Organizational model and whistleblowing organization,

Management and Control Model pursuant to Legislative Decree no. 231/01 231/01

Organizational model

Overmach, with resolution of the Board of Directors dated July 15th 2021, approved its organizational, management and control model, to align with the provisions of Legislative Decree 231/2001 in order to prevent to commit unlawful conduct in the corporate context.

Starting from the assumption that the Organizational Model is a valid tool for raising awareness among recipients to adopt correct and transparent behaviors, through the adoption of Overmach Model it intends to pursue the following purposes:

  • to prohibit conduct that may constitute the offences referred to in the Decree;
  • to spread awareness that, from the violation of the Decree, of the provisions contained in the Model and of the principles of the Code of Ethics, it may result the application of sanctioning measures (pecuniary and disqualification) also against the Company;
  • allow the Company, thanks to a structured system of protocols and procedures and constant monitoring of the correct implementation of this system, to promptly prevent and/or combat the commission of significant crimes pursuant to the Decree.

The provisions of the Model are binding for the directors and for all those who hold, inside OVERMACH or in one of its organizational units with financial and functional autonomy, functions of representation, administration and management or management and control, even de facto, for managers and employees, for collaborators subject to the direction or supervision of the Company’s top management.

whistleblowing system

OVERMACH provides the possibility for employees, business partners, suppliers and other parties to report through the email address of the Supervisory Body and/or by paper mail, any episodes that may determine or determine violations of company procedures or the possible commission of crimes. The mail references are contained within the attached procedure.

The aim of the adoption of this tool is to prevent the violation of legal provisions, non-compliance with the Organizational Model or other company regulations (i.e. Anti-Corruption Code, Antitrust Code of Conduct, etc.), but also to involve all stakeholders in the fight against illegality. The “Reporting Procedure to the Supervisory Body” is attached and any potential whistleblower is invited to read it before submitting any report.

whistleblowing

Whistleblowers provide information that can lead to the investigation, detection and prosecution of breaches of the rules, thereby reinforcing the principles of transparency and responsibility of the organizations. The new rules aim to ensure the protection – both in terms of protection of confidentiality and protection from retaliation – of subjects who expose themselves with reports or complaints, contribute to the emergence and prevention of risks and situations detrimental for the administration or entity to which they belong and, consequently, to the collective public interest.