ORGANIZATION, MANAGEMENT AND CONTROL MODEL 231/2001
The Board of Directors of BetaGlue Technologies SpA held on 31 July 2023 approved the Organization, Management and Control Model drawn up pursuant to Legislative Decree 8 June 2001, n. 231 11 Administrative responsibility of legal persons” and at the same time proceeded to appoint an independent collegial Supervisory Body which assumed the tasks envisaged by the legislation (art. 6, paragraph 1, letter b) of Legislative Decree 231 of 2001).
CODE OF ETHICS
The Board of Directors of BetaGlue Technologies SpA held on 31 July 2023 approved the Organization, Management and Control Model drawn up pursuant to Legislative Decree 8 June 2001, n. 231 “Administrative responsibility of legal persons” which is made up, among other things, of the Code of Ethics. In order to ensure, as far as reasonably possible, effective compliance with the rules reflected in this Code, the Company has appointed an independent collegial Supervisory Body composed of the lawyer. Francesco De Luca (President), Dr. Andrea Chiaravalli and Dr. Giovanni Parisio. BetaGlue Technologies SpA has thus formalized the commitment that has always inspired its action, i.e. implementing and promoting socially responsible behavior within its organization and, through its policies and practices, within its sphere of influence, requiring consequently to all recipients of the Organization, Management and Control Model as identified therein, compliance with the Code of Ethics and the principles set out therein.
BetaGlue Technologies SpA has complied with the provisions of art. 6 paragraphs 2-bis, 2 ter and 2 quater of Legislative Decree 231/01, i.e. detailed reports made by the recipients of the Model to protect the integrity of the Company regarding unlawful conduct relevant pursuant to the decree itself or violations of the Model referred to the exponent became aware of it in the context of the employment relationship. Each recipient is required to report unlawful conduct relevant pursuant to the decree and based on precise and consistent factual elements or conduct in violation of this Model of which they have become aware due to the functions performed. Specifically, reports of violations of the Model and/or illegal conduct must contain:
- useful elements for the reconstruction of the reported event with attachment, where possible, of the relevant supporting documentation;
- information that allows, where possible, the identification of the person responsible for the disputed fact;
- an indication of the circumstances under which the reported fact became known.
Anonymous reports, i.e. without elements that allow the reporting party to be identified, will be taken into consideration if and to the extent that they contain the elements indicated above.
The obligation of the truthfulness of the facts reported and of good faith and diligence in the reporting remains unchanged: the Company will not tolerate unfounded reports made in bad faith and/or with slanderous or defamatory intent and will apply the relevant disciplinary sanctions.
Each report must be adequately detailed so that it appears worthy of attention, as well as in order to allow the Supervisory Body to proceed promptly.
BetaGlue Technologies SpA has identified the Supervisory Body as the person to whom the recipients must send the reports, by post or e-mail to the following addresses:
- email address: email@example.com
- ordinary mail address addressed to: Supervisory Body, BetaGlue Technologies SpA, Piazzetta Umberto Giordano 4, Milan (MI). The envelope, properly sealed, must be marked “confidential”.
Reporters in good faith are guaranteed against any form of retaliation, discrimination or penalization and in any case the confidentiality of the identity of the reporter will be ensured, without prejudice to legal obligations and the protection of the rights of the Company or of persons accused erroneously or in bad faith.
The Supervisory Board evaluates the reports received, with a guarantee of confidentiality and protection of the reporter, carries out the consequent investigations and requests the adoption of any consequent measures, at its discretion and responsibility, possibly listening to the author of the report and/or the person in charge of the alleged violation and assuming the reasoned determination of any waiver to proceed with an internal investigation.
With regard to the data of the reporting person, it is specified that the report can be sent anonymously, provided that it is not only adequately detailed, but also detailed and precise, so that it is possible for the Supervisory Body to carry out the necessary checks and evaluate the reliability of the report.
The aforementioned email and ordinary mail addresses can also be used for reporting violations of EU law and the national regulatory provisions provided for by Legislative Decree 24/2023. The whistleblower is guaranteed the same protections as above.