Pursuant to Legislative Decree No. 231/2001, Modello di Organizzazione, Gestione e Controllo MOG- the Company’s Organization, Management and Control Policy (the Policy) is a structured and integrated prevention, dissuasion and control system aimed at:
- raising awareness among all individuals who, directly or indirectly, are involved in sensitive processes (such as directors, managers, employees, and collaborators) that any unlawful conduct may lead to disciplinary consequences not only for themselves but also for the Company;
- preventing or limiting the Company’s administrative liability.
The Policy update was approved by the Board of Directors of Unipol Assicurazioni S.p.A. on 2 October 2025. The Policy is structured into a “General Part” and individual “Special Parts” concerning the various categories of crime contemplated in the Decree.
The “General Part” describes the regulatory requirements for the adoption of the Policy, the methodology used to draft it, the general control principles, the Supervisory Body, the disciplinary system for ensuring compliance with the Policy itself, and the activities aimed at its dissemination.
The “Special Parts” describe the various categories of crimes that may concretely concern the Company, examples of unlawful conduct, the sensitive processes of Unipol Assicurazioni and the control tools adopted by it.
The task of overseeing the operation of and compliance with the Policy and ensuring its updating is entrusted to a Supervisory Body (SB), which comprises five members, namely:
- all the members of the Control and Risk Committee, independent non-executive directors;
- additional members may be one or two third-party professionals with the appropriate skills and expertise, or a member of the company’s Senior Management, the Head of the Audit Department or Compliance Department.