Organization, Management and Control Model pursuant to Legislative Decree No. 231/2001

 

Montura’s Commitment

Montura S.r.l. considers ethics, legality, transparency and responsibility to be fundamental principles in the conduct of its business activities. In this context, the Company has adopted the Organization, Management and Control Model provided for by Legislative Decree No. 231 of 8 June 2001, as a tool for risk prevention and for promoting a corporate culture based on integrity and regulatory compliance.

 

The Code of Conduct can be downloaded here

The Organization, Management and Control Model can be downloaded here

 

Legislative Decree No. 231/2001

Legislative Decree No. 231/2001 introduced into the Italian legal system the administrative liability of entities for specific criminal offences committed, in the interest or to the benefit of the entity itself, by individuals operating within or on behalf of the entity.

The adoption and effective implementation of an adequate organizational model constitute an important tool for preventing risks and promoting conduct that complies with the law.

 

Purpose of the Model

Through the 231 Model, Montura aims to:

• - promote compliance with applicable laws and corporate ethical principles;

• - prevent the risk of unlawful conduct;

• - strengthen the Company’s control and governance system;

• - foster a culture of responsibility, fairness and transparency;

• - protect the Company’s assets, reputation and sustainability.

 

Recipients

The principles of the Model apply to all those who operate, in any capacity, on behalf of or in the interest of the Company, including directors, employees, collaborators, consultants, business partners and suppliers.

 

Principles of Conduct and Control

Montura’s prevention system is based on the principles of transparency, fairness, traceability of activities, clear allocation of responsibilities, adequacy of controls, and compliance with applicable laws and corporate policies.

These principles provide the framework for the conduct of the Company’s business activities and for managing relationships with all stakeholders.

 

Code of Ethics

The Model is complemented by the Company’s Code of Ethics, which sets out the values and principles of conduct that must guide everyone working for Montura.

Legality, integrity, respect for people, environmental protection, fairness in business relationships and social responsibility are essential values underpinning the Company’s conduct.

 

The Code of Ethics can be downloaded here

 

Supplier Code of Conduct

As an integral part of its prevention system, Montura has adopted a Supplier Code of Conduct, which sets out the principles of legality, fairness, protection of workers’ rights, occupational health and safety, environmental protection and sustainability required of suppliers, business partners and all third parties having business relationships with the Company.

The Supplier Code of Conduct complements the Model and the Code of Ethics and extends these principles throughout the supply chain, requiring everyone who collaborates with Montura to uphold the same values of legality, fairness and transparency.

 

The Supplier Code of Conduct can be downloaded here

 

Supervisory Body

Montura has established an autonomous and independent Supervisory Body, which is responsible for overseeing the effective implementation of the Model, assessing its adequacy and promoting its continuous updating.

 

Whistleblowing

The Company has adopted specific reporting channels in compliance with applicable legislation, through which potential violations of the law, the 231 Model or the Code of Ethics may be reported confidentially.

Montura guarantees the confidentiality of the whistleblower’s identity and prohibits any form of retaliation or discrimination against anyone who makes a report in good faith.

 

Training and Continuous Improvement

The Company promotes a culture of compliance and legality through information and awareness-raising activities aimed at the recipients of the Model.

The Model is subject to periodic review and updating in order to ensure its continued effectiveness and ongoing alignment with regulatory and organizational developments.

 

Transparency and Publication of Documentation

With a view to ensuring the highest level of transparency towards employees, collaborators, suppliers and all stakeholders, Montura makes the General Section of the Model, the Code of Ethics and the Supplier Code of Conduct available on its website. More confidential sections remain for internal use, in order to safeguard the effectiveness of the prevention and control system adopted by the Company.

Montura S.r.l. recognizes legality, business ethics and social responsibility as essential factors for sustainable growth and the creation of long-term value for customers, collaborators, business partners and all stakeholders.