Legislative Decree 231/01 and subsequent amendments, introduced into our system the “administrative responsibility of agencies” (businesses, individual enterprises, etc..., even those without legal personalities) with regard to conduct leading to the commission of crimes by individuals belonging to the company or in a collaborative relationship with the company, occupying both managerial and non-managerial positions. With the implementation of said decree, Metronapoli S.p.A, eager to spread and consolidate a culture of transparency and integrity, as well as being aware of the importance of ensuring proper conditions for conducting business activities in order to protect its image and the interests of its shareholders and clients, has endowed itself with an organisational and business management model as precaution and means of preventing the occurrence of the above-stated offences.
An essential part of this Model is the Ethical Code, which constitutes a means of promoting the “Business Deontology”, and although lacking specific procedural provisions, with regard to the Model, the code comprises a corpus of internal norms aimed at encouraging an ethical environment and one of business transparency.
The agency possesses a preventive control system composed of:
- An Organisational System;
- Manual and Technical Procedures;
- Authorisation powers and signatures
- A Management Control System
- Communication with the personnel, as well as providing for its training;
- Verification System;
- Disciplinary System and Sanction Mechanisms;
- Ethical Code
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Law 231