ORGANIZATIONAL MANAGEMENT AND CONTROL MODEL, LEGISLATIVE DECREE 231/2001

The Legislative Decree 231/2001 introduced a new form of corporate liability for certain types of crimes committed by its directors and employees, as well as by persons acting in the name and on behalf of the company. LSI S.p.A., in reference to Legislative Decree 231/2001, formally established an Organizational Management and Control Model which is available at the following link: Model

The Model thus adopted arises from the need, as well as the regulation, to successfully tackle the complexity of the situations in which the company operates, clearly defining the set of values ​​that inspires and wants to be respected. In no way can the conviction of acting for the benefit of the Company justify the adoption of behavior in contrast with these principles. The Model of LSI S.p.A. consists of a “General Part” and a “Special Part” which defines the different types of crimes and offenses to be prevented.

The Company has also established a Supervisory Body (SB), which has the task of constantly monitoring compliance with the Code of Ethics and the Model by all recipients, as well as checking the implementation of the provisions contained therein. 

REPORTS TO SUPERVISORY BOARD

LSI S.p.a. has adopted a management procedure for the reports received from the Company's Supervisory Body, in which appropriate information channels have been set up to allow the communication of reports on any violations of the Code of Ethics and the Organization and Management Model. These communications and reports are managed by the Supervisory Body, composed of subjects inside and outside the Company. Employees, customers and outsiders can send, with the maximum guarantee of confidentiality, detailed reports of illegal phenomena and suspicious behavior, of irregularities in the conduct of business, of acts or facts that may constitute a violation of internal and external rules, which govern the activities of LSI Spa, the principles and rules of conduct contained in the Code of Ethics and in the provisions of Model 231.

Personal data acquired within the reports are processed in full compliance with the current privacy legislation (Legislative Decree 20 June 2003, No. 196, as amended by Legislative Decree No. 101/2018, and EU Reg. 2016 / 679), with particular regard to the identity of the signaling person. Except in cases where it is possible to configure liability for slander and defamation pursuant to the provisions of the penal code or art. 2043 of the Italian Civil Code and hypotheses in which anonymity is not legally enforceable (for example criminal, tax or administrative investigations, inspections of control bodies), the identity of the whistleblower is protected in any context subsequent to the report.

Therefore, without prejudice to the above exceptions, the identity of the reporter cannot be disclosed without his express consent and all staff involved in the management of a report is required to maintain the utmost confidentiality and compliance with the regulations in force. in terms of privacy, considering every information as sensitive. Any report concerning the implementation of the Model can be sent to the Supervisory Body, at the following e-mail address: OdV@acciailsi.it

Form to fill out to make a report to the SB: Link Management and control model