Carlo Colombo S.p.A., having taken note of the legislation in force and its scope, sharing the spirit expressed by the legislator and being aware of the fundamental importance of ethics, has taken steps to adopt this Organizational Model by resolution of the Board of Directors on July 27, 2018.
It should be stressed that the company already had a system of procedures in place that was certified according to the UNI EN ISO 9001 standard and subsequently integrated with the OHSAS 18001 and ISO 14001 standards, as a tool for proper company management. As part of this quality, safety, and environment system, the Model was considered as a complement to the system, supporting the coordination between corporate mappings, procedures, and protocols already present in the company or to be implemented following approval of this Model.
In its preventive role, the Model is primarily aimed at individuals with company representation, administration, or management duties, in the various forms, as well as at those who in fact manage and control the company, or organizational units of the company itself. In addition to directly complying with and duly observing the Model, these senior individuals ensure compliance by the persons they manage or supervise.
The Model applies directly and must be observed by all company employees in their various categories, and it is also necessary for third parties, partners, and consultants to respect its general principles (in particular the principles of ethics and conduct referred to in the Code of Ethics).
The company reiterates that, beyond the provisions of the law and its potential exempting effect pursuant to the Decree, the adoption of the Model and the Code of Ethics forms a real tool for making recipients aware of their potentially unlawful conduct, for preventing offenses by precisely indicating specific conducts and a suitable monitoring system, or for reacting promptly in the event such conduct is committed anyway.