Model ORG 231

MARA SRL has adopted an Organizational Model pursuant to Legislative Decree 231/2001.
The Model is addressed to all levels of the corporate structure, including directors, managers and supervisors.
The Model, which aims to create a complete system of internal control and organization, represents a set of general principles of conduct as well as specific procedures and provisions put in place to counter and prevent the commission of the crimes envisaged by the decree itself within the scope of the activities of those who operate on behalf of MARA SRL.
The MARA SRL Model is structured in two chapters in addition to attached documents:

  • First Chapter _General Part

    In the first chapter (or general part), the relevant legislation is examined and the structural characteristics of the Organization as well as the methods of creating the model and its training are identified; more precisely:

    1. 1. Legislative Decree 231/2001 and relevant legislation;
    2. 2. The corporate structure of MARA SRL;
    3. 3. The Organizational Model of MARA SRL;
    4. 4. Supervisory Body (OdV);
    5. 5. Verification and updating of the Organizational Model.
  • Second Chapter _Special Part

    In the second chapter (or special part), the protocols of the activities connected to the types of crimes considered are instead developed. After examining the activity carried out and the organizational structure of MARA SRL, the adopted Model considers the following types of crimes:
    1. Crimes committed in violation of the rules on the protection of health and safety at work;
    2. Crimes committed in violation of environmental regulations;
    3. Crimes committed in the management of relationships with suppliers/customers and in the management of contract, work or supply contracts;

  • Allegati

    In the attachments (which are an integral part of the Organizational Model) there is space for:
    1. Risk Map;
    2. Code of Ethics Annex B and Annex B1 (Download Code of Ethics);
    3. Disciplinary and sanctioning system;

The task of overseeing the proper functioning and adequacy of the Organizational Model has been entrusted to a single-member Supervisory Body. The Supervisory Body has autonomous powers of initiative and control and carries out its tasks with all the necessary resources; all the recipients of the Organizational Model are required to collaborate with the Supervisory Body, also through reports of any non-compliant situations.

Therefore, the recipients of the Model are required to transmit to the Supervisory Body the requested information flows, to make observations on the adequacy of the system, highlighting the emerging needs and any critical issues, as well as to report any violations of the behavioral and operational methods set out in the Model.

The information flows will be transmitted in the manner requested by the Supervisory Body, while the Reports of alleged violations of this Model must be sent to the Supervisory Body, in writing only,
by email odv231mara@gmail.com
or by post, to the following address:

Supervisory Body of
MARA SRL
Via Adua 11, 25050 – Passirano (BS)

The reports must contain:

– an indication of the violation of the Model detected with a description of the conduct adopted;
– the identification of the subject who committed the violation;
– the identification of the subject who made the report.

Anonymous reports will not be considered by the Supervisory Body. In the management procedure, by the Supervisory Body of the above-mentioned Reports, the privacy rules as well as the principle of confidentiality will be respected with reference both to the subject of the Report and to the subject who promoted the report.

The Organizational Model is available on request.
Download Code of Ethics
Download the Mog

Download the Whistleblowing Reports Management procedure