General Part Model
Legislative Decree no. 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., with reference to Legislative Decree no. 231/2001, has formally established an Organizational Management and Control Model. The Model thus adopted arises not only from regulatory requirements, but also from the need to successfully address the complexity of the situations in which the Company operates, clearly defining the set of values by which it is inspired and which it requires to be respected. Under no circumstances may the belief of acting in the interest of the Company justify the adoption of conduct that is contrary to 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.
Code of Ethics
For all those who operate with and within San Polo Lamiere S.p.A., the Code of Ethics represents the instrument through which the Company sets out its values and principles of conduct.
All those who maintain business relations with, in the name and on behalf of San Polo Lamiere S.p.A. are required to contribute to its implementation and to the dissemination of the principles formalized therein, so that all relations with external entities may be conducted on the basis of the utmost fairness, in full observance of the rights of others, in compliance with applicable laws and with the principles of belonging to the Company.
At the basis of the Code of Ethics there is a long-term commitment, which supports and provides the foundation for the strategy and economic objectives of the industrial development of San Polo Lamiere S.p.A.
Whistleblowing
SAN POLO LAMIERE S.p.A. undertakes to guarantee the protection of persons who, within the scope of their relationship with the Company, report violations of European Union law and national regulatory provisions, as required by Legislative Decree no. 24/2023.
The EQS Integrity Line platform represents the internal channel implemented for this purpose by SAN POLO LAMIERE S.p.A. and by the Group to which the Company belongs.
This channel:
• allows reports to be submitted in written or oral form;consente di rendere una segnalazione in forma scritta o orale
• is configured in compliance with the parameters set forth in Legislative Decree no. 24/2023, ensuring the confidentiality of the reporting person, of any reported person and of the content of the report;
• allows contact to be maintained with the report manager through the “Secure Inbox”;
• is entirely free of charge for the user.
The EQS Integrity Line platform allows the reporting person to provide their personal data or to remain anonymous. The reporting person may also request a face-to-face meeting with the report manager – Alfa Solutions S.p.A. The reporting person is invited to review the corporate procedure adopted by the Company.