Organisational and Management Model (OMM)
In the context of a structured and organic system for prevention, deterrence and control, each Group company has adopted an Organisation and Management Model, respecting the guidelines of the Parent Company.
Pursuant to Legislative Decree No. 231/2001, the Company’s Organization, Management and Control Policy has been drawn up as a structured and harmonized prevention, dissuasion and control system aimed at:
- raising the awareness of people who, either directly or indirectly, work in sensitive areas (directors, managers, employees and collaborators) that they may be liable to committing an offence;
- preventing or limiting the Company’s administrative liability.
This Policy, which was most recently updated by the Board of Directors on 4 August 2022, is structured into a “General Part” and individual “Special Parts” regarding the various categories of offences regulated in the Decree. The “General Part” contains an introduction on the Decree and its applicability to the insurance sector, as well as the Policy rules and general principles. The “Special Parts” illustrate rules relating to the various categories of offences, exemplifying conducts, sensitive activities carried out within the Company and the control instruments adopted by the same.
The task of supervising the operation of and compliance with the Organization, Management and Control Policy and ensuring its updating has been entrusted to a Supervisory Body (SB) comprising five members identified as follows:
- all members of the Control and Risks Committee, independent non-executive directors;
- additional member(s), i.e. one / two third-party professional(s) with adequate professional skills and expertise or a member of the company’s senior management in charge of the Audit Department or of the Compliance and Anti-Money Laundering Department.