Organizational Model and Code of Ethics
Legislative Decree No. 231/2001 has become an integral part of Tema Sinergie S.p.A.’s corporate social responsibility system.
In fact, the company has implemented the following:
- an Organization, Management, and Control Model (known as “MOG”) with the dual purpose of establishing a structured system of procedures and control activities to support management in preventing crimes and in excluding and/or limiting the entity’s administrative liability;
- a Code of Ethics, intended as a complementary document aimed at identifying—with reference to the ethics and values that guide the company—the rights, duties, and responsibilities of all those involved in the company’s operations.
The MOG is an indispensable tool for raising awareness—among all individuals who, directly or indirectly, are involved in sensitive activities—regarding behaviors that may constitute criminal offenses relevant to corporate liability.
Additional objectives of the MOG are to establish and/or strengthen controls and monitoring measures in high-risk areas, to establish a system of sanctions for conduct that violates the aforementioned requirements, and to improve the effectiveness and transparency of corporate operations and decisions, ensuring their documentability, verifiability, and consistency.
The Code of Ethics sets forth the general values and guiding principles that Tema Sinergie S.p.A upholds in the conduct of its business activities and in its relationships with its stakeholders. In addition to setting forth the standards of conduct regarding integrity and transparency that its employees, executives, corporate bodies, and collaborators must adhere to, it establishes the procedures for their implementation and compliance.
A Supervisory Body has been appointed and tasked with verifying the functioning and compliance with the Model, as well as ensuring its ongoing updating, and proposing any amendments and additions deemed necessary from time to time.
Below you can view the latest versions of the Code of Ethics and the Compliance Management System (MOG), as per the most recent revision approved by a resolution of the Board of Directors on May 27, 2024.