MODEL 231 and CODE OF ETHICS

Organisation and Control Model pursuant to Legislative Decree 231/2001

ORIM is sensitive to the need to ensure conditions of fairness and transparency in the conduct of business and corporate activities, to protect its own position and image, the work of its employees and the expectations of its stakeholders, and is aware of the importance of having an internal control system capable of preventing the commission of unlawful conduct by its directors, employees, collaborators and business partners. The Company adopts the organisation and management model with the awareness that an efficient and balanced organisation of the company, suitable for preventing the commission of offences, is pursued by intervening, mainly, on the processes of formation and implementation of the Company's decisions, on controls, preventive and subsequent, as well as on information flows, both internal and external.

Through the adoption of the Model, ORIM intends to specifically pursue the following main purposes

  • to sensitise all those who work in the name and on behalf of the Company to a corporate culture based on legality, and to determine in them the awareness that, in the event of violation of the provisions set out therein, they may incur in the commission of offences punishable by criminal sanctions that may be imposed on them and by administrative sanctions that may be imposed on the Company
  • reiterate that such forms of unlawful conduct are strongly condemned by the Company, since the same (even if the Company were apparently in a position to take advantage of them) are in any case contrary not only to the provisions of the law, but also to the ethical principles to which the Company intends to adhere in the implementation of its mission
  • enable the Company to intervene promptly to prevent or oppose the commission of the offences themselves through the dissemination of a control culture aimed at governing all the decision-making and operational phases of the Company's activities and the provision of monitoring action on the areas of activity at risk.

The Model and the principles it contains apply to the corporate bodies, employees, collaborators, consultants, suppliers, partners and, more generally, to all those who, in any capacity, operate in sensitive activities on behalf of or in the interest of ORIM.

MOG 231_Orim S.p.A._2020 - ABSTRACT (Italian version only)

 

Code of Ethics

The creation and dissemination of the values on which a company bases its ability to be a competitive player in its business sector and a responsible player in the delicate waste management sector in which it operates, are the necessary elements to build a corporate culture that is suitable for the achievement of the objectives that the company sets itself:

  • the provision of services of a high quality standard,
  • the protection of health and safety within the working environment in compliance with applicable regulations,
  • the management of company risks (particularly non-compliance with mandatory or voluntary regulations) such that they do not have a negative impact on the company.

Already in 2002, ORIM S.p.A. defined and formalised the Code of Ethics as a compendium of the rules, values and guiding principles adopted and recognised as having a positive value; today, at the same time as adopting the Organisation, Management and Control Model, it has decided to update it.

The Administrative Body has also deemed it essential to adopt an Organisational, Management and Control Model pursuant to Legislative Decree 231/2001, within the scope of which this Code is included, with the aim of identifying and indicating, with clarity and transparency, the principles and values that inspire the Company's activities.

In fact, it is believed that in order to achieve the Company's statutory purpose and ambitious objectives, it is indispensable that the persons working in the Company and all those who enter into any relationship with it, comply with the rules of conduct that inspire the Company's operations.

The Code, must guide the Company's daily business and work activities in their entirety, in the conviction that the achievement of social goals cannot disregard ethics and absolute respect for legality in the conduct of business activities.

In order to avoid damage to the image, good name, reputation and institutional, economic and commercial relations of the Company, even in the face of ambiguous or potentially risky situations, the Code of Ethics must represent a guide, the knowledge and application of which are essential and dutiful.

Furthermore, this Code, without substituting for the responsibility and actions of each individual according to common sense, is a fundamental element in the prevention of the offences envisaged by Legislative Decree no. 231 of 8 June 2001, and is also prepared pursuant to and for the purposes of the aforementioned regulatory provision, forming an integral part of the Company's Organisation and Management Model.

All persons in an apical position, such as directors, auditors or persons with management functions, as well as all employees, collaborators, consultants and, more generally, all third parties that enter into relations with the Company must never fail to respect fundamental principles such as honesty, moral integrity, fairness, transparency and objectivity in the pursuit of the Company's purposes.

The Company -by providing adequate information, prevention and control tools- guarantees the transparency of the conducts implemented, intervening, where necessary, to repress possible violations of the Code and supervising the actual observance of the Code itself.

 

Code of Ethics ORIM S.p.A. (Italian version only)