Legislative Decree 231/2001 and Supervisory Body
As provided for by Legislative Decree 231/2001 of 8 June 2001 on the administrative liability of entities, CMC Ravenna SpA has adopted an Organization, Management and Control Model that ensures correctness and transparency in the conduct of business and aims to prevent crimes committed in the interests or for the benefit of the company. According to this Decree, companies and in general all entities may be held accountable in criminal proceedings, and therefore face sanctions, for certain crimes committed in their own interest or benefit by directors, employees, and other entities acting in the name or on behalf of the entity or company. The Decree specifically includes crimes related to public administration, corporate crimes, crimes related to workplace safety and the environment, organized crime, terrorism, cybercrimes, crimes against industry and commerce, crimes against individuals, tax crimes, receiving stolen goods, money laundering, and self-laundering, etc. To minimize the risk of these crimes being committed, Each company is required to adopt an “Organization and Management Model”, that is, a set of provisions and procedures, including the adoption of a Code of Ethics, the establishment of a Supervisory Body, and the implementation of a control and sanctions system. The adoption and effective implementation of the Model and the appointment of the Supervisory Body allow the entity to enjoy the clause exempting liability in the event of crimes. The “Model 231” of CMC Ravenna SpA is a dynamic and shared document. Dynamic, because it is sensitive to any regulatory and organizational change. Shared, because its implementation involves the entire business population, both in the pre-processing phase, through risk assessment, and in the implementation phase, through training and information.
Model Organization Management Control
Supervisory Board
The Company’s Supervisory Body is a collegial body, endowed with powers of initiative and control, whose members, identified by the Board of Directors, must possess requirements of autonomy, independence, professionalism, continuity of action, and integrity. The Supervisory Body is entrusted with supervisory tasks regarding compliance with the Model’s requirements, the actual effectiveness of the Model and the appropriateness of updating it, as well as operational tasks related to the application of the Model.
The organization of the CMC Ravenna SpA company is represented by:
- Avv. ssa Desirèe Fondaroli – President
- Gaetano Mastropierro – External Component
- Costanzo Di Gioia – Internal Component – Corporate Contact
Monitoring and updating the Model
The set of areas at risk of committing crimes under Legislative Decree 231 and the rules of conduct present in the Model are the result of an analysis of company documentation and meetings with staff, in order to adapt the Model to the characteristics of the company.
The CMC Ravenna SpA Model is subject to continuous monitoring to evaluate its effectiveness and ensure its updating with respect to internal (in organizational structure, business activities, etc.) and external changes (legislative developments, best practices, etc.).
Training and information
Staff training is an essential element for the effective implementation of the Model. E’ a training plan was then developed that includes both classroom sessions and e-learning modules, with content diversified according to the recipients and based on concrete examples. Also in order to evaluate the quality of teaching, evaluation tests on the topics covered in the lesson are distributed at the end of the courses.
