Model 231
Model 231 and supervisory body
We
adopted an Organizational, Management and Control Model ("Model 231")
in accordance with Legislative Decree no. 231/2001 and appointed a Supervisory
Body entrusted with the task of supervising the functioning and observance of
the Model, as well as its update.
Model 231
Our Model 231 responds to the requirements expressed by the Legislative Decree no. 231/2001 - which has introduced in Italy the liability of the Legal Entities for certain crimes committed in the interest or to the benefit of the same - and provides for a set of principles, rules and provisions that affect the functioning of the Company and the methods with which it relates to external parties, in order to prevent the commission or attempted commission of the crimes referred to in the Decree from which the administrative liability of the Company may arise.
The Model is designed to promote and strengthen a corporate culture increasingly geared towards ethics, fairness and transparency in conducting Company business and activities, as well as prevent potential unlawful conduct relevant under the Decree.
The Model consists of two parts:
- a general part that describes the contents of the Decree, the purposes of the Model, the methods of constitution and functioning of the Supervisory Body, the disciplinary system and personnel training;
- a special part that describes the relevant types of crimes, the principles of conduct to be respected and the control protocols implemented by the Company aiming to prevent the risk of committing the crimes set forth in the Decree.
The Model 231 is periodically updated in line with best practices and industry standards, in the event of changes in the corporate structure and changes in the context in which the Company operates, as well as in consideration of any regulatory changes having an impact on the Company.
The latest version of the Model 231 was approved by the Board of Directors of Amplifon S.p.A. on July 27th, 2023.
The Code of Ethics is an integral part of the Model 231 and constitutes its very essence for the definition and dissemination of a culture based on ethics and corporate transparency.
The Supervisory Body
Functions
The Amplifon Supervisory Body has the following functions:
- monitoring the functioning and adequacy of the Model;
- overseeing the effectiveness and the observance of the Model;
- taking care of the Model update;
- promoting and supervising the dissemination of the Model and the related training.
The Supervisory Body of Amplifon reports to the Board of Directors.
Composition and appointment
The members of the Supervisory Body meet the following requirements:
- autonomy and independence from any conditioning in carrying out its activities;
- professionalism and competence in legal matters, control systems and company organization;
- continuity of action in constantly monitoring the observance of the Model 231 as well as its implementation and updating.
The current Supervisory Body was appointed by the Board of Directors on April 22nd, 2022 and consists of:
- Lorenzo Pozza, Chairperson of the Supervisory Body, Lead Independent Director
- Laura Donnini, Non-executive, Independent Director
- Laura Ferrara, Chief Internal Audit & Risk Management Officer
Notifications
Each recipient of the Model 231 is required to promptly notify the Supervisory Body of any violation, or well-founded suspicion of violation, of the Code of Ethics’ principles, the rules of conduct and control protocols provided for in the Model 231, as well as any deviation from operating procedures and practices relevant for the purposes of the Decree.
The Company complies with the legislation on whistleblowing (Legislative Decree no. 24/2023) and provides two dedicated institutional communication channels towards the Body:
- E-mail address: odv@amplifon.com
- Dedicated freephone line: 800.737762
In accordance with the law, the Model 231 introduces measures aimed at protecting whistleblowers and other subjects protected by legislation.
