The General Principles

The Società Ecologica SpA, sensitive to the need to spread and consolidate the culture of transparency and integrity, as well as aware of the importance of ensuring conditions of fairness in the conduct of business and corporate activities to protect one's position and image and of shareholders' expectations, has adopted an “Organization, management and control model” (hereinafter the “Model”) in line with the provisions of Legislative Decree no. 8 June 2001, no. 231 (hereinafter the "Decree" or "Law").

The Company believes that the adoption of this Model, together with the simultaneous issue of the Code of Ethics, constitutes, beyond the provisions of the law, a further valid tool for raising the awareness of all employees and all those who collaborate with Ecologica for various reasons. SpA, in order to follow, in carrying out its activities, correct and transparent conduct in line with the ethical and social values which it inspires in pursuing its corporate purpose, and in any case such as to prevent the risk of committing the crimes contemplated by the Decree.

For the purposes of preparing this Model, Ecologica SpA proceeded with an analysis of its risk areas, taking into account, in drafting it, the provisions of the Decree and the "Guidelines for the construction of organization, management and control models pursuant to Legislative Decree no. . Lgs. 231/2001 "formulated by CONFINDUSTRIA as applicable.

Ecologica spa has adopted its own Organisational model, with the aim of building a structured and organic system of guiding principles, operating procedures and other specific safeguards, inspired by criteria of sound company management and aimed, among other things, at preventing the commission of the offenses provided for by the Decree together with a Code Ethics which constitutes an integral part of the Model

The Organizational Model of Ecologica spa

The Organizational Model consists of:

• of a General Part that identifies the recipients and illustrates the organizational structure, the attribution of powers and the control principles of a general nature. It also contains the regulations of the Supervisory Body and the provisions of the disciplinary system.
• of a Code of Ethics
• of Special Sections that examine the individual types of offense deemed potentially of concrete applicability to the context of Miccolis spa, identifying - on the basis of a periodically updated risk assessment activity - the following sensitive areas:
  • 1. Special Part A – Crimes in relations against the public administration;
  • 2. Special Part B – Corporate Crimes;
  • 3. Special Part C – Crimes committed in violation of regulations protecting health and safety at work;
  • 4. Special Part D – Computer Crimes;
  • 5. Special Part E – Organized Crime Crimes;
  • 6. Special Part F – Crimes against Industry and Commerce;
  • 7. Special Part G – Receiving and Money Laundering Offenses with two Attachments;
  • 8. Special Part H – Inducement not to make statements or to make false statements;
  • 9. Special Part I – Environmental Crimes;
  • 10. Special Part L – Employment of third-country nationals whose residence is illegal;
  • 11. Special Part M – Organizational Structure;
  • 12. Special Part N – Articulation of powers and system of delegations.

Ecologica SpA considers it essential - in the conduct of its business - to comply with current legislation and in particular with the provisions of the aforementioned decree.

To this end, it requires the commitment of each counterparty with whom it establishes commercial, financial and / or professional collaboration relationships, to act in compliance with the rules that govern the sensitive areas identified above and, in general, with current legislation;

Ecologica SpA strongly condemns any conduct aimed at the commission, even if only attempted, of behaviors sanctioned by the decree itself and also considers it essential for the establishment and maintenance of a correct fiduciary relationship with any counterpart that - for whatever reason - comes to collaborate with it, compliance with the behaviors indicated in the Code of Ethics based on transparency and integrity.

Supervisory body

The task of verifying the effective implementation and application of the Model as well as the need for updating was entrusted to a Supervisory Body. All Third Party Recipients, where interested, may address requests for information on the Ecologica SpA Model by ordinary mail to the address:

Supervisory Body of Ecologica SpA
Via delle Mammole n. 26
70026 - Modugno BA

or directly to the e-mail address: odv@ecologicaspa.it The aforementioned address must be used exclusively for the purposes of reporting violations pursuant to the organizational model and the code of ethics of Ecologica SpA using the form attached at the bottom of the page.