Pursuant to Legislative Decree 231/2001, the Organisation, Management and Control Model (OMM) is a structured and harmonised prevention, deterrence and control system aimed at:
- informing people who either directly or indirectly work in sensitive areas (directors, managers, employees and collaborators) of their liability to committing an offence;
- preventing or limiting the Company’s administrative liability.
The OMM, adopted by the Board of Directors of Unipol Gruppo S.p.A. on 19 December 2024 following the merger by incorporation of UnipolSai Assicurazioni S.p.A. into Unipol Gruppo, which is now called Unipol Assicurazioni S.p.A., consists of a “General Part” and individual “Special Parts” regarding the various categories of offences regulated by the Decree.
The "General Part" contains an introduction regarding the Decree and its applicability to the Company, as well as the rules and general principles of the Model.
The "Special Parts" illustrate the rules relating to the various categories of offences, providing examples of unlawful conduct, the sensitive processes carried out at the Company and the control mechanisms adopted by the same.
The task of supervising the operation of and compliance with the Organisation, Management and Control Model and ensuring its updating has been entrusted to a Supervisory Body (SB), made up of five members identified as follows:
- all the members of the Control and Risks Committee, who are independent and non-executive directors;
- one or two additional third-party member(s) with suitable professional skills and expertise, or a senior manager of the Company in charge of the Audit Department or the Compliance and Anti-Money Laundering Department.