Organizational Model ex D.LGS 231/2001

The companies of PHOENIX Pharma Italia have adopted the Organisational Model, pursuant to Legislative Decree 231/2001, aimed at preventing the possibility of committing offences for which the companies could be held administratively liable. The model in question, based on a detailed analysis of company activities identifying the activities potentially at risk, is a set of general principles, rules of conduct, control tools, organisational procedures and disciplinary systems aimed at preventing, as far as possible, crimes from being committed.

The Organisational Model 231 consists of a general section, illustrating the function and principles of the Model, as well as the contents of Legislative Decree 231/2001 and the main reference standards, besides a series of annexes that constitute the heart of the Model 231 and refer to its contents, which are: the identification of activities at risk; the definition of protocols to monitor the identified risk profiles; the nature and purpose of the Supervisory Body; information flows; the Code of Ethics; and the disciplinary system.

The Boards of Directors of the various companies of the Group have appointed a Supervisory Body (SB), which is entrusted with the task of supervising the correct functioning of the Model and of updating it. The Supervisory Board is obliged to report every six months to the Board of Directors and the Board of Statutory Auditors.

The persons specifically identified and appointed to implement the model are required to report to the Supervisory Bodies of PHOENIX Pharma Italia and its subsidiaries, both on a routine basis (every six months) and, in the most urgent cases, as promptly as possible.