Model 231
“The principles that guide our organisation in the management of business activities.”
Since 2003, Poste Italiane has adopted its own Organisational Model, which is continuously updated in line with regulatory, organisational and business developments, with the aim of building a structured and organic system of guiding principles, operating procedures and other specific safeguards, inspired by criteria of sound business management and aimed, in line with the company’s purpose, at preventing the commission of the offences set out in the Decree, as well as protecting the interests of stakeholders relevant to the company itself.
The Model consists of a General Section and Special Sections, each of which relates to a class of offence relevant to the Company. The General Section provides a description, adapted to the business specificity of Poste Italiane, of the contents explicitly required by Legislative Decree no. 231/2001, (e.g. the regulation, the governance of the Company, the Supervisory Board, training/information activities, the system of sanctions, etc.) as well as the company’s integrated internal control and risk management system (e.g. the integrated risk management process, the Company Regulatory System, the Group’s Code of Ethics and Policies, the Corporate Governance System); the individual Special Sections outline, according to a logic based on processes, the different types of offences concretely and potentially relevant in the Company, as well as the corporate processes, sensitive activities, rules of conduct and specific control principles analysed for each class of offence.
In Poste Italiane’s Model 231, sustainability issues are also of significant importance, in line with the Company’s strategic direction and in consideration of the correlations and synergies between them and Decree 231. Model 231 constitutes a tool that, through the identification of specific control measures to prevent the perpetration of offences ascribable to Decree 231, also contributes to supporting the Company in the realisation of the material topics defined by it within the 8 Pillars of Sustainability that contribute to the achievement of the United Nations Sustainable Development Goals.
The Organisational Model is constantly updated in order to ensure, on an ongoing basis, its adequacy and effectiveness in relation to the various changes affecting both the organisation and the external context, also taking into account the progressive expansion of the so-called “predicate-crimes” referred to in Legislative Decree no. 231/2001, as well as the orientations of case law on this subject.