D.Lgs. 231/2001

Organisation, management and control model
Costacurta S.p.A.-VICO, aware of the need to ensure correctness and transparency in the performance of its business and the company's activities, has decided to draw up an organisation, management and control model as of Legislative Decree no. 231 of 8 June 2001 (hereinafter for the sake of brevity, also referred to as the "Model") as well as a "Code of Ethics" which forms an integral part thereof.
This decision was taken in the firm belief that the adoption of the Model, besides the requirements of the Decree, which it states are optional and not compulsory, can represent a valid tool for raising the awareness of everyone who operates in the name and on behalf of Costacurta S.p.A.-VICO, so that they follow, in the performance of their activities, correct and linear behaviour such as to prevent the commission of crimes, with special reference to those provided for in the Decree.
In this respect Costacurta S.p.A.-VICO first and foremost highlights that it does not tolerate illegal behaviour, of any type and irrespective of the purpose, as such behaviour, also if Costacurta S.p.A.-VICO could apparently gain advantage, is in any case contrary to the ethical principles with which Costacurta S.p.A.-VICO intends to comply in the pursuit of its corporate mission.
This Model, as set forth in the Decree, was approved by the Company's Board of Directors on 30/03/2018.

Organisation, management and control model as of Italian Legislative Decree 231/2001
General Part
Download the Model

Reports to the Supervisory Board
With the aim of facilitating supervision of the efficacy of the Model, the Supervisory Board can be informed, through specific reports from the Addressees of the Model (executives, directors, employees, suppliers and, more in general, everyone who, for any reason, operates on behalf or in the interest of the Company) about events that could give rise to the responsibility of Costacurta S.p.A.-VICO in accordance with Legislative Decree 231/2001.
These Addressees are entitled to present, in order to protect the integrity of the company, circumscribed reports regarding illegal conduct which is relevant for the purposes of Legislative Decree 231/2001, and founded on precise and concordant facts; that is, reports whose object is the violation of this Model, of which they have become informed of due to the functions carried out.
To this end the company provides the following form to make reports and to protect the identity of the reporting person.

Reporting form
Example of a report

Reporters in good faith will be protected against any form of retaliation or penalisation and they will be guaranteed maximum confidentiality and, in the case of anonymous reports, the anonymity of the reporter will be guaranteed.
The Company has included in its disciplinary system sanctions for whoever makes reports with wilful misconduct or gross negligence that turn out to be groundless.