Model 231 and Code of Ethics

Fondazione Villa Russiz has adopted an Organisation, Management and Control Model (hereinafter "MOG 231" or the "Model") pursuant to Legislative Decree no. 231 of 8 June 2001, which governs the administrative liability of entities for offences committed by their representatives.

Purpose of the Model

Model 231 is a structured system of rules, procedures and control measures designed to prevent the commission of the predicate offences set out in the Decree and to spread, within and outside the organisation, a culture of legality, integrity and transparency.

Structure of the Model

• General Part: regulatory framework, governance, disciplinary system, training, and the role of the ODV.
• Special Part: analysis of sensitive processes and control measures for the offences applicable to the Foundation's activities (including offences against the Public Administration, corporate offences, tax offences, environmental offences, workplace health and safety, and computer crimes).
• Code of Ethics: principles and values that all addressees must uphold.

Addressees

The addressees of the Model and the Code of Ethics are the members of the corporate bodies, employees, collaborators, consultants, suppliers and any other party who, in any capacity, acts in the name and on behalf of Fondazione Villa Russiz.

Reports and disciplinary system

Violations of the Model or the Code of Ethics may be reported to theSupervisory Board or via the Whistleblowingchannel. The disciplinary system provided for by the Model sanctions non-compliant conduct, consistent with the applicable collective labour agreement and contractual provisions.

Documentation

The General Part of Model 231 and the Foundation's Code of Ethics are available upon written request sent to villarussiz@villarussiz.it.