MODEL 231

Legislative Decree No. 231 of 8 June 2001 introduced into our legal system the principle of liability for entities and companies. The Decree provides for the application of sanctions to the entity/company whose senior management or other employees, in the exercise of their functions, have committed certain offenses in the interest and/or to the advantage of the entity or company itself.

The introduction of this Decree has represented, for Fincantieri, an opportunity to reaffirm in the Code of Conduct those principles of loyalty, fidelity and propriety that have always characterized its modus operandi.

In line with the requirements set forth by Legislative Decree 231/2001 (Art. 6, paragraph IIc), the model addresses the following needs:

• identifying the activities within which offenses may be committed;
• providing specific protocols aimed at planning the formation and implementation of the Entity’s decisions in relation to the offenses to be prevented;
• identifying methods for managing financial resources suitable for preventing the commission of offenses;
• establishing information obligations towards the body responsible for monitoring the functioning and compliance with the models;
• introducing a disciplinary system suitable for sanctioning non-compliance with the measures indicated in the model.