Modula S.p.A. Organizational, Management and Control Model and Code of Ethics

Legislative Decree 231/2001 (Regulation on the administrative liability of legal persons, companies and associations even without legal personality) provides that an entity may be held liable (with consequent application of significant sanctions of both of a pecuniary and injunctive nature) in relation to certain specific crimes, committed or attempted, by senior management and subordinates in the interest or to the benefit of the entity itself.
In the event of the commission of a crime, the exemption from administrative liability exists, among other things, if the entity proves that it previously adopted and effectively implemented an Organizational, Management and Control Model suitable for preventing crimes of the type that occurred.
To this end, Modula S.p.A. (with a resolution of the Board of Directors of 17 September 2014) adopted its own Organizational, Management and Control Model, consisting of a set of control procedures and rules, which the company functions must comply with when carrying out their activities.
The Modula S.p.A. Organizational, Management and Control Model includes (as an essential and binding element) the “Code of Ethics”, which is an instrument through which the values that Modula S.p.A. declares, accepts and shares in carrying out its business are defined in order to maximize the efficiency, reliability and reputation of the Company, which are key factors for its success and for the continuous improvement of the conditions in which Modula S.p.A. itself operates.
All individuals who, even on an occasional and non-exclusive basis, work and operate for Modula S.p.A. (such as customers, suppliers, employees, commercial and financial partners, shareholders, members of the Corporate Bodies, etc.), without distinction or exception, are committed to complying with and enforcing the principles and regulations of the Modula Code of Ethics, within the scope of their functions and responsibilities, and the observance of these principles and rules are an essential part of the obligations of the aforementioned individuals with regard to Modula S.p.A.
To this end, the Modula S.p.A. Organizational, Management and Control Model (General Part) and the Code of Ethics, updated with resolution of the Board of Directors of 13 October 2020, are hereby made public and available to all interested parties.

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