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Legislative decree 231 model
Italian Legislative Decree No. 231 of June 8, 2001 (hereinafter referred to as “Legislative Decree 231/2001” or the “Decree”), pursuant to Article 11 of Law No. 300 of September 29, 2000, introduced into the Italian legal system the “Regulations governing the administrative liability of legal entities, companies, and associations, including those without legal personality,” outlining its general principles and criteria for the attribution of liability.
The Decree was intended to align domestic legislation regarding the liability of legal entities with several international conventions, including:
- The Brussels Convention of July 26, 1995, on the protection of the European Communities’ financial interests;
- The Convention of May 26, 1997, on the fight against corruption involving officials of the European Communities or officials of Member States;
- The OECD Convention of December 17, 1997, on Combating Bribery of Foreign Public Officials in International Business Transactions.
In line with this Decree, and in compliance with a broader corporate commitment to the principles of fairness and transparency in its operations, Elettronica Spa has adopted an Organization, Management, and Control Model pursuant to Article 6 of Legislative Decree 231/2001, in accordance with the Confindustria Guidelines. Furthermore, the Company has appointed a multi-member Supervisory Body composed of high-profile professionals to ensure independence, impartiality, and depth of analysis through continuous liaison with top management and the Board of Directors.
The adopted Model integrates into the regulatory framework already established within the company, beginning with the Code of Ethics. It builds upon robust existing controls developed according to recognized international standards and verified by third parties, such as the UNI ISO 37001 certification for Anti-Bribery Management Systems.
Specifically, within the scope of its commitment to preventing and combating conduct for which there is absolute and non-negotiable zero tolerance, the 231 Model will oversee and govern:
- Mapping of activities at risk of offenses being committed
- Disciplinary and sanctioning system
- Training and prevention activities
- Reporting obligations to the Supervisory Body
- Management of financial resources to prevent the commission of offenses