Code of Ethics

Italian Legislative Decree no. 231/2001

Code of Ethics

The Italian Legislative Decree no. 231 of June 8, 2001 (hereinafter, the Decree), which lays down “Provisions on the administrative liability of legal persons, companies and associations, including those without legal personality”, introduced into the Italian legal order an administrative liability regime applying to Entities for a series of specified offences committed, in the interest or to the advantage of the these entities, by individuals who are representatives, directors or managers of the company (i.e. individuals in apical positions), by individuals who are representatives, directors or managers of one of its organizational unit that has financial and functional independence, by individuals who are responsible for managing or controlling the company or by individuals who are managed or supervised by an individual in an apical position. The Entity’s liability is additional to that of the natural person who is the perpetrator of the offence. Companies shall not be considered liable if the individuals who commit the crime act in their own exclusive interest.

The penalties that can be imposed on the legal entity are both monetary and disqualifying penalties, including the following most serious ones: the suspension of licences and concessions, no contracting with the Public Administration, disqualification from carrying on the activity, exclusion from or withdrawal of loans or subsidies, no advertising of goods and services.

Over time the law has extended the crimes which may trigger a company's liability in a continuous evolution of the application field.

 
RDZ, as part of the Caleffi Group, acknowledges the importance of preventing these crimes, has adopted the present Organisation, Management and Control Model as a valid control tool to prevent its representatives, managers and employees from committing such offences.

On July 14th, 2009, the Administrative Body adopted the present Organisation Management and Control Model and appointed a Supervisory Board (OdV). This board has the task of supervising the operation and compliance of the 231 Model and updating it.

Its steady application will eliminate or reduce the risks detected, and it will represent an exempting situation pursuant to the Decree.