231 Corporate Compliance Model

Legislative Decree no. 231/2001 introduces into Italian law the administrative liability of companies for certain offences committed, in the interest or to the advantage of the corporation, by parties functionally connected to it.

Officine Nuove s.r.l. promotes a corporate culture based on principles of Responsibility, Fairness, Integrity and Transparency in the conduct of its activities, requiring similar ethical and behavioural standards from all subjects having contractual relations with the Company.

In this context, acting on a proactive policy and with a significant economic and human commitment, Officine Nuove s.r.l. established a Corporate Compliance Model (M.O.G. 231) aimed at preventing the commission of offences pursuant to Legislative Decree no. 231/2001.

This Model binds all internal and external stakeholders, including directors, auditors, employees, customers, suppliers, partners, and collaborators who operate in different roles in the Company’s interest, to comply with its provisions.

Officine Nuove s.r.l. places respect for Social, Environmental, and Ethical principles at the core of its corporate strategy towards all stakeholders and among the Company’s fundamental values, with particular emphasis on Workplace Health and Safety.

For this purpose, the Company has adopted a Code of Ethics, binding all recipients to comply with the principles and behavioural rules contained therein, and a Disciplinary System, aimed at detecting and sanctioning any violations of the M.O.G. or the Code itself.

The effectiveness and enforcement of the Organizational Model are guaranteed by appointing an external, independent and single-member Supervisory Board, endowed with autonomous powers of initiative, supervision, and control.

In compliance with Legislative Decree no. 24/2023 and the Guidelines issued by ANAC, Officine Nuove s.r.l. has updated its internal reporting system. The Whistleblowing Regulation was adopted, which governs the procedures for reporting possible violations of the Code of Ethics, the M.O.G., as well as Italian and European laws.

The triple envelope method was chosen as reporting channel, entrusting the monocratic Supervisory Body, which ensures the confidentiality of the information and the anonymity of the whistleblower, within the limits allowed by law.