Ethics and Transparency
Transparency, correctness and legality are the values that inspire the work of Autostrada Pedemontana Lombarda. In line with these principles, in 2007 the Company adopted a Code of Conduct and, in 2008, it brought its organisational structure in line with Legislative Decree No. 231/2001, preparing internal mechanisms to identify the liabilities of employees and collaborators, should any unlawful acts be committed.
Organisation, Management and Control Model pursuant to Legislative Decree No. 231/2001 headed “Rules governing the administrative lability of legal entities, companies and associations without juristic personality as well, pursuant to Article 11 of Law no. 300 of 29 September 2000”: it has introduced for the first time in the Italian legal system the administrative liability of entities, which are accountable before the criminal jurisdiction if a manager, employee or collaborator has committed an unlawful act in the interest or on behalf of the Company. In doing so, the entity is obliged to adopt an organisational model that lays down codes of conduct and codes for planning the decision-making activity and, simultaneously, equip itself with an autonomous and independent supervisory body (Supervisory Board), which monitors due compliance with them.
Rules governing the administrative liability of legal entities, companies and associations without juristic personality as well
On the 24 July 2007, Autostrada Pedemontana Lombarda therefore approved the “Organisational Model pursuant to Legislative Decree No. 231/2001”, to ensure maximum transparency, correctness and traceability of actions undertaken by employees, collaborators and whoever deals on any ground with the Company. It also equipped itself with a Supervisory Board and developed an internal operating manual - the Procedures Manual - which establishes a structured and organic system of procedures and monitoring activities aimed at the prevention of unlawful acts. In this way, the Company intends to reaffirm its strong condemnation of all types of behaviour that is illegal, contrary to legal provisions and, above all, to the ethical principles it intends to abide and mould itself by and while carrying out the company’s activity.
Code of Ethics
Autostrada Pedemontana Lombarda is committed to adopting a series of rules to ensure conditions of correctness and transparency in the company's activities, to safeguard the image of the Company itself, the expectations of shareholders and the work of its own employees and collaborators. For this purpose, it has drawn up the Code of Ethics, approved on 24 July 2007, whose aim is the prevention of the crimes expressly envisaged by Legislative Decree No. 231/2001.
The Code of Ethics, which is an essential part of the Organisational Model, identifies the values that make up the Company’s ethical references (based on “absolute honesty, loyalty, good faith, balance correctness and diligence, collaboration and transparency”) and the guidelines that should inspire all the individuals, including the respective collaborators, that interact in any capacity with Autostrada Pedemontana Lombarda.
The rules contained in the Code of Ethics, therefore, regulate both the Company’s internal administrative-financial system and its dealings with third parties, whether they are employees, customers, suppliers, public administrations, political and trade union organisations or media.
It is for the Supervisory Board to ensure compliance with the Code of Ethics.
The Organisational Model and the Code of Ethics have been updated over time. The most recent update took place by resolution of the Board of Directors on 10 February 2014.