Legislative Decree 231, Code of Ethics and Code of Conduct

Organisational, management and control model

Legislative Decree 231 of 8 June 2001 introduced the concept of administrative responsibility for entities – including joint stock companies – into Italian law, covering certain offences committed by directors, executives or employees in the interests or for the benefit of the entity.

Aware of the need to ensure the propriety and transparency of the Company’s business dealings and operations, Atlantia SpA has adopted an Organisational Model, with a view to establishing a system of rules and controls designed to prevent commission of the offences covered by the Decree.

The Model applies to all of Atlantia’s employees and anyone who interacts with the Company, with the aim of ensuring that they conduct themselves in full compliance with the law and in keeping with the ethical and social values adopted by the Company in the pursuit of its objectives.

Organisational, management and control model
Scarica il pdf

Supervisory Board

The Supervisory board is responsible for overseeing the functioning, effectiveness and observance of the Model, and for its ongoing revision.


Code of Ethics and Ethics Officer

The Group’s Code of Ethics sets out the key elements in Atlantia's corporate culture, translated into guidelines to be followed in the day-to-day management of operations.


Code of Ethics (English version) Download PDF
Code of Ethics (Spanish version) Download PDF
Code of Ethics (Portuguese version) Download PDF

Atlantia SpA and all its subsidiaries adopted the Code of Conduct for the prevention of discrimination and the protection of the dignity of the Group’s women and men

Code of Conduct for the prevention of discrimination and the protection of the dignity of the Group’s women and men Download PDF

The Ethics Officer is a Group Body established by Atlantia, with responsibilities for:


  • to supervise the observance of the Code, by examining information on possible violations of the same, by promoting the controls which may be deemed necessary, eventually with the cooperation of Atlantia Internal Audit Department;
  • to diffuse and verify knowledge of the Code, by preparing communication programs and activities aimed at improving the knowledge of the Code;
  • to issue guidelines and operational procedures or subsequent amendments and additions aimed at reducing the risk of violation of the Code;
  • to propose eventual amendments to the Atlantia’s Supervisory Body with the aim of updating the Code.



The members, appointed by the CEO of Atlantia, are :


Michelangelo Damasco General Counsel Coordinator
Monica Cacciapuoti Chief Human Resources Officer
Concetta Testa Head of Group Internal Audit
Guglielmo Bove Head of Legal and Corporate Affairs at Aeroporti di Roma
Amedeo Gagliardi Head of Legal Affairs at Autostrade per l’Italia



Reports to the Ethics Officer may be submitted:
  • by email to: ethic_officer@atlantia.it;
  • by regular mail to: Atlantia S.p.A., Ethics Officer, via Antonio Nibby, 20 - 00161 Roma

Atlantia adopted a procedure that regulates the receipt, analysis and processing of the reports submitted to the Ethics Officer, by employees and third parties who have come to have knowledge of any alleged breaches of the Code of Ethics; and the method of conducting the relevant investigation, in accordance with the privacy laws or any other regulations of the country where the alleged breach occurred, as applicable to the party and the subject of the report. The Ethics Officer shall ensure utmost confidentiality with respect to the reports received, as well as the anonymity of the reporting and reported parties.
Reporting to the Ethics Officer
Scarica il pdf

All reports will be processed by Ethics Officer to aim necessary adjustments.


Summary of the reports received and handled by the Ethics Officer