by those entrusted with the verification of the reports. The identity of the whistleblower is never disclosed without his/her consent, except in cases where the verifications conducted as a result of the report fall within the scope of criminal, administrative or tax investigations, or give rise to disciplinary proceedings based solely on the complaint received, for which knowledge of the identity of the reporter is absolutely essential for the defence of the person being accused.
Personal data acquired within the reports are processed in full compliance with current privacy regulations, with particular regard to the identity of the reporter. The Data Controller is ALBINI&PITIGLIANI S.p.A.
Any communications to the Supervisory Board (OdV – Organismo di Vigilanza), may be sent via the following channels: