Model 231 and Whistleblowing

Techpol Srl has equipped itself with the Management, Organization and Control Model pursuant to Legislative Decree No. 231/2001 (hereinafter also only “Model 231”), which introduced a regime of administrative/criminal liability, borne by companies for certain types of offenses provided for in the aforementioned decree, thus adapting and integrating its organizational system to the requirements of this legislation.

The Organization, Management and Control Model pursuant to Legislative Decree 231/01 was approved by the Board of Directors of Techpol Srl, in the first instance, by resolution on June 30, 2018, and subsequently updated and amended to adapt it to the changed regulatory and organizational contexts.

The main purpose of the adopted Model is to ensure the prevention of the commission of the offenses provided for in the decree itself, and it consists of a series of documents such as: assessment of activities in relation to the risks of offenses provided for; Code of Ethics; control procedures and tools; training and information activities; disciplinary system; Supervisory Board (SB) and information flows.

The principles, provisions and prescriptions set forth in the Model adopted by Techpol Srl are binding on the directors, employees, suppliers and all persons acting in various capacities on behalf of and in the interest of Techpol Srl

In line with Legislative Decree 231/01, Techpol Srl has also adopted its Code of Ethics, which defines the set of values that the company recognizes, accepts and shares, at all levels, in carrying out its business activities. The principles and provisions of the Code of Ethics constitute illustrative specifications of the general obligations of diligence, fairness and loyalty that qualify the performance of work services, behavior in the work environment and the activities of the company itself.

In addition, in compliance with Article 6, paragraph 1, letter b) of Legislative Decree 231/2001, the Board of Directors of Techpol Srl also established and appointed its own Supervisory Board, in the person ofLawyer Vincenzo Arenella, endowed with autonomous powers of initiative and control, which has the task of supervising the operation of and compliance with Model 231.