Code of ethics and 231 model

The Group Code of Ethics defines the set of ethical principles, duties and responsibilities assumed with regard to all parties who collaborate with the Group to achieve the corporate objectives. 

The Code of Ethics is directed at all internal parties of the Group, as well as external parties who, by virtue of contractual relationships, collaborate with the Group in the course of their activities.

Through the adoption of the Code of Ethics, doValue guarantees that the conduct of recipients is always inspired by correctness, collaboration, loyalty, transparency, legality and mutual respect, and to avoid that any conduct considered in any way unsuitable is avoided. 

These principles also apply to the relationships between the various Group Companies which must be transparent and comply with applicable regulations in the legal systems of reference as well as consistent with the guidelines set by doValue.

Whoever acquires knowledge of breaches or situations that are even potentially noncompliant with the principles expressed in the Code of Ethics (and/or the system of procedures and internal controls enabling implementation) shall promptly notify the Supervisory Body (SB) of the Company, where applicable, or the local Body or Function attributed the control tasks. Reports can be sent by paper post, by e-mail and through alternative internal channels used to report breaches (so-called “whistleblowing”) accessible through the dedicated application on the institutional website.

Recipients, non compliant with or in breach of the principles, will be sanctioned as they were considered non compliant with the ethical-conduct principles adopted by doValue and by the Group Companies, with the duty of correctness towards the latter and a breach of specific contractual clauses, if foreseen.

Each company is committed to ensure the sharing and dissemination of the Code of Ethics, both to internal and external parties, with the aim of developing awareness of the value of ethics and to promote conducts in compliance with the principles and values stated in the Code.

The Code of Ethics is an essential part of the Organization, Management and Control Models pursuant to Leg. Decree 231/2001 adopted by doValue, and constitutes a valid sensitization tool for all those operating on behalf of the Company so that their conduct is correct and straightforward, but also a more effective way to prevent the risk of committing the Offences and illegalities established in the Decree.

The doValue models, in accordance with Italian Legislative Decree no. 231/2001, are based on the fundamental principles of:

• transparency of conduct related to sensitive areas;
• traceability of operations related to the sensitive areas;
• correctness of all parties referring to doValue or to the Group’s Italian Companies.

Models principles and provisions must be respected by all parties operating in the Company and by all external ones who, through contractual relations, collaborate with doValue to perform their activities.

The doValue’s 231 Models establish different reporting channels for violations, as defined within the procedure “Use and management of the violation reporting system” (“Whistleblowing”) published on the institutional website and on the intranet.
 

Organization, Management and Control Model

To implement what is set forth in the Decree and consistent with statutory regulations, the Board of Directors appoints the Supervisory Body to which it assigns the supervision, functioning and compliance of the Model, and its continuous updating.

In consideration of the provisions pursuant to Leg. Decree 231/2001, the Board of Directors of doValue has assigned the role as Supervisory Body of the Group’s Italian Companies to their Board of Statutory Auditors, or, where the supervisory body has not been set up, has opted for the establishment of a body of monocratic composition, entrusting the role of member of the ODV to a person identified among the statutory auditors of the Board of Statutory Auditors of the Parent Company and/or of the other companies of the doValue Group.