Pursuant to the Italian regulations on the “administrative liability of legal entities deriving from offences” contained in Legislative Decree No. 231 of 8 June 2001 (hereinafter “Legislative Decree No. 231 of 2001”), legal entities – including limited companies – may be held liable, and consequently subject to financial penalties and/or interdiction, for any crimes committed or any attempts to commit crimes – in Italy or abroad – in the interest or to the advantage of the companies themselves: – by individuals who are representatives, directors or managers of the company or of one of its organizational units that has financial and functional independence, or by individuals who are responsible for managing or controlling the company; – by individuals who are managed or supervised by an individual in a top position (individuals managed by others).

Companies may adopt organizational, management and control models designed to prevent these crimes. In this regard, All Services Srl adopted the Organization, Management and Control Model pursuant to Legislative Decree No. 231 of 2001.

All Services appointed a Supervisory Body (“Organismo di Vigilanza” or “ODV”), entrusted with “independent powers of initiatives and control” pursuant to Article 6, paragraph 1, letter b) of Legislative Decree No. 231 of 2001. OdV shall be informed by the parties subject to compliance with Model 231 about any events that might give rise to liability for All Services. pursuant to Legislative Decree No. 231 of 2001.

The dedicated e-mail of ODV is  odv@comeritaly.com

The identification of corporate activities which may entail the risk of commission of the offences provided for by Legislative Decree No. 231 of 2001 (“Sensitive Activities”) is the result of corporate process analysis. Each Sensitive Activity is associated with a reference person for individual corporate processes (Key Officer), as well as existing operational and management conditions and existing control factors.

The following documents are available upon request:

• Model 231 General Section
• Code of Ethics
• Whistleblowing Policy

The Special Part documents, including the risk assessment document, are filed at the registered office.