CONTACTS
SOCIAL MEDIA
Email: info@gruppoantonini.it
Telephone: +39 0187560746
Email: nautica@gruppoantonini.it
Telephone: +39 337225431
MODEL 231
Legislative Decree No. 231/2001 (the "Decree") introduced a new form of liability, Administrative Liability, which applies to Legal Entities (the "Companies") in the event of crimes committed by their directors, employees, or representatives during the performance of activities carried out in the name and on behalf of the Companies. The Decree provides that Companies can be exempted from this liability if they can demonstrate that they have adopted and effectively implemented an organizational, management, and control model (the "Model") that is effective in preventing the commission of crimes.
Antonini Group S.p.A. has developed a Model in compliance with the provisions of the Decree. The Antonini Group's Model consists of a General Part, which outlines the reference principles upon which the entire Model is based, and 13 Special Parts. Additionally, the Model includes the following attachments: risk analysis and "gap analysis," the disciplinary system, the Code of Ethics, the Statute of the Supervisory Body (OdV), the Procedure for Managing Information Flows, and the Whistleblowing Procedure.
Gruppo Antonini S.p.A. Registered Office: Via Enrico Fermi 7 - 54026 Groppoli (MS) Italy - VAT NUMBER IT00364890459
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CODE OF ETHICS AND CONDUCT
The Company adopts this Code of Ethics as a "charter of fundamental rights and duties," through which the Entity defines and clarifies its responsibilities and ethical commitments towards both internal and external stakeholders, as well as an integral part of the organizational, management, and control model provided by Article 6 of Legislative Decree 231/01 regarding the administrative liability of Entities (hereinafter "Model"). The Code of Ethics binds the corporate bodies, management, employees, external collaborators, business partners, suppliers, and all those who engage in relationships with the Company.
The Code of Ethics serves a legitimizing function, as it outlines the duties and responsibilities of the Entity towards its stakeholders. Furthermore, it has a cognitive function, as it enables the recognition of unethical behaviors and provides guidance on the correct ways of exercising the functions and powers assigned to each individual, through the enunciation of abstract and general principles and behavioral rules. The Code of Ethics also serves a preventive function, as the codification of ethical principles and fundamental behavioral rules constitutes an explicit declaration of the Entity's serious and concrete commitment to ensuring the legality of its activities, with particular emphasis on preventing unlawful acts. Finally, the Code has an incentivizing function, as by enforcing adherence to the principles and rules contained therein, it fosters the development of an ethical consciousness and strengthens the Entity's reputation and the trust relationship with stakeholders. Similarly, adherence to the principles of the Code is crucial for the reputation of management and employees.
WHISTLEBLOWING REPORTING
The Company provides whistleblowers with an internal written channel through a digital platform called varWhistle, which is accessible to anyone via the corporate website at www.gruppoantonini.it under the "whistleblowing reports" section in the website footer.
This tool ensures, from a technological standpoint, the confidentiality of the whistleblower, the individuals mentioned in the report, and the report's content.
The digital channel can be accessed via the link at the bottom of the page. Before entering the platform, whistleblowers must review the corporate whistleblowing procedure and the privacy notice on personal data processing.
The channel offers two possible reporting methods:
Anonymous Reporting: The whistleblower submits a report anonymously.
Signed Reporting: The whistleblower submits a report under their name.
To ensure the effective handling of the report, whistleblowers are encouraged to act in good faith and provide all useful details to facilitate verification of the facts, including any available supporting documents that can be digitally attached to the report.
Whistleblowers can use an appropriate form to enter information about the reported facts and upload any supporting documentation, either as individual files or compressed into a zip file containing one or more files or folders.
The report must be based on precise and consistent elements that lead the whistleblower to have a reasonable suspicion of the truthfulness of the matter being reported.
Therefore, whistleblowers are requested to:
At the end of the reporting process, the whistleblower will receive a unique 10-character alphanumeric code, which can be used to access the report and engage in two-way communication with the recipient, exchange messages, and submit additional information.
All information on the platform is encrypted and can only be accessed by authorized personnel.
The whistleblower cannot modify the data of a submitted report. However, it is possible to supplement it by retrieving the report using the unique code and submitting additional information via appropriate user messages, with the option to attach files.
Through the digital channel, the Report Manager can communicate with the whistleblower in complete confidentiality, confirming receipt of the report, requesting additional information or documents, and providing feedback on the actions taken or planned regarding the report.
GRUPPO ANTONINI is committed to analyzing reports submitted in any language.
Reports submitted through the digital channel are received by the Report Recipient as defined in the procedure.
If the report concerns the Report Recipient, the whistleblower must use postal mail (as outlined in paragraph 6.1, item 2 of this procedure) and address it to the Supervisory Body.
The Supervisory Body will perform the duties assigned to the Report Recipient, acting as the Report Recipient for the specific case.
The Designated Function handles all interactions with the whistleblower (if identified) and the subject of the report, fulfilling the requirements set out in the corporate whistleblowing management procedure.
Before submitting a report, please review the following documents:
Privacy Notice on Personal Data Processing
Thank you for your commitment to fostering an ethical and responsible corporate environment.
Access the digital channel to submit your report by clicking the link below: