Organisational Model pursuant to Italian Legislative Decree n. 231
Organisational Model pursuant to Italian Legislative Decree n. 231 - Warrant Hub
On 21/12/2012, the board of directors of Warrant Hub approved the company’s first organisational model constructed in compliance with the provisions of Italian Legislative Decree 231/2001.
This decree establishes liability of the company in the event that certain types of offences are committed in its interest or to its advantage by parties in senior positions or by parties under their management or supervision.
The model adopted by Warrant Hub, which was updated and approved in December 2020, represents a further step towards achieving rigour, transparency, and a sense of accountability in both internal relations and those with the outside world.
The model adopted by Warrant Hub includes the following aspects:
Abidance by the Tinexta Group Code of Ethics and Conduct;
All procedures are designed to contain the risk of offences being committed;
A disciplinary system designed to deter conduct breaching the models adopted;
The appointment of a supervisory body whose main task is to oversee compliance with the model, while also assessing its effectiveness and updating it;
An information and training plan aimed at employees to raise awareness among them of the importance the company attributes to ensuring proper performance of the activity in general and in particular to compliance with the procedures established.
For all the details, please download the general section of the organisation and management model.
How to raise a concern about a breach or a suspected breach
Any party can report a breach or suspected breach of the model and/or the Code of Ethics to the supervisory body, using the following channels:
- by conventional mail to the following address (marking the envelope with the word: "RISERVATO" i.e. "CONFIDENTIAL", and addressing it to: Supervisory Body , c/o Warrant Hub S.p.A. Corso Giuseppe Mazzini, 11, 42015 Correggio (RE);
- to email address: odv231@warranthub.it
Any party who raises a concern is guaranteed confidentiality of their identity, without prejudice to legal requirements.
Code of Ethics and Conduct
The code sets out the principles and rules of conduct with which the parties to whom or which the code applies must comply in relation to Warrant Hub and all the companies in the Tinexta Group when going about their work; the code applies, for example, to directors, members of the board of auditors, statutory auditors, executive managers, employees, associate workers, consultants, customers, suppliers, business partners, and all those who, directly or indirectly, permanently or temporarily, establish, for any reason, working relationships with or work in the interest of the group member companies and the shareholders.
Among other things, it governs the following areas:
- Compliance with the law and internal regulations;
- Relations with public administration authorities;
- Relations with investee companies;
- Relations with suppliers and partners.
For all the details, please download the Tinexta Group Code of Ethics and Conduct.
Organisational Model pursuant to Italian Legislative Decree n. 231 - Warrant Service
On 29/07/2020, the board of directors of Warrant Service approved the company’s first organisational model constructed in compliance with the provisions of Italian Legislative Decree 231/2001.
This decree establishes liability of the company in the event that certain types of offences are committed in its interest or to its advantage by parties in senior positions or by parties under their management or supervision.
The model adopted by Warrant Service, which was updated in March 2021 and then again in January 2024, represents a further step towards achieving rigour, transparency, and a sense of accountability in both internal relations and those with the outside world.
The Company is particularly sensitive to the implementation and continuous updating of a risk prevention and management system, in line with the provisions of the Decree and suitable to prevent and reduce to the greatest extent possible, within the company, the risk of offences being committed, and consequently to avoid the application of the sanctions provided for by the same Decree.
This Model has the following objectives:
- Raise the awareness of the Addressees by requiring them, within the limits of the activities carried out in the interest of the Company, to adopt correct and transparent conduct, in line with the ethical values by which the Company is inspired in the pursuit of its corporate purpose and such as to prevent the risk of commission of the offences contemplated in the Decree;
- Determine in the aforementioned persons the awareness that they may incur, in the event of violation of the provisions issued by the Company, disciplinary and/or contractual consequences, as well as criminal and administrative sanctions that may be imposed on them;
- Establish and/or strengthen inspections that enable the Company to prevent or promptly react to prevent the occurrence of offences committed by apical persons and persons subject to the management or supervision of the former that entail the administrative liability of the Company;
- Enable the Company, thanks to a monitoring process on the areas of activity at risk, to intervene promptly in order to prevent or counteract the occurrence of offences and sanction any conduct contrary to its Model;
- Improve effectiveness and transparency in the management of activities;
- Determine a full awareness in the potential perpetrator that committing an offence is strongly condemned and contrary - in addition to the provisions of the law - both to the ethical principles to which the Company intends to adhere and to the Company's own interests, even when it could apparently gain an advantage.
For all the details, please download the organisation and management model.
How to raise a concern about a breach or a suspected breach
Any party can report a breach or suspected breach of the model and/or the Code of Ethics to the supervisory body, using the following channels:
- by conventional mail to the following address (marking the envelope with the word: "RISERVATO" i.e. "CONFIDENTIAL", and addressing it to: Supervisory Body, c/o Warrant Service Corso Giuseppe Mazzini, 11, 42015 Correggio (RE);
- by email to the following address: odv231warrantservice@warranthub.it.
Any party who raises a concern is guaranteed confidentiality of their identity, without prejudice to legal requirements.
Code of Ethics and Conduct
The code sets out the principles and rules of conduct with which the parties to whom or which the code applies must comply in relation to Warrant Service and all the companies in the Tinexta Group when going about their work; the code applies, for example, to directors, members of the board of auditors, statutory auditors, executive managers, employees, associate workers, consultants, customers, suppliers, business partners, and all those who, directly or indirectly, permanently or temporarily, establish, for any reason, working relationships with or work in the interest of the group member companies and the shareholders.
Among other things, it governs the following areas:
- Compliance with the law and internal regulations;
- Relations with public administration authorities;
- Relations with investee companies;
- Relations with suppliers and partners.
For all the details, please download the Tinexta Group Code of Ethics and Conduct.