Organization, Management and Control Model
and Group Code of Ethics

IRCA S.p.A. has adopted an Organization, Management and Control Model pursuant to Legislative Decree no.231/01 and a Group Code of Ethics in the firm belief that they are appropriate tools for disseminating rules and regulations to company personnel and to all individuals acting in the name and on behalf of the Company, in order to ensure an ethically agreed conduct and to pursue compliance with the principles of legitimacy, fairness and transparency.
IRCA S.p.A. has appointed its own Supervisory Body which has the task of supervising the correct functioning, effectiveness and observance of the Organisation, Management and Control Model and compliance with the principles of the Code of Ethics.


Reporting
All reports of violations, certain or only alleged, of the Model and/or the Code of Ethics, or in any case of conduct that may imply the committing of crimes referred to in Decree 231/01, must be sent to the email address: [email protected], or by post to the Company's offices, for the attention of the Supervisory Body.
The Company and the Supervisory Body adopt appropriate measures so that the identity of a person transmitting information always remains confidential, provided this information is true.
Any form of retaliation, discrimination or penalisation against those who make a report to the Supervisory Body in good faith is prohibited.
The Company reserves the right to take any action against anyone who makes untrue reports in bad faith.
Anonymous reporting is not possible.