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 in order to prevent the risk of commission of criminal offences related to the Company's business.
Model 231
Our Model 231 implements the provisions of Legislative Decree no. 231/2001 - which has introduced into Italian legislation the administrative responsibility in criminal proceedings of organizations for some offences committed in their interest or to their advantage by directors, managers or employees - in order to prevent the commission of the crimes provided for by the Decree itself.
The Model is designed to promote the execution of company activities in accordance with the principles of fairness, ethics and transparency and, at the same time, to avoid potential risk situations in the management of the business.
The Model consists of two parts:
- a general part that illustrates 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 behaviors and prevention measures in order to reduce the risk of committing the crimes set forth in the Decree.
The Model 231 is dynamic by definition and it is periodically updated in consideration of any organizational and/or regulatory changes in line with best practices and industry standards.
The latest version of the Model 231 was approved by the Board of Directors of Amplifon S.p.A. on October 26th, 2022.
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 Supervisory Body is responsible for supervising the correct functioning, effectiveness and observance of the Model 231, as well as its updating, and periodically verifying the implementation of the principles and controls contained therein.
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 22th, 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 and 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 (Law 179 of November 30, 2017) 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.
