Company

Organizational, Management and Control Model of GT Line

GT Line Srl, in its capacity as leading company in its field and always attentive to the principles of integrity and transparency, has adopted the Organizational, Management and control Model (hereinafter “the Model”) consistent with the requirements laid down in Article 6 of Legislative Decree n. 231 of 8 June 2001, which regulates the “Administrative liability of entities and legal persons”.

In this manner, GT Line intended to strengthen and integrate the guiding principles of its business conduct and the related internal control system, in order to ensure that the behaviour of all those who work on behalf of or in the interest of the company must always comply with the laws and regulations and be consistent with the principles of correctness and transparency in the conduct of business and corporate activities.

This initiative was undertaken in the belief that the definition, adoption and implementation of this Model – beyond the requirements of the Decree – can be a valuable awareness tool for all those who work on behalf of and in the name of GT Line, so they observe the correct and linear behaviour in carrying out their work, so as to prevent the risk of committing offenses specified in the Decree.



RECIPIENTS

The following are recipients of this Model and, as such, within the sphere of their specific competencies, are required to have knowledge of it and observe it:

- The Administrative Body, constituted today by the Board of Directors of the company;
- The Statutory Control Board, represented today by the Auditing Company in the sphere of monitoring activities and verifying the accuracy of financial statements and management of administration and accounts;
- All employees and direct collaborators with whom contractual relations are held, of any capacity, even occasional and/or temporary;
- All third parties, customers and suppliers who hold relations of any kind with the company.



PURPOSE

The Model, in line with the requirements of Legislative Decree n 231 of 2001 has the purpose of:

- Integrating and strengthening the system of corporate governance and the compliance with the laws and regulations of GT Line;
- Preparing a structured and systematic system of prevention and control tools, aimed at reducing the risk of committing offenses related to the business activity;
- Reiterating to the recipients that GT Line does not tolerate unlawful behaviour or non-observance of the pursued purpose or erroneous assumption of acting in the interest or benefit of the company. These conducts are contrary to the ethical principles and values on which the company is based and intends to meet in its corporate mission, therefore they are contrary to the interest of it;
- Making everyone who works in the name, on behalf of or however in the interest of GT Line, aware of the fact that committing an offense in the misunderstood interest of the company, gives rise not only to the application of administrative sanctions against the person of the offending conduct, but also administrative sanctions against the company, exposing it to financial, operational and image prejudices;
- Noting that all employees are required to strictly comply with laws in force and ensure their conduct is to the highest standards of diligence, prudence and expertise, with the view to safeguarding security and the environment;
- Informing everyone who works in the name, on behalf of or however in the interest of GT Line that violating the provisions in the Model, will result, regardless of the criminal relevance of them, the application of disciplinary and/or contractual sanctions.



STRUCTURE OF THE MODEL

The Model has been defined following an in-depth examination and assessment of areas and corporate activities that are potentially at risk of committing the offenses foreseen in Legislative Decree n. 231/2001.

The General Part, in addition to introducing the reader to the context of the law in question, explains the organizational references adopted by the company to conduct its business and the structure of the responsibilities and powers, introducing several general principles on which its internal control system can be based.

Through analysis carried out according to a risk-based approach, in compliance with the principles set forth by universally recognised frameworks on assessment of governance and internal control systems, the sensitive areas were therefore identified and the verification of the possible ways to commit offenses and corporate controls to prevent these possibilities was carried out.

The special Part of the Model, composed in several sections, adopts the detailed examination of criminal cases that are abstractly applicable to the GT Line context, identifying the specific rules of conduct that must be adopted in order to prevent the presupposed offenses and conform – in this sense – training processes and implementation of corporate decisions.



DISSEMINATION

For the Model to be effective, it is the aim of GT Line to guarantee the recipients identified above the correct knowledge of principles of conduct established by the company and contained within the Model.

To this end, GT Line has prepared the adequate dissemination of the Model, in the full version or in simple extracts, with different levels of in-depth analysis related to the different levels of involvement of the recipients in the areas of activities at risk.

Internal staff and direct collaborators participate regularly at training sessions and refresher courses to correctly and effectively adopt the provisions in the Model.

For any information, please contact the Technical Secretariat (c/o the office of Barbara Di Giacomo) of the Supervisory Board at the following addresses and number:



Via del Lavoro, 50/52 Loc. Crespellano - 40053 Valsamoggia (BO) - ITALIA
TEL. +39.051.6504122 - E-Mail: hr@gtline.com