Code of Ethics
Mastria Vending S.r.l. Code of Ethics
Information Model 231 | Code. RPA – Rev. 00 of 20/11/2023
In compliance with Legislative Decree no. 231/01, Mastria Vending S.r.l. has adopted the "Organizational Model 231" aimed at preventing the commission of offenses that may lead to the administrative liability of the Company if carried out in its interest or to its advantage.
The generally accepted principles of transparency, fairness, and loyalty that inspire the company are at the core of the adoption of Organizational Model 231, which ensures the effective performance of sensitive activities by preventing, through the application of the provisions of Legislative Decree no. 231/2001, the commission of offenses that may lead to the administrative liability of the company, if carried out in its interest or to its advantage.
The purpose of the Organization, Management and Control Model (hereinafter also "Model") is the construction of a structured and organic system of procedures and control activities aimed at preventing the offenses referred to in Legislative Decree no. 231/2001, through the identification of activities exposed to the risk of offense and their consequent proceduralization.
Through the adoption of the Model, Mastria Vending S.r.l. aims to achieve the following main objectives:
- establish ethical values and principles of professional conduct;
- make the Recipients of the Model aware that, in case of violation of the provisions contained therein, they may incur in the commission of offenses liable to criminal penalties against them and administrative penalties applicable to the Company;
- reiterate that such forms of illicit behavior are strongly condemned by Mastria Vending S.r.l., as they (even if the Company were apparently in a position to benefit from them) are in any case contrary, not only to legal provisions but also to the ethical principles to which it intends to adhere in the exercise of its business activities;
- allow the Company, thanks to monitoring of risk areas, to intervene promptly to prevent or combat the commission of such offenses. Any violation of Model 231 can be reported to the Supervisory Body established within the Company at the certified email address roccosgro@pec.it
Reports for the prevention of corruption (pursuant to and for the purposes of
Legislative Decree no. 24/2023)
Whistleblowing is a legal instrument aimed at protecting workers who report illegal acts or fraudulent activities carried out within their organization and committed for its benefit. Legislative Decree no. 24 of 10 March 2023 has recently strengthened the measures already provided for in Italian law since 2017, requiring the employer or entity to provide potential whistleblowers with a series of measures aimed at guaranteeing, also through the use of encryption tools, the confidentiality of the whistleblower's identity, the person involved, and any person mentioned in the report, as well as the content of the report itself and the relevant documentation. The decree identifies both the subjects who can report and the nature of the violation being reported (by way of example but not exhaustive, it includes administrative, accounting, civil, or criminal offenses; conduct constituting the offenses referred to in Legislative Decree no. 231/2001 and violations of organizational, management, and control models; violations of EU regulations; etc.), as well as the procedural steps that the responsible party must follow in managing the aforementioned report. Reports can be submitted either in writing – by filling out the attached form and sending it to the Reporting Manager – or orally through an interview with the Manager. Mastria Vending S.r.l. has appointed Dr. Maria Stefania Consarino as the Manager for Reporting Management. Reports can be sent to the Certified Email address: mariastefania.consarino@legalmail.it using the attached form.