Model 231 forms an integral part of Mercitalia Intermodal SpA Internal Control System and, in addition to the regulatory requirements of Legislative Decree no. 231/2001, has been drawn up in accordance with the “Guidelines for constructing the organisation, management and control models pursuant to Legislative Decree No. 231/2001” issued by Confindustria. The Model represents the set of rules, procedures, protocols and organisational measures enacted by Mercitalia Intermodal SpA to prevent the risk of the offences referred to in Italian Legislative Decree no. 231/2001.

Moreover, as set out in Legislative Decree 231/2001, Mercitalia Intermodal SpA entrusted the task of supervising the effectiveness of Model 231 to a “Supervisory Board” endowed with autonomous powers of initiative and control and characterised by: “ the professionalism - independence - continuity of action”. The Body is appointed by the Board of Directors and reports to the Corporate Bodies (Managing Director, BoD and Board of Auditors) on implementation of the Model and the detection of any critical issues related thereto, for the purpose of its timely adaptation.

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