Organisational Model under Legislative Decree 231/2001
The CIAL Consortium has decided to adopt an Organisation, Management and Control Model in order to implement and maintain a Governance system adhering to high ethical standards, promoting constant awareness of the importance of auditing and of responsible and conscious behaviour, and therefore capable of preventing and/or reducing the risk of the offences identified in Legislative Decree no. 231 of 8 June 2001.
In line with the new international and national regulatory and self-regulation scenario, CIAL has thus undertaken a series of initiatives aimed at implementing the Compliance Model adopted.
This has led to a need for the Consortium to bring its structure and management methods into line with the aforesaid Model by means of the following measures:
- Risk mapping, analysis and assessment
- Appointment of a Supervisory and Control Body
- Verification of the adequacy of the procedures adopted in order to create an adequate preventive auditing system
- Verification of the existence of an organisational system that is sufficiently formalised and clear as far as the so-called “reporting hierarchy” is concerned (organisation charts)
- Verification of the adequacy of Information Systems
- Review of powers of signature and levels of authorisation
- Adoption of management control systems
- Preparation of an internal and external communication plan
- Staff instruction and disciplining system
- Establishment of “Help-Desk” and a “Hotline”
- Planning of periodic Audits
The Organisational Model aims to prevent the risk of commission of the offences described in Legislative Decree 231/2001 and is addressed – in addition to the Supervisory Board – to persons having relations with CIAL, in particular:
- members of other consortium bodies, as well as any other person in a senior position,
- meaning any person who holds representation, administration or management positions in the Consortium
- employees (including managers), including temporary or part-time workers who have been assigned powers and associates, meaning people who have relationships of agency, representation, commercial distribution or coordinated and continuous collaboration with the Consortium, mainly on a personal basis and without any relationship of subordination
- occasional and ongoing consultants, including temporary workers
- intermediaries, business partners, consultants, professionals and suppliers of goods and services
- any other counterpart having contractually regulated relations with the Consortium
The Model was approved, in its current version, by the Board of Directors on 21 September 2017
The complete document may be downloaded below.
In order to supervise the correct application of the model and propose updates thereto, in compliance with the provisions of Art. 6, paragraph 1, letter b) of Legislative Decree 231/2001, CIAL has set up a Supervisory Body, a collegial body made up of three external members: Marco Salvatore Brignone (Chairman), Renato Montedoro and Salvatore Rocco”.