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, with a resolution dated 15/12/2008, the Organisation, Management and Control Model (hereinafter also ‘Model’) in line with the provisions of Legislative Decree no. 231/2001, which regulates the administrative liability of companies for offences committed by senior management or by employees or collaborators in the interest or to the advantage of the Company itself.

An integral part of the Model is the Code of Ethics, which contains the principles and rules of conduct that guide the activities of AFV Beltrame Group. In consideration of the fact that the Code of Ethics recalls principles of conduct (including legality, correctness and transparency) that are also suitable for preventing unlawful conduct as set forth in Legislative Decree 231/2001, this document acquires relevance for the purposes of the Model and therefore constitutes 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 promptly to prevent or counteract the commission of the types of offences set out in Legislative Decree 231/2001.

Over the years, the Model has been updated to adapt it to the new offence hypotheses considered by the legislator as prerequisites for the application of Legislative Decree No. 231/2001.
The last update was made on 21/02/2025.

The Company has also appointed the Supervisory Board, endowed with autonomous powers of initiative and control, responsible for supervising the operation of and compliance with the Model and reporting directly to the Board of Directors.