Ingeo Progetti Adopts the 231 Model and the Code of Ethics: Strengthened Governance and Legal Compliance Framework

Ingeo Progetti Srl takes a further step in consolidating its governance system by adopting the Organizational, Management and Control Model pursuant to Italian Legislative Decree No. 231/2001 (the “231 Model”) and the Company Code of Ethics.

This decision reflects the Company’s commitment to ensuring increasingly high standards of fairness, transparency and accountability in the conduct of its business activities, safeguarding its reputation, the expectations of its collaborators and partners, the work of its employees, and all stakeholders with whom Ingeo Progetti interacts.

A Structured Prevention and Control System

The 231 Model adopted by Ingeo Progetti Srl consists of:

• General Part, which defines the implementing principles of Italian Legislative Decree No. 231/2001 and the operating rules of the internal control system;
• Special Part, which identifies the relevant categories of offences and the sensitive activities identified through risk assessment, providing specific control measures for the prevention and mitigation of risk;
• Code of Ethics, which establishes the values, principles of conduct and behavioural guidelines that must guide all corporate activities.

The General Part also regulates the functioning rules of the corporate system and the disciplinary system, which provides for specific sanctions applicable to all recipients of the Model, in compliance with applicable employment law provisions.

The Special Part groups offences into homogeneous categories and, for each of them, identifies risk areas and the related organizational and procedural control measures, thereby strengthening the internal prevention framework.

Establishment of the Supervisory Body

To support the effective implementation of the 231 Model, the Board of Directors has resolved to establish a Supervisory Body (Organismo di Vigilanza – “OdV”), composed of three independent external professionals.

The Supervisory Body is entrusted with overseeing the proper functioning, effectiveness and updating of the 231 Model and the Code of Ethics, ensuring an autonomous and qualified control function.

Legality and Ethics as Strategic Drivers

The Code of Ethics represents the Company’s core value framework: it defines the principles of integrity, responsibility and legality that must inspire strategic thinking and operational management.

The 231 Model and the Code of Ethics share a common objective: preventing improper conduct and promoting a corporate culture based on transparency, fairness and compliance with applicable laws and regulations.

Document Consultation

The General Part of the 231 Model and the Code of Ethics are available at the following links:

• M.O.G.
• Code of Ethics

Through this initiative, Ingeo Progetti reaffirms its commitment to high standards of compliance and governance, strengthening its reliability towards the market and all stakeholders.