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Organization Model pursuant to Legislative Decree No. 231/2001

Bologna Airport’s Organization, Management and Control Model ('Model') aims to guarantee an internal control system designed to prevent unlawful conduct on the part of its directors, employees, associates and partners, while ensuring fairness and transparency in the conduct of business and corporate activities, to protect the Company’s position and image, the shareholders’ expectations and the employees’ work.

Bologna Airport resolved to update the Model 231, by resolution of the Board of Directors on 22 December 2015, following the legislative amendments which extended the administrative responsibility of societies and institutions, at the same time allowing for a greater integration with the Corruption Prevention Plan.

The revised Model consists of a General Part, which contains the principles and objectives of the Model, and the following attachments:

The Code of Ethics

The CoE defines in an explicit and unambiguous way all values and principles on which the Company should base its actions and which the Company intends to adopt and apply in their relationships with all shareholders with whom it interacts during the performance of its business activities (employees, partners, clients, passengers, suppliers, public authorities and institutions), to ensure that all relations, external and internal to the Company and, more generally, of the Group, are conducted and developed in a socially and ethically correct manner.

An Independent Evaluation Body was established with autonomous powers of initiative and control, with the tasks of supervising the efficiency of and compliance with the Model, including the Code of Ethics, and continuously updating it.

All of the Company’s shareholders are required to promptly report any violations or breaches of the Model to the Independent Evaluation Body, as well as to keep it informed of any legal proceedings against them.
Violations are subject to sanctions according to the disciplinary procedures outlined in the Model, which, for employees, integrate the types of misconduct defined by the Collective Agreement and the Company Rules and which, in general, define any penalties to be imposed to the relevant subjects and to the misconduct detected, according to criteria of appropriateness and proportionality.

Reports of possible violations of the Model must be submitted to the Independent Evaluation Body in writing.


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