Governance and Compliance
Our commitment to transparency and legality
Grivan Group S.p.A. adopts a Governance and Compliance system in line with Legislative Decree
231/2001, which defines the administrative responsibility of companies.
This organizational model reinforces the principles of transparency, integrity, and fairness that guide all
our activities, protecting stakeholders and preventing unlawful conduct.
Organization, Management and Control Model (“Model 231”)
To prevent the crimes indicated in Legislative Decree 231/01, Grivan Group has approved an Organization,
Management and Control Model that identifies risk areas, defines procedures, protocols, and internal controls, and
regulates information flows to the Supervisory Board.
The Model is a fundamental tool for ensuring compliance with corporate
rules and values.
Code of Ethics
The Code of Ethics expresses the principles of integrity, compliance with the law, transparency, confidentiality, and fairness in
relations with the Public Administration, customers and suppliers, health, safety, and the environment, which all
employees and partners are required to observe.
Disciplinary System
The Disciplinary System defines the sanctions and procedures applicable in the event of violations of Model 231
or the Code of Ethics, against directors, auditors, managers, employees, and third parties operating
on behalf of the Company.
It is an essential tool for ensuring the effectiveness of the Model and protecting whistleblowers
from potential retaliation.
Supervisory Body and Whistleblowing
Compliance with Model 231 and the Code of Ethics is monitored by an independent Supervisory Body, vested
with control and reporting powers.
The Company has adopted secure and confidential whistleblowing channels to allow
the reporting of any conduct contrary to the Model or the Code of Ethics, ensuring protection from
retaliation.