General documents

Model 231 and plan for corruption prevention and transparency

The regulation of the "Administrative responsibility of legal persons, societies and associations with or without legal personality" is contained in legislative decree no. 231 of 8 June 2001 and provides that associations can be held responsible, and therefore subject to penalties and/or interdiction orders, for certain crimes committed or attempted in their own interest or advantage.

With respect to this form of responsibility, the "Model of organization, management and control" (hereinafter "Model 231") has been adopted by SIAE as a justification, since societies can be exempted from liability subject to the adoption of a model of organization, management and control suitable to prevent major offences and the institution of a Control Body responsible for monitoring its functioning and updating.

Model 231 has been adopted by SIAE following a decision of the Management Board of 6 April 2006, in compliance with the provisions of Legislative Decree no. 231 of 8 June 2001. SIAE also appointed a Control Body with a collegiate composition having the task of supervising the effectiveness and adequacy of Model 231.

Due to subsequent amendments to Legislative Decree 231/2001 (which included further major offences to those under analysis at the date of its adoption) and in consideration of the significant modifications in the business reality of SIAE, implying substantial organizational changes thereto, a first update of Model 231 was deemed necessary in April 2011 and a further one in 2014.

In order to guarantee the maximum effectiveness of the prevention activity, information flows have been provided towards the Control Body and from the Body towards the Society’s top management.

On drawing up Model 231 and, in particular, on the updating activity therof, SIAE particularly focused on: (i) the "Guidelines for building organizational, management and control models ex Leg. Decree 231/2001", issued by Confindustria in March 2002 and lastly updated in July 2014; and (ii) the Position Paper "Administrative responsibility of societies: organizational models of prevention and control" of the Italian Association of Internal Auditors (AIIA).

The current Model 231 is composed of: (i) a General Part, describing the contents of Legislative Decree 231/01.
It briefly illustrates the models of corporate governance and organization and management of the Society, the general operating principles of the Model, as well as the list of sensitive processes pursuant to Leg. Decree 231/01, with the indication of the relevant categories of offences; (ii) seven Special Parts, describing, for each category of offence relevant for the Society, the areas of the Society’s activities subject to potential “231” risk, the behavioral principles to comply with for risk prevention and the specific control protocols aiming at mitigating the risk of crime commission; (iii) a further special part called "SIAE Plan for corruption prevention and transparency". Its update was approved by the Management Board on 20 May 2015 and adopted by the Supervisory Board on 25 June 2015. As expressly requested by the Society, it constitutes a special part of Model 231, allowing also to address the needs for contrasting corruption phenomena relevant for the purposes of the principles established by the Anticorruption Law no. 190 of 6 November 2012.

These principles and contents of Model 231 are addressed to:

  1. Managers and internal staff: the members of the Governing Bodies, the Managing Director, the management and all those performing management, administration, direction or control tasks in the Society, the employees of the Society;

  2. Contractual counterparties: external subjects operating by mandate or assignment (agents, field agentesentrusted by the Society) and/or contributing to performing SIAE’s activities, such as suppliers of goods and services, advisors, partners in temporary associations or societies SIAE shall work with;

  3. Other external subjects: human resources (permanent and/or temporary) supporting the subjects mentioned above, with specific reference to agents and field reference entrusted by SIAE, using its name in their support activity, under the responsibility of the same agents or authorized subjects.

The whole documentation is made up with: (i) the Risk Assessment 231 document; (ii) the Master Plan of corrective actions; (iii) the list of the offences provided by Leg. Decree 231/01; (iv) the regulations of the Control Body.

With reference to health protection and workplace safety introduced by the Leg. Decree no. 81 of 9 April 2008, on 31 October 2013 the Risk Prevention and Protection Service of SIAE obtained the certification by an accredited certification body for the compliance of its Workplace Safety and Health Management System (Sistema di Gestione della Sicurezza e della Salute sul Lavoro - SGSL) with the BS OHSAS 18001:2007 standard.
The certification has a validity of three years and has been the final acknowledgement of a series of activities aiming not only at ensuring a punctual fulfilment of all the legal requirements, but also at introducing a structured organization suitable to implement the most appropriate health and safety policy.

According to the above mentioned standard and pursuant to art. 30 of Leg. Decree 81/2008, the adoption of this SGSL System is particularly useful for guaranteeing the exemption from the administrative responsibility of the Society pursuant to Leg. Decree 231/2001, with reference to offences committed in violation of accident prevention regulations.


- General Part

       - Ann. 1 Major offences

       - Ann. 2 Control Body Regulation

- Special Part A - Public Administration and obstruction of justice

- Special Part B - Cyber-crimes

- Special Part C - Corporate Crimes

- Special Part D - Health and Safety

- Special Part E - Receiving stolen Goods, Money Laundering anf Forgery

- Special Part F - Environmental Crimes

- Special Part G - Employment of illegal citizens

Special Part - Plan for corruption prevention and transparency (updated to 31 January 2019)


Code of conduct

The "Code of Conduct", or "Code", regulates the set of rights, duties and responsibilities towards whoever enters into a steady business relationship with SIAE.
Everybody working for SIAE shall be considered as an addressee of the Code, including the members of the governing bodies, all the staff (executives included), the agents, field adgents, advisors and collaborators on a regular basis who, participating in the Society’s activity, operate on behalf of SIAE or in the name and on behalf of SIAE.
The "Code of Conduct" has been drafted also with a view to the implementation of the provisions of Legislative Decree no. 231 of 8 June 2001.

Download SIAE's Code of Conduct