Minifaber SpA Code of Ethics
Model 231
The Board of Directors of Minifaber SpA adopted the organization, management, and control model for the prevention of crimes on March 14, 2023, for the purposes of Legislative Decree. 231/2001, as amended. This model is a tool that companies adopt to prevent crimes within their organizations and avoid criminal liability.
Why does a company decide to adopt model 231?
A company decides to adopt Model 231 for several reasons:
Crime prevention: Model 231 helps the company define and implement procedures and behaviors that reduce the risk of crimes, such as bribery or fraud, being committed by its employees and managers.
Exemption from liability: If a company adopts an effective 231 model and demonstrates that it has applied it correctly, it can avoid or reduce its criminal liability for crimes committed by its employees or contractors.
The law provides that the company is exempt from liability if the crime was committed by a person under its direction but the company has put in place adequate prevention means.Improved image and reputation: The adoption of a 231 model demonstrates a company's concrete commitment to legality and ethics. This can be a competitive advantage, improving the company's reputation vis-Ã -vis customers, partners, investors, and regulators.
Governance and internal control: Model 231 helps structure and strengthen governance and internal control processes by establishing clear operational guidelines for managing crime-related risks.
How does the 231 model work?
Model 231 is based on a number of key components:
Risk analysis: The company must map the risks related to the commission of crimes within its activities.
Procedures and protocols: Internal procedures, codes of conduct, policies, and controls are defined to prevent the occurrence of crimes.
Supervisory Board: This is an independent body outside the company that monitors and supervises the effectiveness of the model.
Training and awareness: The company must train its employees, managers, and contractors on the model, procedures, and the importance of compliance.
In summary, Model 231 is a compliance tool that helps companies prevent unlawful behavior and protect themselves from criminal liability while improving their governance and reputation.
The Code of Ethics and Model 231
The Code of Ethics is a fundamental component of Model 231, as it is the document that establishes the principles and ethical values by which the company is guided in its activities. It is a compliance tool that helps ensure that the organization's actions are in accordance with legal, transparent, and social responsibility standards. Within the 231 model, the Code of Ethics is crucial in setting behavioral guidelines and preventing crimes by employees, managers, and contractors.
The Code of Ethics within Model 231 is a set of moral, behavioral, and operational principles that the company adopts to promote a culture of legality, integrity, and responsibility. It establishes norms of behavior to be followed in all business activities and interactions with stakeholders (employees, customers, suppliers, partners, institutions, communities).
The Code of Ethics, in relation to Decree 231/2001, helps to:
prevent the commission of crimes
define corporate expectations in terms of behavior for all those working within the company, including expectations toward legality, ethics and accountability.
strengthen corporate culture.
The Code of Ethics is supported by the Supervisory Board (SB), which is responsible for monitoring compliance with Model 231, including the Code of Ethics. The SB verifies that company policies are effective and that the behaviors described in the Code are adhered to. The SB is also responsible for updating the Code of Ethics based on changing regulations and business needs.
Whistleblowing
Whistleblowing is a fundamental aspect of the 231 model, as it represents a tool through which employees, collaborators, and other company members can report illegal behavior, violations of regulations, or other activities that do not comply with the Code of Ethics and the organization and control model.
An effective whistleblowing system not only helps reduce the risk of criminal liability, but also promotes a culture of corporate ethics and integrity. To be truly effective, the whistleblowing system must ensure the protection of whistleblowers, confidentiality of information, and timely handling of reports, with the involvement of the Supervisory Board in monitoring compliance with internal policies.