Supervisory Body pursuant to Legislative Decree 231/2001
Italian Legislative Decree 231/01 prescribes the establishment of an internal Supervisory Body (hereinafter also SB) with independent powers of initiative and control whose duty is to supervise the functioning of and compliance with the Organization and Management Model and to ensure its updating.
The functions of the Supervisory Body of UniCredit SpA, pursuant to Legislative Decree 8 June 2001, n. 231, have been attributed to the Board of Statutory Auditors.
Organization and management Model pursuant to Legislative Decree 231/2001
Legislative Decree No. 231 of June 8, 2001 states the administrative liability of incorporated and non-incorporated bodies, companies and associations (entities). This liability is very similar to the criminal liability because it's not linked to the person committing the illegal conduct (entities are liable even if the person liable can't be prosecuted or has not been identified).
Entities can be liable as per L.D. 231/01 if:
a) senior managers, directors or people working under their guidance and supervision commit any of the crimes listed into the special part of the Decree;
b) the offence is committed for the benefit or in the interest of the entities themselves.
Entities may be exempted from liability if they prove that they have adopted and effectively implemented models of organization and management suitable to prevent the commission of the offences covered by the decree.
In this context, UniCredit SpA has adopted an Organization and Management Model that describes the methodology used to manage the risks pursuant to Legislative Decree 231/2001, the composition and role of the Supervisory Board and the internal disciplinary system.
The "Code of Ethics pursuant to Legislative Decree no. 231/2001" is an integral part of the Organization and Management Model, and contains rules intended to ensure that the conduct of the Addresses are always guided by principles of fairness, collaboration, loyalty, transparency and mutual respect, as well as to avoid conducts that could constitute the offences and crimes set forth in Italian Legislative Decree 231/01.