MOG 231/01

The Legislative Decree 231/2001 introduced a new form of corporate liability for certain types of crimes committed by its directors and employees, as well as by persons acting in the name and on behalf of San Polo Lamiere S.p.A.

San Polo Lamiere S.p.A., in reference to Legislative Decree 231/2001, formally established an Organizational Management and Control Model. The Model thus adopted arises from the need, as well as the regulation, to successfully tackle the complexity of the situations in which the company operates, clearly defining the set of values ​​that inspires and wants to be respected. In no way can the conviction of acting for the benefit of the Company justify the adoption of behavior in contrast with these principles.

The Model of San Polo Lamiere S.p.A. consists of a „General Part“ and a „Special Part“ which defines the different types of crimes and offenses to be prevented.

Any violation or suspected violation of the Model and / or any other information pertaining to the implementation of the Model can be reported to the Supervisory Body of San Polo Lamiere S.p.A. at the following email address:



Still in the same section, we suggest to insert another part dedicated to the Ethical Code with a document and a brief description:

For all those who work with and within San Polo Lamiere S.p.A., the Ethical Code is the tool through which the Company sets out its values ​​and principles of behavior.

All those who entertain business relations with, in the name and on behalf of San Polo Lamiere S.p.A. they are required to contribute to its implementation and to the dissemination of the principles formalized in it, so that all relations with external bodies can be conducted on the basis of the most absolute correctness, in full observance of the rights of others, in compliance with applicable laws and the principles of belonging to the company.

At the basis of the Ethical Code there is a long-term commitment, that supports and gives foundation to the strategy and economic objectives of the industrial development of San Polo Lamiere S.p.A.


Link Ethical Code

Whistleblowing is the reporting of a risk that may harm customers, colleagues, shareholders, the public or the company’s reputation. San Polo Lamiere has always been careful of the prevention of risks, of any nature and entity, which could compromise the responsible and sustainable management of its functions.

The Corporate Governance Code for companies listed on the Italian Stock Exchange, has ordered the creation of an instrument that can offer the possibility to report any presumed irregularities that may be disclosed; therefore, San Polo Lamiere ,inspired by these provisions, has been activated for the creation of a tool that provides the possibility to employees, business partners, suppliers and other subjects, to report incidents of corruption, fraud or other non-compliance, through a path guided online, which assists the signaling person and allows to specify the report in a precise and orderly way .

The reports may refer to issues related to the internal control system (for example compliance with external laws and regulations, as well as corporate rules and procedures, corporate asset fraud and corporate information) or violations of the Ethical Code (for example behavioral ethics, mobbing, harassment, conflicts concerning personnel management).

San Polo Lamiere guarantees all aspects of privacy and security in the protection of personal data and in the processing of information, through the adoption of secure protocols and the use of cryptographic tools for the contents of the reports and any attachments.

San Polo Lamiere has developed its own reporting management tool in compliance with the guidelines, instructions and internal operating procedures (Ethical Code and Model 231)



Personal data acquired within the reports are processed in full compliance with the current privacy legislation (Legislative Decree 20 June 2003, No. 196, as amended by Legislative Decree No. 101/2018, and EU Reg. 2016 / 679), with particular regard to the identity of the signaling person. The Data Controller is San Polo Lamiere S.p.A., in the person of its legal representative, with registered office in Via IV Novembre 2, 43056 San Polo di Torrile (PR). The updated list of Data Processors is available at the company’s registered office.

Except in cases where it is possible to configure liability for slander and defamation pursuant to the provisions of the penal code or art. 2043 of the Italian Civil Code and hypotheses in which anonymity is not legally enforceable (for example criminal, tax or administrative investigations, inspections of control bodies), the identity of the whistleblower is protected in any context subsequent to the report.

Therefore, without prejudice to the above exceptions, the identity of the reporter cannot be disclosed without his express consent and all staff involved in the management of a report is required to maintain the utmost confidentiality and compliance with the regulations in force. in terms of privacy, considering every information as sensitive.

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