Like the Parent Company, ADR S.p.A., in addition to adopting the Atlantia Group's Code of Ethics and Anti-Bribery Policy, ADR TEL has also adopted its own Organisational, Management and Control Model (Model) in accordance with the requirements of Legislative Decree no. 231/2001 and developed on the respective legal subjectivity and operational specificities.
The Model, which is constantly updated in light of the regulatory changes that have taken place, was most recently revised during 2019, taking into account the developments in reference best practices and new case law on the liability of entities.
The Model describes the inspiring principles and the operational procedures followed for its preparation and updating, regulates the requirements, functions and powers of the Supervisory Body, as well as the characteristics of the system of notifications and information flows, the penalty system and the procedures for disseminating said Model within ADR TEL and to third parties.
The document describes the set of control and behavioural principles considered suitable for regulating the processes for which a potential risk of committing crimes and administrative offences pursuant to Legislative Decree no. 231/2001 has been identified.
The Organisational Model has been disseminated to Company staff and is brought to the attention of all third parties who undertake business relations with ADR TEL.
Like the Parent Company, ADR S.p.A., in addition to adopting the Atlantia Group's Code of Ethics and Anti-Bribery Policy, ADR TEL has also adopted its own Organisational, Management and Control Model (Model) in accordance with the requirements of Legislative Decree no. 231/2001 and developed on the respective legal subjectivity and operational specificities.
The Model, which is constantly updated in light of the regulatory changes that have taken place, was most recently revised during 2019, taking into account the developments in reference best practices and new case law on the liability of entities.
The Model describes the inspiring principles and the operational procedures followed for its preparation and updating, regulates the requirements, functions and powers of the Supervisory Body, as well as the characteristics of the system of notifications and information flows, the penalty system and the procedures for disseminating said Model within ADR TEL and to third parties.
The document describes the set of control and behavioural principles considered suitable for regulating the processes for which a potential risk of committing crimes and administrative offences pursuant to Legislative Decree no. 231/2001 has been identified.
The Organisational Model has been disseminated to Company staff and is brought to the attention of all third parties who undertake business relations with ADR TEL.
The Supervisory Body (SB) is the body entrusted, pursuant to Article 6 of Legislative Decree 231/2001, the task of "overseeing the functioning, compliance and effectiveness of the Model and ensuring its updating".
The Supervisory Body must be notified of any circumstances that are relevant to the compliance with and operation of the Model itself, as well as any unlawful conduct or breaches of the Model, ensuring that the reports are circumstantial and based on precise and consistent facts.
Each report received is managed by the Supervisory Body, in accordance with the provisions of Article 6 of Legislative Decree 231/2001, guaranteeing the confidentiality of the identity of the person making the report and their protection from any form of retaliation, discrimination or prejudice connected, be it directly or indirectly, to the report.
The Company provides alternative channels (WEB platform, email box and postal address) for the transmission of reports.
Reports can specifically be made:
via the "Whistleblowing" IT platform, which can be accessed from the website www.adr.it and via the company's intranet;
via email, to the following email address:
organismodivigilanza@adrtel.it;
via email for the attention of Supervisory Body, ADR TEL- Via Pier Paolo Racchetti 1, 00054 Fiumicino - Rome.