Organizational model

Dear Sirs,
Santa Monica S.p.A has been pursuing forever a business policy based on entrepreneurial values in the administration of its activities based on efficiency, integrity and loyalty in all daily management process.
Our company has adopted the organization and management model as laid down in Legislative Decree Nr. 231,June 8th 2001, which has introduced an administrative and criminal liability scheme borne by the company for some types of crime as foreseen by the Legislative Decree 231/01, adapting in this way the organizational model, the management and control to the law prescriptions.
The adopted model is a set of general principles, rules of conducts, control instruments, organizational and operating procedures, training and information activities, disciplinary system, supervisory body aimed also to ensure the crime prevention foreseen by the Legislative Decree. The Administrative board definitively approved the organization, management and control model as indicated in the Legislative Decree 231/01 on March 29th 2010, together with the nomination of the supervisory body.
The Company is persuaded that the adoption of that Model will constitute an excellent tool for raising awareness among all members acting on behalf of the company and to follow correct and right behavior when carrying out their tasks and also an essential means of prevention against risk of criminal acts and administrative offences laid down in the Decree.
The adopted model represents a clear message of the Company about transparency and sense of responsibility in both internal and external relationships.
Furthermore, Santa Monica S.p.A has adopted a Code of Ethics establishing all the values the Company recognizes, agrees and supports at all levels in carrying out its activities.
The principles and guidelines of the a Code of Ethics serve as specifications of general duty of care, correctness and loyalty which qualify the performance of the task, the behavior in the working environment and the activities carried out by the company itself.
The principles and guidelines of the a Code of Ethics are mandatory for the administrators and the employees and anyway for everybody associated with Santa Monica S.p.A. The management board has also adopted the Code of Ethics on March 29th , 2010.
The article 6, (1)(b) of the Legislative Decree nr. 231/2001 identifies, among the requirements, the establishment of a supervisory agency, in order to exempt the Company from liability for the criminal acts listed in the Decree, with independent power of initiative and control and the task to ensure compliance with the organizational model and its updating. This is an internal agency which is independent and impartial from other bodies of the Company.
In order to perform its task, a continuous exchange of information between the recipients of the model and the agency is necessary.
Therefore, the supervisory body is also the addressee of warnings of possible violations of the organizational model adopted by the company, at following address:
– Postal mail to the address : Santa Monica S.p.A. – Supervisory body, Via Daijiro Kato n.10 47843 Misano Adriatico (RN).
– e-mail to the account [email protected]

– using the proper form on the website https://gruppofinanco.integrityline.com/