In 2010, The Compagnia di San Paolo chose to adopt the Organizational, Management and Control Model as provided for by Italian Legislative Decree 231/2001, containing “Provisions on the administrative liability of legal persons, companies and associations, including those without legal personality”.
The Compagnia’s so called Operating Bodies adopted the same Model; one Surveillance Body is responsible for monitoring compliance. The Model contains a thorough analysis of the risks the Compagnia’s activity is potentially subject to and states the procedures set up to manage them .
The adoption of the Model is also aimed at developing a common management approach as well as at promoting a shared system of rules of conduct, regulations and procedures within both the Compagnia and its Operating Bodies.
In parallel with the implementation of the Model, self-audit mechanisms were put in place in order to monitor the correct functioning of the control system in its various articulations and to support its continuous improvement, especially thanks to the constant analysis of the actual effectiveness of processes and procedures. Consequently, the Model has been reviewed from time to time in order to preserve its effectiveness and appropriateness as regards internal and external change. In this, suggestions from the Surveillance Body have proved valuable.
The Model includes the Rules of conduct to be followed by the Compagnia and its Operating Bodies in reaching their goals; these rules must be observed by all Target Recipients of the Model, both inside and outside the Compagnia and its Operating Bodies.
Herewith is attached the updated version of the Model (latest review approved by the Management Board of the Compagnia July 9th 2018).