Whistleblowing e Modello 231 – Tutela e trasparenza V73 Venezia

V°73 is produced and distributed by Miriade S.p.A., with registered office at Piazza dei Martiri No. 30 – 80120 Naples – Companies Register, VAT No. 07631370637 and Tax Code No. 03371431218, REA – NA – 610434 (hereinafter referred to as “Miriade”).

Miriade S.p.A. has adopted an Organisation, Management and Control Model (the “Model”) pursuant to Legislative Decree No. 231 of 8 June 2001, in particular Articles 6 and 7 thereof (the “Decree”).

This Decree introduced the administrative liability of legal entities, companies and associations, including those without legal personality. Pursuant to Article 5 of the Decree, the company shall be held liable for offences committed in its interest or for its benefit:

1. by persons who hold positions of representation, administration or management within the entity or within one of its organisational units having independent financial and operational powers, as well as by persons who, even de facto, exercise the management and control of the entity;
2. by persons subject to the direction or supervision of one of the individuals referred to under point 1.

Therefore, in order to avoid any form of liability and to ensure full compliance with the above-mentioned legislation, Miriade has long established a Supervisory Body vested with autonomous powers of initiative and control, responsible for monitoring the functioning and compliance with the Model and ensuring that it is suitable for preventing the commission of the so-called predicate offences.

Based on the documentation acquired and the information received, and in compliance with the requirements and duties set forth under Article 6 of the Decree, this Supervisory Body verifies:

• the adequacy of the Organisation and Management Model;
• the adequacy of measures aimed at eliminating so-called “non-conformities” through corrective and preventive actions;
• the consistency and effectiveness of the powers of attorney and delegations granted by the company;
• the data collected in audit reports and company registers, with particular regard to the preparation of financial statements and statutory audits;
• compliance by company personnel with legal requirements and internal company procedures.

Furthermore, in accordance with the provisions of the aforementioned Article 6 of the Decree, the Supervisory Body is responsible for:

i) monitoring compliance with the Model, as well as compliance with the relevant requirements and information flows by senior management personnel;

ii) monitoring the effectiveness and adequacy of the Model in relation to the corporate structure and its actual ability to prevent the commission of the offences referred to in the Decree;

iii) identifying and proposing to the Board of Directors any integrations, updates and/or amendments to the Model in relation to changes in applicable legislation, changes in business operations and internal organisational structures, or the need to develop, within the company, more effective procedures from a preventive perspective.

The channel, ensuring the utmost confidentiality of the whistleblower’s identity, allows individuals who hold roles involving representation, administration, or management of the organisation, their subordinates, and customers of the various points of sale to submit reports, in order to safeguard the integrity of the organisation:

• detailed reports of unlawful conduct relevant under Legislative Decree 231/2001 and based on precise and consistent factual elements;
• violations of the Organisation and Management Model;
• violations or non-compliance relating to Gender Equality principles, including discriminatory conduct, harassment, or behaviours that are not aligned with the UNI/PdR 125:2022 practice.

The link below allows reports of misconduct and/or violations of the Organisation Model to be submitted anonymously.

Read the complete privacy notice policy.