On 07 May 2013, the Board of Directors approved the Organisational Model for Self-Control provided for by Legislative Decree 231/2001 as the only exempting instrument for the company in the event of ascertainment of an offence committed by a natural person who is in some way linked to the Cooperative.

The process of constructing the Model, which lasted several months, has primarily ensured substantial compliance with the regulatory requirements, but has been experienced within Codess above all as an opportunity for organizational rethinking, through the involvement of the figures with top management responsibilities, the contribution of the intermediate figures, information to the shareholder structure and the possibility given to the various interlocutors to intervene by reporting any critical issues.

With the construction and adoption of the Organizational Model, in compliance with the provisions contained in Legislative Decree 231/01, Codess Sociale intended to strengthen its system of internal governance, through a tool to encourage correct, transparent and compliant conduct by all those who work on behalf of or in the interest of the Cooperative.

During 2016, the model was completely revised in order to:

  • reconsider the degree of exposure to the risk of offences being committed for the organisation, particularly in the most “sensitive” areas
  • update the Model with respect to the new offences recently introduced by the Legislator contained in Decree 231/01
  • define modifications and improvements, in particular with respect to the possible introduction or elaboration of specific crime prevention measures

As a result of the review of the Organisational Model, training meetings were held in order to raise awareness and make the liaison and coordination roles within the organisation more responsible, in accordance with the requirements of Decree 231/01.
In addition, a specific FAD course was set up to provide all Codess Sociale operators with a basic knowledge of Model 231, especially with regard to the offences that have the greatest impact on the daily management of services and the ways in which they are reported.

The Organizational Model of Codess Sociale aims in particular at:

  • prepare a structured and organic system of prevention and control aimed at reducing the risk of committing crimes connected with corporate activities;
  • to introduce within the organisation controls, provisions and protocols suitable for preventing significant illegal conduct pursuant to Legislative Decree 231/01, while also enhancing those already in existence and in operation;
  • make the ethical principles and rules of conduct adopted by the Cooperative and binding for those who work on its behalf known in a clear and explicit manner to all employees, collaborators, consultants, suppliers and partner organizations;
  • to inform all employees, collaborators, consultants, suppliers and partner organisations of the importance of timely compliance with the provisions and protocols contained in the Model, and also of the existence of disciplinary measures aimed at sanctioning cases of violation of the provisions and protocols themselves;
  • make every effort to prevent the commission of unlawful acts in the performance of corporate activities by means of continuous monitoring of areas at risk, by means of systematic information and training of personnel and by means of measures to prevent and combat the commission of unlawful acts.

The Organizational Model of Codess Sociale does not replace or duplicate, but integrates the other systems and instruments of management and control present in the Cooperative, in particular those operating in the following organizational areas:

  • planning and control;
  • quality;
  • safety in the workplace;
  • social responsibility;
  • food safety;
  • environmental protection;
  • protection of personal data.

In order to facilitate the forwarding of reports to the Supervisory Body by the recipients of the Model who become aware of violations, even potential ones, Codess has activated a dedicated communication channel, namely the e-mail address odv@codess.com