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Prysmian Group – 2015 Sustainability Report
Group ID Card
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ORGANISATIONAL MODEL (DECREE 231/2001)
Prysmian adopted an organisational model (the "Model") in compliance with the requirements of Decree
231/2001 on 24 January 2006. This Model is periodically revised and updated to take account of changes in
the list of administrative offences and crimes envisaged by the Decree, as well as the dynamics of the
system of corporate governance and the organisational structure of the Group. This activity ensures that the
Model is always up to date and applicable over time. The Company is and has always been determined to
comply with the related legislative requirements, to implement the principles of proper management laid
down in the Decree and to improve systematically the system of corporate governance, in order to combine
the achievement of excellent results with full compliance with the regulations and the highest ethical
standards.
The Model, which is an integral part of the Group's broader system of governance, is designed to establish
operational rules of behaviour that are suitable for preventing illicit conduct deemed significant by the
Company pursuant to the Decree, based on analyses of Prysmian's business activities, decision-making
processes and system of internal control.
The Model comprises two sections. The first part, of a general nature, describes the Decree, the rules of
governance and the general principles on which the Model is based.
Code of Ethics, which sets out the key principles of ethical behaviour that must be observed by all
those who work on behalf of Prysmian or its affiliates. Translated into 26 languages, the Code of
Ethics is displayed at each Group affiliate and periodic training sessions are held for employees and
collaborators;
Guidelines for Conduct that, by analysing the key principles expressed in the Code of Ethics, identify
required behaviours in the areas of "what to do" and "what not to do", thus responding to the need to
prevent possible offence risk scenarios.
The second section, on the other hand, seeks to identify and govern the specific conduct required in areas
that are known to expose the Company to offence risk situations.
The fundamental principles laid down in the Code of Ethics and the Guidelines for Conduct are rendered
operational by the definition of specific
Decision, management and control protocols
that govern, for each
process exposed to offence risk: the roles and responsibilities of the parties involved, the decision-
making/authorisation procedures, and the management and control methodologies adopted.
Lastly, the governance rules for the Model specify the organisational rules for implementation, ensuring the
continuous functioning of the Model.
Following the amendments made to the Decree during 2015, with regard to Eco-crimes
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relating to
environmental matters and to self-money laundering
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, the Internal Audit function has commenced a risk
assessment in order to assess the Group's exposure to the above offence risk scenarios and, if necessary,
update the Model adopted by Prysmian and each Italian company within the Group.
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Law 68/2015, so-called “Eco-crimes Law”: “Instructions on crimes against the environment”.
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Law 186/2014: “Instructions on the emergence and return of capital held abroad, as well as for strengthening the fight against tax
evasion. Instructions on self-money laundering”. This measure amended the existing legislation by adding the new crime of self-money
laundering to art. 25-octies of Decree 231/2001 and to the criminal code (art. 648-ter.1), as well as by increasing the penalties for
money laundering (art. 648-bis) and the use of cash, goods or other value obtained from illegal sources (art. 648-ter).