The D.Lgs.231/2001 has introduced into the Italian legal system a new regime of liability for legal persons that arises from the commission, in the interest of or for the benefit of the Authority, of certain types of crime (cd. Crimes presupposed) by natural persons who – as subjects in the top position or subject to the direction of others – represent, administer, direct or, more generally, operate for the same entity.

This liability is in addition to that of natural persons who have actually committed the illegal act with a view to penalising the legal person in the interest or for the benefit of which the crime was committed. In this regard, in fact, art. 5, paragraph II, of the Decree states that the institution is not liable if the perpetrators of the crime have committed it in the exclusive interest of themselves or third parties.

The D.Lgs.231/2001 guarantees the exclusion from the administrative responsibility, pursuant to art.6, comma1, if: the governing body has adopted and effectively implemented, before the commission of the fact, a Model of Organization and Management suitable to prevent the offences provided for by law; has been assigned to supervise the observance and proper functioning of the Model to an Entity Body with autonomous powers of initiative and control (Supervisory Body); employees or directors have committed the crime by fraudulently circumventing the Organisation and Management Model adopted by the Institution and that there has been no omission or insufficient supervision by the Control Body.

In order to guarantee behaviours aimed at correctness and transparency in the management of business activities, Ferriera di Cittadella S.p.A. has adopted its Code of Ethics, a Model of Organization, Management and Control ex D. Lgs. 231/2001 and established a Supervisory Body.

The Model provides not only for the measures aimed at preventing the commission of the offences provided for by the Decree, a disciplinary system, articulated according to the different types of recipients of the Model, aimed at sanctioning the non-compliance with the rules contained in the Model itself.

The Supervisory Body includes an external component appointed Chairman of the Body and an internal component.

It is possible to send any reports for violations of the Model to the Supervisory Body by writing an e-mail to: odv@ferriera.it, or writing to the Supervisory Body of Ferriera di Cittalella SpA to the following address: Borgo Vicenza,126 – 35013 Cittadella (PD) – Italy. All communications will be processed by the Supervisory Body in accordance with the provisions of Law 30.11.2017 n. 179 on the protection of the anonymity of the authors of the reports.

CODE ETHICS || MOG || Mail to ODV (D. Lgs. 231/01) || Whistleblowing