Organization model 231

As of February 28, 2020, Vianova has adopted the Organization, Management, and Control Model pursuant to Legislative Decree no. 231 of June 8, 2001. The update to the Model on July 30, 2021, incorporated the organizational and regulatory changes that occurred after its adoption.

The Model consists of:

• the General Part, which includes the description of the regulations contained in Legislative Decree no. 231/2001, the indication – in the relevant parts for the purposes of the Decree – of the legislation specifically applicable to the Company, the description of the offenses relevant to the Company, the indication of those to whom the Model is addressed, the operating principles of the Supervisory Body, the establishment of a penalty system dedicated to monitoring violations of the Model, and the indication of the Model’s reporting and staff training obligations
• the Special Part, which consists of Control Protocols relating to each at-risk process, and which is intended to prevent relevant offenses as part of these so-called ‘at-risk’ activities – i.e. activities that have been deemed by the Company to involve a risk of offenses in light of the risk analyses carried out
• the Control & Risk Self-Assessment, aimed at identifying at-risk activities
• the Code of Conduct, which contains the general principles and rules of conduct which the Company recognizes as having positive ethical value and with which all those covered by the Code must comply: the Board of Directors, employees, Partners, and all those who operate on behalf of the Company, either directly or indirectly. The Code complies with the provisions of Legislative Decree no. 231/01, in accordance with the ‘Guidelines for the construction of Organization, Management, and Control Models’, developed by Confindustria, issued on March 7, 2002 and updated in June 2021.
• the Disciplinary System, designed to sanction violations of the principles, rules, and measures set out by the Model, in compliance with the applicable CCNL (National Collective Labor Contract) as well as with the applicable laws or regulations
• the Statute of the Supervisory Body
• the Catalog of administrative offenses and predicate offenses for which corporations are liable.