Etichal Code and Model 231

Allo scopo di rafforzare e migliorare il proprio sistema di controllo Villa Belvedere S.r.l.  ha avviato un progetto diretto all’adeguamento del sistema di prevenzione e gestione dei rischi ispirato sia alle previsioni del D.lgs. 231/2001 sia alle migliori pratiche in materia. Il progetto si è concluso con l’adozione del Codice Etico di Villa Belvedere S.R.T.R.e.

The multidisciplinary team therefore implemented Etichal Code on 05.10.2018 and approved its 231 model on 21.10.2018.

Ethical code

Etichal Code of Villa Belvedere has been developed to clearly define the ethical values ​​of the Structure, which constitute the basic element of the corporate culture, as well as the rules of behavior to be respected in carrying out professional activities and the rules of conduct to follow in relations with guests, suppliers, colleagues, the Public Administration and with all other stakeholders with whom the Villa Belvedere Company interacts.

Model 231

Model 231 responds to specific provisions contained in the Legislative Decree. 231/2001, aimed at preventing the commission of particular types of crimes (for facts which, apparently committed for the benefit of the company, may lead to administrative liability for crimes based on the provisions of the decree itself). Villa Belvedere s.r.l. has also established a Supervisory Body, equipped with autonomous powers of initiative and control, responsible for monitoring the functioning and observance of Model 231 and promoting its constant updating. The Supervisory Body has been assigned, among other things, the task of:

• Verify the effective adoption and correct application of the control protocols envisaged by Model 231. It is noted, however, that control activities are delegated to the primary responsibility of operational management and are considered an integral part of every company process ("line control" ), hence the importance of a staff training process.
• Carry out, also through the operational support of the secretariat, periodic targeted checks on certain operations or specific acts implemented, above all, in the context of sensitive activities, the results of which are summarized in a specific report whose content will be exposed in the scope of communications to corporate bodies, as described below.
• Collect, process and store relevant information regarding compliance with Model 231.
• Monitor initiatives for the dissemination of knowledge and understanding of Model 231.

Any violation or suspected violation of Model 231 can be reported to the Supervisory Body.

Reports can be sent in the following way: