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CHAPTER 6 | GOVERNANCE AND MONITORING OF CORPORATE ETHICS AND RISK

timely manner. To this end, a dedicated procedure The Organisational Model
has been created and distributed which identifies and the Supervisory Body
the modes of operation and rules to be followed Since 2006, Ratti SpA has had an organisational,
when managing any reports of violations received management and control Model which complies
from recipients of the Group’s Code of Ethics. with Legislative Decree 231/2001 (MOG
231/01) and has appointed a Supervisory Body.
The Board of Statutory Auditors The Organisational Model and the related
The Board of Statutory Auditors is the internal attachments (the Group’s Code of Ethics, the
body that monitors the application of all corporate Suppliers’ Code, the Whistleblowing Policy), were
governance principles and ensures compliance updated at the end of 2018. All the Company’s
with regulation and legislation. It also ensures subsidiaries have subsequently adopted the
compliance with the principles of the by-laws Code of Ethics and the Suppliers’ Code.
and guarantees that the principles of proper
administration are adhered to, with a specific The Model consists of twelve parts: a general
focus on the functioning of the organisational, introductory part and eleven special parts which
administrative and accounting structure. describe the details of the offence, recipients,

Figure 10 – Characteristics of Organisational Model 231

SUPERVISION, UPDATING, DOCUMENT AND SYSTEM
INFORMATION AND TRAINING OF PREVENTION

DISCIPLINARY COMMITMENT TO
MEASURES PREVENT OFFENCES
AND SANCTIONS
THE 231
ORGANISATIONAL
MODEL
INTEGRATION ORGANISATIONAL
OF MANAGEMENT CHOICES TO ENSURE
SYSTEMS LEGALITY

GUIDELINES AND
RULES, REGULATIONS INDICATIONS
AND PROCEDURES
REGARDING BEHAVIOUR

Figure 11 – Characteristics of the Supervisory Body

Self-regulation Checking the need to update
the Model

Supervising observance
Access to corporate of the Model
documents

POWERS SUPERVISORY FUNCTIONS Checking that the Model is
BODY valid and adequate
Information obtained in a timely
manner
Communicating with the
responsible bodies

Use of external consultants
Coordinating and verifying
activities to disseminate
the model within the company

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