The organizational model of the parent company

The Board of Directors of AFV Acciaierie Beltrame spa, in order to ensure the best conditions of fairness, transparency and legality in the conduct of its business activities, has adopted, by resolution of the Board of Directors of 15/12/2008, the Organizational, Management and Control Model in line with the requirements of Legislative Decree No. 231/2001, which regulates the administrative liability of companies for crimes committed by top management or by employees or collaborators in the interest or to the advantage of the company itself.

An integral part of the Organizational Model is the Code of Ethics, approved at the same time as the model itself, which contains the principles and rules of conduct that guide the activities of AFV Beltrame Group.

In view of the fact that the Code of Ethics recalls principles of behavior (including legality, fairness and transparency) that are also suitable for preventing unlawful conduct referred to in Legislative Decree 231/2001, this document acquires relevance for the purposes of the Organizational, Management and Control Model and is, therefore, a complementary element to it.

The purpose of the model is the construction of a structured and organic system of procedures and control activities, such as to allow, thanks to a monitoring action on the areas of activity at risk, to intervene in a timely manner to prevent or counteract the commission of the types of offenses provided for in Legislative Decree 231/2001.

Over the years, the Organization, Management and Control Model has been updated to adapt it to the new crime hypotheses considered by the legislator as prerequisites for the application of Legislative Decree No. 231/2001. The latest update was made on 02/02/2023.

The company has appointed the Supervisory Board, which is in charge of supervising the operation of and compliance with the Organizational Model.

The Supervisory Board has autonomous powers of initiative and control and reports directly to the Board of Directors.