MODEL 231

Italian Law 231/01 introduces and disciplines administrative responsability for specific crimes outlined in the Law itself. A Company is liable for its staff, personnel or other parties connected with the business who commit or attempt to commit crimes in the interest or to the advantage of the Company.

The Law excludes the Company from responsibility only in the event it can demonstrate that (art. 6 of Italian Law 231/01):

  • The Board of Directors adopted and efficiently applied, prior to the crime being committed, a Model appropriate for preventing crimes of the kind committed;
  • Responsibility for overseeing the functioning and application of the Model, including updating it, has been entrusted to a corporate body equipped with independent powers of initiative and control (the Integrity Board);
  • The people who committed said crimes did so by fraudulently evading the Model;
  • Oversight and control by the Integrity Board was neither omitted nor considered insufficient.

Port Mobility has therefore decided to adopt a set of rules, processes and procedures aimed at the prevention of crime through the implementation of an adequate organizational system, named Organization, Management and Control Model, approved by the Board of Directors.

The adoption of the model favors the rigor, transparency and the sense of responsibility in internal and external relations, while at the same time it offers the best guarantees of efficient and correct management.

The model of Port Mobility consists of a General Section and Special Sections, one for each specific crime to be prevented.

At the same time as the adoption of the Model, an Integrity Board was established, to which reports of violations, suspicious and others can be sent at the email address odvportmobility@portmobility.it, or to the following address: Organismo di Vigilanza, Port Mobility S.p.A. con Socio Unico, Località Prato del Turco snc, 00053 Civitavecchia.

Organizational Model (updated January 5 2022)

CODE OF ETHICS

Simultaneously with the adoption of the Organization, Management and Control Model Port Mobility has adopted its own Code of Ethics, also approved by the Board of Directors. Social organs, management and employees, as well as all external collaborators, suppliers and those who have a relation with the company are required to observe the principles contained in the Code of Ethics that defines the set of principles and values to which Port Mobility is inspired in the conduct of its affairs and lays down the rules of conduct.

The code represents a general principle that cannot be waived of Model 231 of which it is an integral part, and it is the responsibility of the Integrity Board to check on compliance with the principles and behaviors mentioned in this Code of Ethics.

Code of Ehtics (updated 5 January 2022)

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