Organisational model pursuant to Italian legislative decree 231/01

Legislative decree 231/01 introduced the concept of the administrative liability of Entities and Companies into Italian law, to be ascertained in criminal proceedings (a tertium genus of liability). The liability of companies and the related sanction are connected with the perpetration of offences by contractors, employees and/or persons holding senior roles within the company’s organisation.

In view of the need to ensure probity and transparency in the business practices and company activities undertaken by management, governing bodies, employees, contractors and all persons who work with the Company in any capacity, and in order to prevent unlawful acts and to protect its position, image and the expectations of its shareholders and employees, Cogenio’s Board of Directors has decided to adopt an Organisation, Management and Control Model and a Code of Ethics, which forms an integral and substantial part thereof.

As envisaged in Article 6 of legislative decree 231/01, Cogenio has also appointed a Supervisory Body to oversee the operation and adequacy of the Model adopted by the Company. The Supervisory Body is made up of the following:

Claudio Solenghi

Giovanni Frucci
Eugenio Vaccari