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Organizational Model according to Decree Law no. 231 of 8th June 2001 FOMA Spa


  • The task of monitoring observance of the Model and its effectiveness was entrusted to a collective Monitoring Body made up of three members, of which two from outside the Company. All of them fulfil the autonomy, independence and professionalism requirements.
  • The Monitoring Body carries out the task entrusted to it in full autonomy vis-à-vis the Company’s structure. It has the necessary financial resources to carry out its activities and avails itself of all the employees obliged to collaborate with it also by reporting possible violations.
  • The Organizational Model is directed to all those who belong to the structure at all levels, including managers and administrators.
  • The Organizational Model includes all the general behavioural principles and specific procedures and provisions to be implemented in order to prevent those working on behalf of Foma SpA from committing the offences mentioned in the relevant Decree.


Keeping in mind the business carried out and the organizational arrangement of Foma SpA, the Model was implemented on the basis of the following types of offences provided for by Decree Law 231:

    • Offences against the Public Administration
    • Company’s offences
    • Offences committed through violation of the regulations concerning accident prevention and hygiene and health protection at the work place
    • Offences concerning IT practices and the handling of data;
    • Offences committed throughviolation of the regulations concerning money laundering
    • Offences committed through violation of the environmental regulations


The Model consists of two parts:

  • General Part;
  • Specific Part.


The following issues are tackled in the General Part:

  1. Decree Law no. 231 of 8th June 2001 and relevant Standard
  2. The Company’s structure of Foma SpA
  3. The Organizational Model of Foma Spa;
  4. The Monitoring Body
  5. Selection and training of personnel
  6. Disciplinary and sanction system
  7. Control and update of the Organizational Model
  8. Self-discipline Code
  9. Ethical Code


The protocol of activities connected with the types of offence taken into consideration are discussed in the Specific Part.

They are the formalization of the Company’s procedures adopted. These procedures are subject to constant review and updating following (internal and external) audit analyses, reports received and the changes in the regulations concerning the issues taken into consideration.

The Ethical Code discussed in the general part completes the model containing the values, the behavioural principles and the commitments that must be observed by all those who work for the Company.

The Organizational Model is available on request.


The Monitoring Body does not have operating tasks but monitors the application and updating of the Model on the basis of a constant flow of information, keeping in mind the reports received.

All the Receivers of the Model must transmit the required flow of information to the Monitoring Body, make considerations on the suitability of the system by highlighting emerging requirements and possible critical profiles and by reporting violations of the Model as far as the behavioural and work modalities are concerned.

Should the above flows of information not be transmitted or be transmitted late, this will be considered as a violation of the organizational Model and may be sanctioned in compliance with the provisions of the Disciplinary System.

The flows of information will be trasmitted as required by the Monitoring Body, while Reports concerning assumed violations of this model must be in writing and sentby post to theMonitoring Body at the following address:

Organismo di Vigilanza di Foma Spa

Via Kennedy n. 20,

25020 – Pralboino (BS),

The reports must contain:

  • an indication of the violation of the Model detected
  • a brief descrption of the behaviour punishable with a sanction
  • the identification of the person committing the violation
  • the identification of the person reporting


The Monitoring Body will not be able to take into consideration reports received anonymously.

When managing the above Reports the Monitoring Body will observe the regulations governing privacy and the principle of secrecy as far as both the object of the report and the person reporting are concerned.

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