Organization, Management, and Control Model
Legislative Decree no. 231/2001 introduced a regime of administrative liability into the Italian legal system for companies regarding certain offenses committed (or attempted) by directors, employees, and individuals subject to the company’s direction or supervision, when such actions are carried out in the interest or to the benefit of the company itself. This liability is in addition to the personal criminal liability of the individual who committed the act.
However, Legislative Decree 231/2001 provides an exemption from liability if the company can demonstrate that, prior to the commission of the offense, it had adopted and effectively implemented Organization, Management, and Control Models suitable for preventing such crimes.
SPM Drink Systems Spa has adopted its own Organization, Management, and Control Model (the “Model”) and has established a Supervisory Body. The Model not only allows Electrolux Professional Spa to benefit from the safe harbor provisions provided by the Decree, but also improves corporate governance by ensuring fairness and transparency in the conduct of business operations.
The Electrolux Professional Group’s Policies, Directives, and Guidelines (within which the Code of Conduct plays a fundamental role) are an integral part of the Model. This framework also includes all procedures and specific "prevention protocols" designed to prevent the commission of the offenses outlined in Legislative Decree 231/01. Furthermore, a disciplinary system has been established, structured according to the various categories of stakeholders subject to the Model, to penalize any failure to comply with the Model itself.
The Supervisory Body is responsible for monitoring the correct application and overall effectiveness of the Model.
Any violations of the Model or the Code of Conduct may be reported to the Supervisory Body in accordance with the procedures set forth in the “Whistleblowing” management policy detailed below: