MODEL ORG. 231
The Organisational Model pursuant to Legislative Decree 231/2001
of MARA SRL
MARA SRL has adopted an Organisational Model pursuant to Legislative Decree 231/2001.
The Model is addressed to all levels of the corporate structure, thus including directors, managers and supervisors.
The Model, which aims to create a complete system of internal control and organisation, represents a set of general principles of conduct as well as specific procedures and provisions put in place to combat and prevent the commission of the offences provided for by the decree itself in the context of the activities of those who work on behalf of MARA SRL.
The MARA SRL Model is structured in two chapters plus annexed documents:
a) The first chapter (or general part) examines the relevant legislation and identifies the structural characteristics of the Organisation as well as the methods of creating the model and its formation; more specifically:
- 1. Legislative Decree 231/2001 and the relevant legislation;
- 2. The corporate structure of MARA SRL;
- 3. The Organisational Model of MARA SRL;
- 4. Supervisory Body (SB);
- 5. Verification and updating of the Organisational Model.
b) The second chapter (or special section) instead develops the protocols of the activities related to the types of offences considered. Having examined the activity performed and the organisational structure of MARA SRL, the Model adopted considers the following types of offences:
- 1. Offences committed in violation of the rules on the protection of health and safety at work;
- 2. Offences committed in violation of environmental legislation;
- 3. Offences committed in the management of relations with suppliers/clients and the management of tender, work or supply contracts;
c) The annexes (which in any case form an integral part of the Organisational Model) include:
- 1. Map of Risks;
- 2. Code of Ethics annex. B and all. B1
- 3. Disciplinary and sanctioning system;
The task of supervising the proper functioning and adequacy of the Organisational Model has been entrusted to a monocratic Supervisory Board. The Supervisory Board is endowed with autonomous powers of initiative and control and performs its duties with all the necessary resources; all recipients of the Organisational Model are required to cooperate with the Supervisory Board, also by reporting any non-compliant situations.
Therefore, the recipients of the Model are required to transmit the required information flows to the Supervisory Board, to make observations on the adequacy of the system, highlighting emerging needs and any critical profiles, and to report any violations of the behavioural and operational procedures set out in the Model.
Information flows shall be transmitted in the manner requested by the Supervisory Board, while Reports of alleged violations of this Model shall be forwarded to the Supervisory Board, solely in writing, by e-mail [email protected] or by postal service, to the following address
Supervisory Board of
Via Adua 11, 25050 – Passirano (BS)
Reports shall contain:
– an indication of the violation of the Model detected with a description of the conduct adopted;
– the identification of the subject author of the violation;
– the identification of the person making the report.
Reports received anonymously cannot be taken into account by the Supervisory Board. In the procedure for the handling by the Supervisory Board of the Reports referred to above, the rules on privacy and the principle of confidentiality shall be observed, with reference both to the person who is the subject of the Report and to the person who made the Report.
The Organisational Model is available on request.