How we work
- Risk assessment: analysis of business processes, identification of sensitive areas, mapping of the applicable predicate offences.
- Model design: drafting of the general document plus a special section for each relevant category of offence.
- Operating protocols: written procedures for the high-risk areas (purchasing, dealings with the public administration, financial management, IT, health and safety).
- Code of Ethics and Conduct: definition of the principles and rules of behaviour.
- Formal adoption: support to the Board of Directors in the adoption resolution.
- Supervisory Body (OdV): we take on the role of external Supervisory Body, or support the internal one.
- Training: mandatory programme for directors, managers and employees.
- Periodic audits: annual verification of the Model's effectiveness, and its updating.
When it is mandatory
Legislative Decree 231 does not formally make the adoption of the Model mandatory, but it is a necessary condition for benefiting from the exemption from liability should an offence occur. It is particularly recommended for:
- companies that work with the public administration;
- companies that take part in public tenders;
- companies with complex or multi-site governance;
- organisations subject to sector supervision (healthcare, finance, energy);
- companies whose shareholder-directors want to limit their personal liability.
Continuous updating
The Model is not a static document: it has to be updated at every significant organisational change, whenever new predicate offences are added by law (the list keeps growing) and following relevant findings from internal audits.