Legislative Decree no. 231, dated 8 June 2001, introduced into the Italian legal system the administrative liability of Companies for certain offences perpetrated, in their own interest or for their own benefit, by their directors, employees and/or representatives in general, together with the related monetary and prohibitive sanctions to be imposed upon the Companies themselves.

 The administrative responsibility of the company is autonomous with respect to the criminal responsibility of the natural person who has committed the crime and is placed alongside it.

 The administrative responsibility of the company is, however, excluded if it has adopted and efficiently implemented, before the crimes were committed, models of organization, management and control suitable for preventing the crimes of the kind that have been committed; these models can be adopted on the basis of codes of conduct (guidelines) drawn up by the representative associations, including Confindustria (Italian Board of Industry).  

 In order to ensure, to the greatest possible extent, that the perpetration of the offences set out in the aforementioned Decree is prevented, ATV has adopted its own Organisational, Management  and Control Model. Please find it attached.

Any information, reports or data relevant to the Organization, Management and Control Model may be addressed to the Supervisory Body via the following physical postal address: Organismo di Vigilanza ATV S.p.A., Via Ombriano 2, 23823, Colico (LC), Italy  Or forwarded by email to the following email address: odv231@atvspa.com