Model Org. 231

The Organisational Model per Legislative Decree no. 231/2001


- EURAL GNUTTI has adopted an Organisational Model in compliance with Legislative Decree no. 231/2001. The model relates to all levels of company structure, therefore directors, managers and supervisors are included. - The Model, which aims to achieve a complete organisation and control system, represents a set of general conduct principles as well as specific procedures and rules put in place to combat and prevent the carrying out of offences provided for by the same decree in the activities of those who work on behalf of EURAL GNUTTI SPA. -  The EURAL GNUTTI SPA Model is organised into two chapters, in addition to the annexed documents: a) In the first chapter (or general section) the relevant legislation is examined and the organisation’s structural characteristics are identified as well as the methods for the creation of the model and its formation; more precisely:
  1. Legislative Decree 231/2001 and the relevant legislation;
  2. The company structure of EURAL GNUTTI S.P.A.;
  3. The Organisational Model of EURAL GNUTTI S.P.A.;
  4. The Supervisory Board (SB);
  5. Verification and updating of the Organisational Model.
b) In the second chapter (or special section) protocols for the activities associated with the types of offence considered are instead elaborated. The activities undertaken and the organisational structure of EURAL GNUTTI S.P.A are examined. The Model adopted considers the following types of offence:
  1. Offences against the public administration;
  2. Company offences;
  3. Offences committed through violation of the provisions on workplace health and safety regulations;
  4. Computer-related offences and unlawful data processing;
  5. Offences committed in violation of anti-money laundering legislation;
  6. Offences committed in violation of environmental legislation;
  7. Offences relating to the employment of illegally staying third-country nationals.
c) In the annexes (which form an integral part of the Organisational Model) are found:
  1. Risk Map
  2. Code of Ethics (Download Code of Ethics)
  3. Self-Regulatory Code
  4. Disciplinary and Sanctioning System;
- The proper implementation and adequacy of the Organisational Model was entrusted to a collegial Supervisory Board. The Supervisory Board was endowed with autonomous powers of initiative and control and performs its tasks having all the resources necessary; all the recipients of the Organisational Model are required to cooperate with the Supervisory Board including through reports of any cases of non-compliance. - Therefore, the recipients of the Model are required to send the information flows required to the Supervisory Board, comment upon the adequacy of the system, by highlighting emerging needs and any criticalities, as well as report any violations to the standards of conduct and established operating procedures in the Model. -  The information flows should be sent in the manner that the Supervisory Board requires, while reports of presumed violations of this Model must be sent to the Supervisory Board, in writing only, by post, to the following address:

Supervisory Board of


Via San Andrea n. 3,

25038 – Rovato (BS)

The reports should contain:
  • The report of the observed violation of the Model with a description of the conduct adopted;
  • The identity of the alleged person responsible for the violation;
  • The identity of the person responsible for the report.
Anonymous reports will be disregarded by the Supervisory Board. In the management procedure by the Supervisory Board of the Reports described above, the privacy policy as well as the principle of confidentiality with reference to both the subject and the promoter of the report should be complied with. The Organisational Model is available on request. Download Code of Ethics