We have adopted an organisation and management model that sets out rules of conduct and identifies the controls that must be adopted to prevent offences under Italian legislative decree 231/2001 and to exclude or limit any administrative liability for the company. In addition, we have appointed a surveillance body that is responsible for monitoring the functioning and implementation of the model.
The model comprises a general part and several special parts.
The general part sets out the reasoning behind the decree and its principles, and illustrates the governance model, the principles of the internal control system, and the component parts of the model.
Each special part contains a legal analysis of the individual offences covered by the decree, as well as the general principles of conduct that should guide activities in all potential risk areas. For each risk area, we have identified the following information: the company functions affected, any ‘sensitive activities’, the specific offences theoretically possible, how they could be committed or the actions that could lead to their commission, ‘preventive controls’ and the duties of the surveillance body in this regard.
The methodology used to prepare the model takes account of major legal precedents and theories, best practices for applying the decree, and the Italian insurance association’s (ANIA) guidelines for the industry.
The surveillance body is a collegiate body comprising two external professionals, one of whom serves as chairperson, an independent non-executive director, and the heads of the group audit and group compliance functions. All members meet the requirements for authoritative knowledge, competence and proven experience on matters relating to the responsibilities of the surveillance body.
In order to perform the tasks assigned, the surveillance body is granted all necessary powers to ensure that it can accurately and effectively monitor the functioning of the model and compliance with it.
A detailed description of the powers and responsibilities of the surveillance body is provided in the model.
Luigi Arturo Bianchi (External member – Chair)
Giuseppe Alessio Vernì (External member)
Maurizio Basso (Group Compliance)
Giuseppe Catalano (Secretary)