231/01 Organizational, Management, and Control Framework | Whistleblowing

To strengthen and improve the company’s control and governance system, OverIT S.p.A. has launched a project for the adoption of an organizational and management framework, pursuant to Legislative Decree 231/2001 and to international principles, defining a set of protocols to regulate the corporate structure and the management of sensitive processes, especially to reduce the risk of committing criminal offenses.

OverIT S.p.A., firmly believing in the need to constantly raise its ethical standards, the culture of transparency and integrity used in the conduct of its business, wanted to adopt its own Code of Ethics that contains the enunciation of ethical principles, values and rules of conduct that all those who work for the company are required to observe.

The project ended on 22 December 2021 with the approval of the document “Organizational, Management and Control Framework of OverIT S.p.A. as pursuant to Legislative Decree no. 231 of 8 June 2001” (also OMC Framework”), which is constantly updated and it is approved by the Board, as well as the Code of Ethics.  Both documents may be viewed herein.

General Section – OMC Framework
OverIT Code of Ethics

In addition, OverIT has appointed a Supervisory Body – with autonomous powers of initiative and control, to ensure that the OMC Framework is compliant with the company’s structure and is updated, thus it is entrusted with the following tasks:

  • monitoring the effectiveness of the OMC Framework (checking the compliance of the conduct of a natural person with the model);
  • assessing the adequacy of the OMC Framework, i.e. its actual capacity to prevent unlawful conducts;
  • checking that the requirements of soundness and efficiency of the OMC Framework are maintained over time;
  • ensuring that the OMC Framework is updated, if the assessments made entail revisions and amendments.

The Supervisory Body is also responsible for:

  • identifying any non-compliance that may emerge from the analysis of information flows and reports received by the heads of the different departments;
  • reporting any breaches which may give rise to liability for the Company, so that the management may take appropriate measures;
  • providing guidance as to the meaning and the enforcement of the provisions contained in OMC Framework;
  • freely accessing, without prior consent, any department of the company in order to request and acquire -from employees and managers – information, documents and data, deemed necessary for the performance of the tasks provided for by Legislative Decree no. 231/2001 and international principles.

Any violation or suspected violation of the OMC Framework may be reported to the Supervisory Body, which will be the solely entity viewing the report, as compliant with the principles of full protection of the security, confidentiality and anonymity of the same reporter.

Reports may be sent to: omc_supervisorybody@overit.it

Moreover, OverIT has introduced the discipline of the so-called “Whistleblowing” and created a specific channel by means of which the Company’s employees can report, in complete confidentiality, irregular conducts. Whistleblowing channel is at the following link: https://overit.whistleblowing.it/

While, when the reporting involves the Supervisory Body or any individual member of the Board, whistleblowers may notify the event directly to the Board of Directors at the following e-mail: omc_boardofdirectors@overit.it 

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