The Poste Italiane Group bases its actions on fairness, integrity, transparency, reliability, sustainability, and responsibility, translating the appreciation of these values that characterise the way the company operates into a competitive advantage.
REGULATORY CONTEXT
Italian Legislative Decree no. 231 of 8 June 2001 introduced into Italian law a system wherein entities — including corporations — are liable for certain crimes committed by directors, managers, or employees in the interest or to the advantage of the entity.
THE ADOPTION OF THE ORGANISATIONAL MODEL
Since 2003, Poste Italiane has adopted its own Organisational Model, which is continuously updated in line with regulatory, organisational, and business developments, with the aim of building a structured and organic system of guiding principles, operating procedures, and other specific safeguards inspired by sound business management criteria and aimed, in line with the company's purpose, at preventing the commission of the crimes set out in the Decree, as well as protecting the interests of stakeholders relevant to the company itself.
The Model consists of a General Section and Special Sections, each of which relates to a class of crime relevant to the Company. The General Section describes the contents explicitly required by Italian Legislative Decree 231/2001 (e.g. the law, the Company's governance, the Supervisory Board, training/information activities, the sanctions system, etc.) and the Company's integrated internal control and risk management system (the Company's Regulatory System, the Group's Code of Ethics and Policies, the Corporate Governance System), which are adapted to Poste Italiane's specific corporate situation. The individual Special Sections outline, according to a logic based on processes, the different types of crimes actually and potentially relevant to the company, as well as the company processes, sensitive activities, rules of conduct and specific control principles analysed for each class of crime.
In Poste Italiane's Model 231, sustainability issues are also of significant importance, in line with the Company's current strategic direction and in consideration of the correlations and synergies between them and Decree 231. The 231 Model is a tool which, through the identification of specific control measures to prevent the commission of crimes attributable to Decree 231, also helps support the Company to achieve the objectives included in the 8 Pillars of the ESG Strategic Plan, as well as in implementing the issues relating to the ESRS standars relevant to the Poste Italiane Group.
At Group level, Poste Italiane encourages each subsidiary to implement its own Organisational Model.
SUPERVISORY BOARD
Poste Italiane has entrusted a Supervisory Board (composed of two members from outside the Company — Carlo Longari, as Chairman, and Massimo Lauro, and an internal member, the Head of the Internal Control Function, Paolo Casati) with the task of monitoring compliance with the provisions of the Organisational Model, verifying their actual effectiveness and assessing the need for any updates. The Supervisory Board's term of office is three years, until September 2025.
REGULATORY CONTEXT
Italian Legislative Decree no. 231 of 8 June 2001 introduced into Italian law a system wherein entities — including corporations — are liable for certain crimes committed by directors, managers, or employees in the interest or to the advantage of the entity.
THE ADOPTION OF THE ORGANISATIONAL MODEL
Since 2003, Poste Italiane has adopted its own Organisational Model, which is continuously updated in line with regulatory, organisational, and business developments, with the aim of building a structured and organic system of guiding principles, operating procedures, and other specific safeguards inspired by sound business management criteria and aimed, in line with the company's purpose, at preventing the commission of the crimes set out in the Decree, as well as protecting the interests of stakeholders relevant to the company itself.
The Model consists of a General Section and Special Sections, each of which relates to a class of crime relevant to the Company. The General Section describes the contents explicitly required by Italian Legislative Decree 231/2001 (e.g. the law, the Company's governance, the Supervisory Board, training/information activities, the sanctions system, etc.) and the Company's integrated internal control and risk management system (the Company's Regulatory System, the Group's Code of Ethics and Policies, the Corporate Governance System), which are adapted to Poste Italiane's specific corporate situation. The individual Special Sections outline, according to a logic based on processes, the different types of crimes actually and potentially relevant to the company, as well as the company processes, sensitive activities, rules of conduct and specific control principles analysed for each class of crime.
In Poste Italiane's Model 231, sustainability issues are also of significant importance, in line with the Company's current strategic direction and in consideration of the correlations and synergies between them and Decree 231. The 231 Model is a tool which, through the identification of specific control measures to prevent the commission of crimes attributable to Decree 231, also helps support the Company to achieve the objectives included in the 8 Pillars of the ESG Strategic Plan, as well as in implementing the issues relating to the ESRS standars relevant to the Poste Italiane Group.
At Group level, Poste Italiane encourages each subsidiary to implement its own Organisational Model.
SUPERVISORY BOARD
Poste Italiane has entrusted a Supervisory Board (composed of two members from outside the Company — Carlo Longari, as Chairman, and Massimo Lauro, and an internal member, the Head of the Internal Control Function, Paolo Casati) with the task of monitoring compliance with the provisions of the Organisational Model, verifying their actual effectiveness and assessing the need for any updates. The Supervisory Board's term of office is three years, until September 2025.