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.
Methodology
GENERAL PART containing, in addition to a brief description of the content of Legislative Decree 231/01, a presentation by Inalca and the Cremonini Group to which it belongs, an illustration of the methodology used to build the Model together with a description of the “sensitive” areas, as well as the identification of the Supervisory Body and the provision of a specific disciplinary system.
SPECIAL PART dedicated to the specific Organizational Units of the Society due to the characteristics of the activities carried out with a view to preventing the crimes referred to in Legislative Decree. 231/2001.
The document, thus constructed, details the contents of the General Part Model and aims to indicate to the members of the individual Offices/Organizational Structures of the Company:
the tasks entrusted to them, in the performance of which the Company has identified a risk of committing a crime (so-called sensitive activities);
the reference prevention protocols.
OUTSOURCED ACTIVITIES: Finally, the Model provides for one “Part Three”, which contains the sensitive activities identified in the context of activities outsourced by the Company to other entities, with regard to which the prevention protocols in use, implemented by the entities performing the outsourced services, are applied.”
