Model 231 & Code of Ethics
With the regulations dictated by Legislative Decree 231/01, the Italian legal system has provided that a company can To be held criminally responsible for the commission by its members of certain crimes expressly provided for in Legislative Decree 231/01; an indispensable condition for liability to arise is the commission of the crime in the interest or for the benefit of the company.
In order to exclude such liability for companies, Legislative Decree 231/01 requires in particular the adoption of an adequate and efficient organization and management model (so-called Model 231) functional for the prevention of relevant offenses; this Model 231 not only exempts the company from liability for crime, but also improves the management of the internal control system and fosters the consolidation of a corporate culture based on the values of transparency, ethics, fairness and respect for rules, to the benefit of the corporate image and the trust placed in it by all its stakeholders.
C.R.M. S.p.A. has therefore adopted its own “Model 231“ and simultaneously appointed, again pursuant to Legislative Decree. 231/01, a Supervisory Board responsible for monitoring the operation of and compliance with the Model itself, as well as its updating.
Through Model 231 C.R.M. S.p.A. ultimately intends to affirm and disseminate a corporate culture marked by:
- to legality, transparency, ethics, fairness and respect for rules, reiterating that, consistent with the strict principles adopted by it, no unlawful behavior can be considered permissible, even if it is committed in the interest or to the benefit of the company;
- to the control of every stage of the decision-making and operational processes of the business activity, in full awareness of the risks arising from the possible commission of crimes.
These aims are embodied in a coherent system of organizational, managerial and control that represent the primary content of Model 231 prepared and adopted by C.R.M. S.p.A.
The main objectives of Model 231 are therefore:
- Improve effectiveness and transparency in the management of business activities;
- raise awareness among those who collaborate, in various capacities, with C.R.M. S.p.A. (employees, collaborators, consultants, contractors, etc.), about the risks of verifiable wrongdoing in the performance of company activities, requiring them, for activities carried out in the interest of C.R.M. S.p.A., to adopt behaviors that are correct and transparent behavior;
- Establish, as well as strengthen, the necessary control structures that enable C.R.M. S.p.A. to prevent the commission of offenses by apical and non-apical persons, including through monitoring action on the areas of activity at risk, and sanction behavior contrary to the provisions of Model 231;
- make potential perpetrators aware that any offense is stigmatized by C.R.M. S.p.A. and contrary – in addition to the provisions of the law – to the ethical principles to which the company itself intends to adhere to.
As an integral part of Model 231, C.R.M. S.p.A. has also adopted a “Code of Ethics” which contains the values, principles and rules behavior of a general nature, which all those who work in the employ or on behalf of C.R.M. S.p.A. or who represent it must respect and pursue in the performance of their respective activities.