Model 231
According to the Italian regulation of the “liability of entities for unlawful administrative acts stemming from a crime” set forth in Legislative Decree no. 231 of 8 June 2001 (hereinafter, “Legislative Decree no. 231 of 2001”), associations - including corporations - may be held responsible, and consequently subject to pecuniary and/or prohibitory sanctions, in relation to said crimes committed or attempted - in Italy or abroad - in the interest of or for the benefit of the companies themselves.
Securitisation Services, aware of the need to guarantee and promote conditions of correctness and transparency in the performance of company activities, saw fit to implement the Organisation, Management and Control Model in the company pursuant to Legislative Decree no. 231 of 2001 which was approved by the Board of Directors on 21 December 2011 and periodically updated; at the same time, the Supervisory Body was appointed, equipped with autonomous initiative and control powers, which was assigned the task of monitoring the functioning of and compliance with the Model, and handling its updating.
In order to ensure effective and efficient governance of the company and its informed management, as well as formalisation of the procedures able to guarantee the proper management of company events, it is necessary, first and foremost, to ensure an environment characterised by ethical integrity and a high degree of sensitivity to control, as such to permit the achievement of objectives in the context of the utmost integrity and transparency.
Ethical integrity makes a significant contribution to the effectiveness of the policies and control systems and influences conduct which could elude the most sophisticated control systems. It was deemed necessary to circulate the values which constitute the cornerstone of the proper conduct, in order to encourage the sharing of these values between all subjects in the company organisation.
Based on this premise, the Company adopted its Code of Ethics, which is signed as proof of acceptance by all company employees and encapsulates the essence of company conduct, through a collection of values and rules whose compliance and observance represent fundamental elements of company activities. The Code of Ethics represents a crucial component of the model adopted by Securitisation Services.
Summary of Model 231