ORGANIZATIONAL MODEL
 


CHOOSING TRANSPARENCY


Coeclerici (“The Company”) voluntarily adopted the Organizational Model for Italian Legislative Decree no. 231 of 8 June 2001.

According to the Italian law “Responsibility of legal entities for administrative offenses,” entities, including corporations, can be responsible and therefore subject to penalties in relation to certain offenses committed or attempted – in Italy or abroad – on behalf or for the benefit of The Company.

The Company has adopted the Organizational Model, a Code of Ethics and set up a Supervisory Board.
Adoption of this Model is designed to create organic and structured procedures, rules and controls in order to prevent and / or substantially reduce the risk of committing one or more offenses covered by the Decree.

The Model adopted by The Company is consistent with best practices established by industry associations, and is designed to reinforce transparency and accountability within the internal control environment.

Any violation or suspected violation of this Model and / or any other information pertaining to its implementation may be reported to the Supervisory Board.

Messages to the Supervisory Board can be sent in writing to the following address:

Coeclerici S.p.A.
Organismo di Vigilanza – c/o Internal Audit
Piazza Armando Diaz n.7
20123 Milan (Italy)
Organismodivigilanza@coeclerici.com