Pursuant to the Italian provisions on the “administrative liability of legal entities deriving from offences” contained in Legislative Decree no. 231 of June 8, 2001, legal entities – including limited companies – may be held liable, and consequently subject to money penalties and/or interdiction, for any offences committed or any attempts to commit offences – in Italy or abroad – in the interest or to the advantage of the company itself:
by individuals who are representatives, directors or managers of the company or of one of its organizational unit that has financial and functional independence, or by individuals who are responsible for managing or controlling the company (individuals in apical positions or “apicals”);
by individuals who are managed or supervised by an individual in an apical position (individuals under the command of others).
In this regard, the Board of Directors of HB Trading S.p.A. approved the organizational, management and control Model pursuant to Legislative Decree no. 231 of 2001 (“Model 231”) at the meeting of January 3, 2012, and updated it by resolution of October 29, 2014.
Organizational, management and control Model download pdf at the end of the page
HB Trading S.p.A. has also adopted a Code of Ethics: the Code is, among other things, a compulsory general principle of Model 231. The Code of Ethics includes the principles upon which HB Trading S.p.A. bases its work.
Code of Ethics download pdf at the end of the page
HB Trading S.p.A. assigned to an established Supervisory Body (“Organismo di Vigilanza”), with autonomous proposal and monitoring powers, the task to monitor the implementation, adherence to and updating of the Model 231.
The Supervisory Body shall be informed by the parties subject to compliance with Model 231 about any events that may cause responsibilities of HB Trading S.p.A. pursuant to Legislative Decree no. 231 of 2001. Each manager or employee shall report any behaviour which is not in line with the principles and contents of Model 231, contacting the Supervisory Body; consultants, collaborators and business partners, shall report on their activity carried out for HB Trading S.p.A. directly to the Supervisory Body.