Introduction to
Model 231

ABP Nocivelli SpA prevents risks arising from liability under Legislative Decree 231/2001 by adopting and effectively implementing a specific Organisation, Management, and Control Model.

The Model is a document drawn up by the company, which determines guidelines and identifies control activities to avoid violation of the principles unless its provisions are fraudulently circumvented.

Consequently, the Model: analyses the activities in the context of which the offenses precisely indicated in the decree (predicate offenses) may be committed; defines the possible violations relevant to the company’s activities, identified among the predicate offenses provides for specific prevention controls;

identifies the company management methods suitable for preventing the commission of each offense;

introduces a disciplinary system to sanction non-compliance with the measures included therein.

According to legislation, supervision of the Model’s adequacy, updating, and effectiveness is entrusted to a “Supervisory Board”, an independent body appointed by the Board of Directors.

To enable the Supervisory Board to carry out its activities regularly, the Model also defines the obligations to provide it with information.

The Model was adopted by the resolution of the Board of Directors on 27/01/2017 and is periodically updated to incorporate organizational and process changes and new types of offenses that may subsequently modify the scope of application of Legislative Decree 231/2001. 231/2001.