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
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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 identifies the essential core of values that underpins the corporate culture and is translated into the management principles and policies that guide our daily actions.

Moreover, Atlantia and the Group Companies have adopted a Code of Conduct for the prevention of discrimination and the protection of the dignity of the Group's women and men. Both are Codes.

 

Code of Ethics (English version) Download PDF
Code of Ethics (Spanish version) Download PDF
Code of Ethics (Portuguese version) Download PDF
Code of Conduct for the prevention of discrimination and the protection of the dignity of the Group’s women and men Download PDF

Atlantia has set up a specific Collegial Body called the Whistleblowing team, which is responsible for the reporting management process, assesses this latter’s adequacy, suggests any improvements to the process to the Board of Directors and promotes the necessary information and training measures aimed at the corporate population. It is also responsible for:

  • monitoring compliance with the Codes, examining reports of possible violations and promoting the checks deemed necessary, also in collaboration with the Internal Audit Department of Atlantia S.p.A.;
  • disseminating and verifying knowledge of the Codes, promoting communication programmes and activities aimed at spreading awareness of them;
  • proposing the issuance of guidelines and operating procedures, or additions and amendments to existing ones, to reduce the risk of the Codes being violated;
  • proposing any amendments aimed at updating the Code of Ethics to the Company's Supervisory Body.

The Whistleblowing team, which was appointed by Atlantia's Managing Director, is made up of the following members:

Lorenzo Alzati Internal Audit Director of Atlantia S.p.A. Coordinator
Nicola Pelà Human Capital & Organization Director
Claudia Ricchetti General Counsel 
Tiziano Ceccarani Chief Financial Officer

 

 

Reports to the Ethics Officer

 
Summary of the reports received and handled by the Ethics Officer