Model 231

General principles of conduct

CUORE DEL SUD, in compliance with the provisions contained in Legislative Decree No. 231 of June 8, 2001, on the “Regulation of the administrative liability of legal entities,” with a resolution of the Board of Directors dated September 30, 2024, has adopted an Organization, Management, and Control Model pursuant to Legislative Decree No. 231/2001.

The Model 231 for business management, consisting of a General Section and a Special Section, identifies the operating procedures that CUORE DEL SUD adopts to reduce the risk that senior management and subordinates commit crimes for the benefit of the company. CUORE DEL SUD’s Model 231 is a document whose preparation involved examining every department of the company, allowing for a preliminary analysis of “sensitive” activities considered to be at potential risk under Legislative Decree 231/2001, establishing general principles of conduct, prevention measures, and essential control measures designed to prevent or mitigate illegal acts.

CUORE DEL SUD’s Model 231 is a dynamic document that is adapted to regulatory and organizational changes in order to ensure its adequacy and suitability. CUORE DEL SUD’s Code of Ethics is an integral part of Model 231 and defines the set of values and principles that inform the company’s activities, establishing rules of conduct for relationships with employees, customers, suppliers, and partners.

The adoption of Model 231 is a necessary prerequisite for CUORE DEL SUD to be exempt from administrative liability in the event of offenses committed by its directors and employees, as well as by persons acting in the name and on behalf of CUORE DEL SUD itself, of the types of offenses provided for by Legislative Decree No. 231/2001. The Board of Directors of CUORE DEL SUD has also appointed a Supervisory Body (SB), endowed with autonomy of action and specific powers, with the task of verifying compliance with the rules of Model 231, ensuring its updating, and reporting to the Board of Directors any possible situations of non-compliance with the provisions of Model 231 itself.

Risk prevention

Reporting of Violations to Model 231 CUORE DEL SUD.

Reports to the Supervisory Body regarding violations of the company’s Model 231 can be sent by email to:
• email: odv@witlogistics.it
• regular mail addressed to: Supervisory Body CUORE DEL SUD, Viale Europa Zona Ind., Battipaglia, SA 84091

Reporting procedure – Whistleblowing
Whistleblowing is a process through which individuals who work on behalf of or in favor of CUORE DEL SUD, or who have business relations with the latter through any type of contract or assignment, and who, in the performance of their duties within the organization to which they belong, have become aware of illegal conduct or irregularities in the workplace that could harm the integrity of the Company or cause damage to third parties.
CUORE DEL SUD, in implementing Model 231, has placed particular emphasis on preventing risks that could compromise the responsible and sustainable management of its business.

In Italy, the reporting procedure is regulated by Legislative Decree No. 24 of March 10, 2023, which implements Directive (EU) 2019/19372. This decree provides for the protection of persons who report violations of Union law and national regulatory provisions. Reports can be made through internal channels within the organization, external channels such as ANAC (National Anti-Corruption Authority), or through public disclosure.
In compliance with Model 231 and ANAC’s whistleblowing guidelines, CUORE DEL SUD provides the Reporting Procedure Portal – Whistleblowing.
The ANAC guidelines, approved by Resolution No. 311 of July 12, 2023, provide details on the procedures for submitting and managing external reports. These guidelines include instructions on the transmission and acquisition of reports, as well as protections for whistleblowers, such as confidentiality and protection from retaliation.
For CUORE DEL SUD, whistleblowing is an important tool in the security system. Thanks to its protocols, the CUORE DEL SUD Reporting Procedure Portal – Whistleblowing protects:

the identity of the whistleblower, allowing disclosure only with their explicit consent;
the identity of the reported person;
the confidentiality of information in every context following the report;
computerized management with the archiving of reports (ref. Legislative Decree 24/2023) entrusted to the company bodies responsible for receiving and verifying them;

Strategic communication

Communication and dissemination of Model 231

Communication and dissemination of Model 231 are essential to ensure its effectiveness and adoption within a company.
It is essential that all employees are informed and trained on Model 231. This can be done through informational meetings, training sessions, and the distribution of informational material. Communication must be clear, detailed, and periodic.

External partners, such as suppliers and customers, must also be informed about the adoption of Model 231.

The Supervisory Body (SB) must receive regular information flows concerning the sensitive processes identified. This allows it to monitor the effectiveness of the model and intervene promptly in the event of critical issues.
Communication must be planned strategically, identifying the recipients and specific content for each group. For example, employees may receive detailed communications on operating procedures, while external partners may receive general information on the adoption of the model.

It is important to use various communication channels, such as email, the company intranet, information boards, and regular meetings, to ensure that the message reaches all recipients effectively.