Procedures and controls
The Organization, Management and Control Model pursuant to Legislative Decree 231/2001 (hereinafter, the “Model”), adopted in accordance with the Guidelines issued by Confindustria in the version updated to June 2021 and approved by the Ministry of Justice, constitutes an organic system of principles, procedures, protocols and controls aimed at preventing the risk of commission of predicate crimes provided for by Legislative Decree 231/2001 (hereinafter, the “Decree”). It is composed of a General and a Special Part, which regulate, with reference to the individual processes and sensitive activities identified by the Company, the internal control system, the prevention procedures and the information flows adopted respectively for each company management involved, also with a view to integrated compliance and whistleblowing protection, in accordance with current legislation.
Surveillance body
In order to ensure the effective and concrete implementation of the Model, including by monitoring company behavior in risk areas and acquiring a constant flow of information on sensitive activities, the Company has established, in accordance with the provisions of Legislative Decree 231/2001, the Supervisory Body, which is granted autonomous powers of initiative and control. By resolution of the Board of Directors dated November 24, 2025, the Model and Code of Ethics were reviewed and updated, also in light of the regulatory changes that have occurred and the introduction of additional relevant predicate offenses pursuant to the Decree.
Other documents
General Section: INALCA S.p.a. Organizational and Management Model
Special Sections:
- Undue receipt of funds, fraud against the State, a public authority or the European Union or in order to obtain public funds, IT fraud against the State or a public authority and fraud in public supplies. Embezzlement, misconduct, undue induction to give or promise utilities, corruption and abuse of office.
- Corporate crimes
- Manslaughter and serious or grievous bodily harm, committed in breach of the laws on injury prevention and health and safety in the workplace
- Falsities involving cash, public credit cards, stamp duty and recognition means or signs. Crimes against trade and industry
- Environmental crimes
- Crimes of receiving stolen goods, money laundering, use of cash, assets or utilities of illegal origin and self-laundering
- Organised crime
- Tax-related crimes.
