ORGANISATIONAL AND MANAGEMENT MODEL (OMM)
Pursuant to Legislative Decree 231/2001, the Organisational and Management Model (OMM) is a structured and organic system of prevention, dissuasion and control, aimed at:
- developing awareness, among the individuals who directly or indirectly operate in the context of sensistive activities, (directors, managers, employees and others working with the Company) of the potential for an offence to be committed, and
- protecting the Company against Corporate Administrative Liability.
As part of its corporate reorganisation process and of the broader range of initiatives aimed at strengthening aspects of its idenitty, values and corporate governance, the UGF Group decided to launch a project aimed at setting up a new Organisational and Management Model.
This Model, which was approved by the Board of Directors of 19 March 2009, consists of a 'General Section' and individual 'Special Sections' drawn up for the various categories of offences identified in the Decree.
The 'General Section' contains an introduction dediated to explaining the structure of the Decree and its applicability to the insruance and banking sectors, as well as the general rules and principles of the Model.
The 'Special Sections' provide and explanation of the rules for the various categories of offences, giving examples of the relevant conducts, sensistive activities within the Group's companies and the monitoring and control tools adopted by the Company.
The task of overseeing the operation of the OMM and compliance with it, and ensuring that it is updated, is assigned to a Supervisory Body, which is currently made up of three members of the Internal Auditing Committee, the Head of Legal Corporate Affairs and Compliance and the Head of the Internal Audit Department.
Each company in the Group has adopted its own Model and identified its own Supervisory Body, pursuant to the guidelines supplied by the Parent Company.
OMM