As part of the initiatives to strengthen its internal control system, FITD and the Voluntary Intervention Scheme have adopted an Organization, Management and Control Model, pursuant to Legislative Decree no. 231/2001, for monitoring risk of offences as regards the Fund and VIS’s activities.
The Model sets out a system of prevention and control for reducing the risk of offence connected with the Fund’s activities. It warns all those who carry out activities for and on behalf of the Fund - in particular, those activities considered at risk - of the possibility to incur in offences and administrative charges for the violation of the set provisions.
In the meetings of March 20, 2019, the Board of FITD and the Management Board of the Voluntary Scheme approved, respectively, the Organization, Management and Control Models of FITD and Voluntary Scheme, and appointed the Oversight Committee (Organismo di Vigilanza - OdV), composed by criminal lawyer, Mr. Luigi Panella (Chairman of the OdV) and two Statutory Auditors, Mr. Maurizio Comoli and Mr. Amedeo Grilli (SB members).
The 231 Models consist of a General Part, containing the core principles of the discipline (legislation?) - including those relating to the functioning of the Oversight Committee - and a Special Part outlining the various crime categories encompassed by the Decree and applicable to the FITD and Voluntary Scheme.
The Models were updated in the meetings of the Bodies on 13 November 2019 with the introduction of a whistleblowing procedure to be applied together with the provisions of the Code of Ethics.
On 22 July 2020, the Models were updated in relation to regulatory changes and significant corporate events, as well as by introducing Market Abuse and Stock-Market Offenses as part of the strengthening of internal profedures for the management of confidential and privileged information.
Based on the provisions of the Model, reports on events that could involve the FITD pursuant to Legislative Decree no. 231/2001, can be sent to the following e-mail address: email@example.com.