Organization, management and control model (Model 231)
Legislative Decree no.231 of 8th June 2001 (the “Decree”) introduced the principle of administrative liability of Entities for certain offences committed in their interest or to their advantage by persons in a senior position or subject to the management or supervision of these persons.
In order to ensure, as far as possible, the prevention of commission of these offences, the Board of Directors of GSC Group SpA has adopted an organization, management and control model (the “Model”).
The current Model was adopted by the Board of Directors of GSC Group SpA on 06/12/2023.
The Model is part of a broader corporate policy of GSC Group SpA, which seeks to respect ethical principles of management and which has also led to the adoption of the Code of Ethics, always drawn up according to the provisions of the Decree.
A specific sanctioning system, organized and based on the different types of subjects who interact or come into contact with the Company, is provided for in the event of violation of the provisions of the Model.
A special Supervisory Body, appointed by the Board of Directors (“BoD”), has the task of supervising the functioning of and compliance with the Model and the Code of Ethics and of ensuring that they are kept up-to-date.
Any violations of the Model or the Code of Ethics may be reported to the Supervisory Body by post or by e-mail to odv@gscspa.it.
Code of ethics
GSC Group focuses its efforts on improving social performance and reducing environmental impact, and is committed to ensuring compliance with laws, regulations, the most advanced standards and ethical practices for the well-being of people and our planet.
The Codex of Ethic‘s contains all principles our employees, collaborators, customers and suppliers and whoever is in contact with our company has to respect and follow its mandate.
Environment politics
GSC Group recognises the importance of minimising the impact on the environment and the territory and of ensuring health and safety at work. With this in mind, the company is dedicated to continually improving its processes, complying with statutory requirements, adopting a prevention system in relation to these issues, and promoting responsible and sustainable behaviour in everyday life.
Whistleblowing
GSC Group Spa (or “GSC”) In accordance with the provisions of Legislative Decree 24/2023 regarding Whistleblowing, GSC encourages you to report, in good faith, any behavior-whether commission or omission-occurring within GSC Group Spa or in relation to it, which violates (or induces a violation of) applicable regulations, the Code of Ethics, internal procedures, and
principles of social responsibility. GSC has established an internal channel for reporting, which allows submissions in written form (including electronic means) or orally, concerning actual or potential violations that you have become aware of during your employment or service with the company.
In managing these reports, GSC commits to respecting the principles of confidentiality, proportionality, and impartiality. The company recognizes the good faith of whistleblowers and ensures their anonymity. Furthermore, GSC strictly prohibits any form of retaliation, intimidation, or disciplinary action against anyone who makes a good-faith report or
participates in an investigation, even if the reported violation turns out to be unfounded.
The relevant information and reporting procedures are as follows: