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|
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)|
|Code of Ethics (Spanish version)|
|Code of Ethics (Portuguese version)|
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: email@example.com;
- 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|
All reports will be processed by Ethics Officer to aim necessary adjustments.