Cefla acts following a code of conduct based on some important key values that have characterized the whole company’s lifetime.
With the introduction of Legislative Decree 231 of 8 June 2001, and subsequent amendments and additions thereto (“Decree 231”), Italian law attributes criminal liability to companies for offences contemplated expressly by the decree and committed by their directors, employees or other agents, where such corporate crime is committed in the interests or to the advantage of the company. Such liability can give rise to administrative sanctions, fines, disqualification orders and seizures. Under the provisions of Decree 231, a company is relieved from liability in the event of an offence if the company in question has effectively implemented specific compliance measures designed to prevent and detect wrongdoing. The effective implementation of a compliance programme, as an integral part of a general system of rules and procedures governing the organization, management and control of the company, must be assured by an independent supervisory body with decision-making and oversight powers. Besides relieving a company from criminal liability, the adoption and effective implementation of a compliance programme also helps improve internal control and encourages a corporate culture to take root built on the principles of transparency, ethical practice, fairness and respect for rules, underscoring the good reputation of the company and strengthening the trust of all stakeholders, be they customers, suppliers, employees or associates in general.
Cefla s.c. duly has in place a corporate compliance programme, known by the Italian acronym ‘MOG’, in accordance with Legislative Decree 231 of 8 June 2001. The compliance programme was approved by the Board of Directors on 28 October 2013. Cefla adopted the MOG with a view to spreading and consolidating a corporate and business culture built on:
- lawfulness, transparency, ethical practice, fairness and respect for rules;
- oversight of all decision-making, operational and approval processes in corporate and business matters, in full awareness of the legal risks associated with potential wrongdoing.
I principali obiettivi del modello sono:
- to raise awareness of corporate crime among people who work with Cefla (employees, consultants, suppliers, etc.) and request that their practices are fair and transparent at all times within the scope of their dealings with and on behalf of the Company, in keeping with the ethical values and principles that underpin the pursuit of our business, and such as to prevent the risk of the offences contemplated by Decree 231;
- to duly inform those people of the disciplinary measures and/or contractual penalties applicable in the event of a breach of the Company’s rules and procedures, along with the criminal and administrative liability attaching to offences;
- to establish and/or step-up checks and controls on ‘sensitive’ areas so as to enable the Company to prevent or act in a timely fashion to stop any wrongdoing by senior decision-makers and the people under their responsibility or supervision;
- to improve the effectiveness and transparency of corporate transactions and decisions, ensuring that they are always verifiable, documented, proper and appropriate.