Irem Spa

Organisation management and control model

Organisation management and control model

Organisation management and control model


Legislative Decree no. 231 of June 8, 2001 (hereinafter “D.Lgs. 231/2001”), introduces for the first time in Italian Judicial System “administrative liability of legal entities” for offences committed (or attempts to commit offences) in the interest or to the advantage of the company itself, that could be subject to money penalties and/or interdiction.


A company may be responsible for crimes committed in its interest and/or its advantage by:



  • “Individuals in senior positions”: directors, legal representatives, managers, directors of units provided with financial and functional indipendence, persons carrying out “de facto” management or control activities;

  • “Individuals under the command of others”: individuals who are managed or supervised by an individual in a senior position.


However, companies may adopt organizational, management and control models designed to prevent these offences.


In compliance with D.Lgs. n. 231/2001, the Board of Directors of IREM S.p.A. has approved for the first time, at the meeting of june 29th, 2012, the organizational, management and control Model pursuant to D.Lgs. n. 231/2001 (also in accordance with the guideline developed by the Trade Associations - Confindustria).


This Model is composed by:



  1. Organization Management and control Model (General and Special sections)

  2. Attachments:

    • List of Offences 

    • Code of Ethics

    • Risk Assessment

    • Disciplinary System 

    • Supervisory Body charter




On September 23rd, 2015, the Board of Directors has adopted the updated Model (included its Attachments). This updating has been requested by the recent introduction of new offences into D.Lgs. n. 231/2001 concerning:



  • Employment of third-country employee whose illegally staying;

  • New Environment crimes (environmental pollution, environment disaster, culpable crimes against the environment, Trafficking and abandonment of highly radioactive substances, aggravating circumstances);

  • New Corporate Offences (private bribery, false statement in/of account);

  • Self- money laundering.

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