Internal control and compliance

The Code of Ethics lays down the principles and values underlying Rekeep S.p.A.’s activities and the conduct of its business, in addition to the set of rights, duties, rules of conduct and responsibilities with respect to all the persons and organizations with whom it enters into a relationship with a view to the attainment of its corporate purpose. The Code is applied and abided by in order to ensure the safeguarding of the surpassing interest of fair conduct of company business at any time.

Code of Ethics

Rekeep S.p.A. has adopted an organizational, management and control model, Model 231, to prevent the commission of criminal offences in the interests of or to the advantage of the company.

Legislative Decree 231 of 8 June 2001 introduced rules on “Corporate liability for unlawful administrative acts resulting from criminal offences” into the Italian legal system, on the basis of which companies may be deemed “liable”, and are therefore punishable, for certain criminal offences committed by representatives of the top management (persons referred to as being in “top positions” or simply “at the top”), and by personnel subject to their management and oversight, in the interests of or to the advantage of the companies themselves.

The Company is not liable, however, if it has adopted organizational, management and control processes and has effectively implemented them before a criminal offence of this type has been committed, if the processes are adequate to prevent such criminal offences and if it has formed a Board responsible for overseeing the functioning and observance of the processes.

Rekeep S.p.A. has adopted the Model 231 and has appointed a Supervisory Board which has independent powers of initiative and control and which has been entrusted with the duties of overseeing the functioning and observance of the process and seeing that it is kept up to date.

Organizational, management and control model under Legislative Decree 231/2001

Composition of the Supervisory Body

Rekeep S.p.A. has adopted an Antitrust Code of Conduct addressed at all its executive, staff and auxiliary resources that clarifies the principles and rules for safeguarding competition and provides guidance on how to behave in situations that could be causes of possible breaches of antitrust regulations.

In order to bring the Group into line with international best practice, an Antitrust Compliance program has been drawn up, which provides for:

  • the adoption of the Antitrust Code of Conduct by the Board of Directors;
  • the appointment of an Antitrust Compliance Manager by the Board of Directors;
  • information and communication initiatives for employees in order to augment the awareness, dissemination and efficacy of the Code of Conduct.
Antitrust Code of Conduct