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Organizational Model according to the provisions of Legislative Decree n° 231 dated 8/6/2001 of CUPRUMFOMA Spa


  • The Company CUPRUMFOMA Spa, with resolution dated 09 June 2020, adopted an Organizational Model according to the provisions of Legislative Decree n° 231.
  • The task of supervising the compliance with the Model and its effectiveness has been entrusted to a collegial Monitoring Body composed of three members, two of them being external to the company, all having the requisites of autonomy, independence and professionalism.
  • The Monitoring Body acts in full autonomy from the corporate structure; in carrying out its activities it disposes of the necessary financial resources and makes use of all employees who are required to collaborate also by reporting any violations.
  • The Organizational Model is aimed at the personnel of all levels of the Company, including managers and directors.
  • The Organizational Model represents a set of general principles of conduct as well as specific procedures and provisions to be implemented in order to prevent the offences envisaged by the decree from being committed within the activities of those who work on behalf of CUPRUMFOMA Spa.

Taking into consideration the activity carried out by CUPRUMFOMA Spa and its organizational structure, the Model has been implemented for the following types of offences provided by the Legislative Decree 231, in particular:

  • Crimes against Public Administration;
  • Corporate crimes;
  • Crimes committed in violation of accident prevention regulations and of the protection of hygiene and health at work;
  • Environmental crimes.

The Model is structured in two parts:

  • General part;
  • Specific part.

The following topics are treated in the General part:

  • Introduction to the Legislative Decree n. 231 dated 8 June 2001;
  • The administrative liability regime of legal entities;
  • Administrative offences;
  • Recipients of the Organizational Model;
  • Structure of the Organizational Model;
  • Confindustria Guidelines;
  • Adoption principles;
  • Monitoring Body;
  • Sanction system;
  • Diffusion of the Organizational Model;
  • Update of the Organizational Model;
  • Adoption of the Organizational Model;



The protocols of the activities connected with the considered types of crimes are treated in the Specific Part.

Such protocols set the formalization of the procedures adopted by the Company. These are constantly revised and updated according to the analysis carried out by internal and external audits, the received notifications and the norm modifications which occur on the considered topics.


The Ethical Code processed in the General Part completes the Model with the values, behavioural principles and commitments which must be respected by those who work on behalf of the Company.


The Monitoring Body has got no operational tasks and it carries out its monitoring activities and update of the Model according to constant flows of information and taking into consideration the received notifications.


All recipients of the Model are required to transmit the requested flows of information to the Monitoring Body, to keep the adequacy of the system under control, highlighting the incoming requirements and the critical topics. They are also required to report infringements to the behavioural and operative rules established in the Model.


A failure to disclose the a.m. flows of information to the Monitoring Body or a delay in their transmission will be considered as a violation of the Organizational Model and may be sanctioned according to the premises of the Disciplinary System.


The flows of information will be transmitted to the Monitoring Body following the required modes; the notifications of alleged infringement of the current Model will have to be transmitted to the Monitoring Body in written form by Postal service, to the following address:

Organismo di Vigilanza


Via Kennedy n. 20,

25020 – Pralboino (BS)

Otherwise, they could be sent per email to the following email address: Cette adresse e-mail est protégée contre les robots spammeurs. Vous devez activer le JavaScript pour la visualiser.

The Monitoring Body will treat the a.m. notifications in respect of the privacy norms and will ensure confidentiality regarding either the person who allegedly infringed the norm or the person who transmitted the infringement notification.

Click here to download the Ethical Code