The general principles of behavior

Model 231

WIT LOGISTICS SOC. COOP., in compliance with the provisions contained in Legislative Decree 8 June 2001 n. 231, on the "Regulation of the administrative liability of legal persons", with resolution of the Board of Directors dated 30 September 2024, has equipped itself with an Organization, Management and Control Model pursuant to Legislative Decree n. 231/2001.

The 231 corporate management Model, composed of a General Part and a Special Part, identifies the operating procedures that the company WIT LOGISTICS SOC. COOP. adopts to reduce the risk that top management and subordinates commit crimes to the benefit of the company. Model 231 of WIT LOGISTICS SOC. COOP. is a document whose preparation has examined each company department, allowing for a preliminary analysis of the "sensitive" activities, considered at potential risk pursuant to Legislative Decree 231/2001, establishing the general principles of behavior, the elements of prevention and the essential control measures designed to prevent or mitigate crimes.

Model 231 of WIT LOGISTICS SOC. COOP. is a dynamic document that is adapted to regulatory and organizational changes, in order to guarantee its adequacy and suitability. The Code of Ethics of WIT LOGISTICS SOC. COOP. is an integral part of Model 231 and defines the set of values and principles that inform the company's activity, establishing the rules of conduct for relationships with Collaborators, Customers, Suppliers and Partners.

The adoption of Model 231 is a necessary prerequisite to allow WIT LOGISTICS SOC. COOP. exemption from administrative liability in the event of commission by its directors and employees, as well as by persons acting in the name and on behalf of WIT LOGISTICS SOC. COOP. itself, of the types of crimes provided for by Legislative Decree no. 231/2001. The Board of Directors of WIT LOGISTICS SOC. COOP. has also appointed a Supervisory Body (OdV), with autonomy of action and specific powers, with the task of verifying compliance with the rules of Model 231, of ensuring its updating and of reporting to the Board of Directors all possible situations of non-compliance with the provisions of Model 231 itself.

Risk prevention

Reporting of Violations to Model 231 WIT LOGISTICS

Reports to the Supervisory Body for violations of the company's Model 231 can be sent by email to:
• email: odv@witlogistics.it
• ordinary mail addressed to: Supervisory Body WIT LOGISTICS SOC. COOP., Viale Europa Zona Ind., Battipaglia, SA 84091

Reporting Procedure - Whistleblowing
Whistleblowing is a process through which people, operating on behalf of or in favor of WIT LOGISTICS SOC. COOP. who have business relationships with the latter through any type of contract or assignment, who, in carrying out their duties within the organization to which they belong, have become aware of illicit conduct or irregularities in the context of work activity that may harm the integrity of the Company or that may cause damage to third parties.
WIT LOGISTICS, by implementing Model 231, wanted to pay particular attention to the prevention of risks that could compromise the responsible and sustainable management of its business.

In Italy, the reporting procedure is regulated by Legislative Decree no. 24 of 10 March 2023, which implements Directive (EU) 2019/19372. This decree provides for the protection of people who report violations of Union law and national regulatory provisions. Reports can be made through internal channels within the organization, external channels such as ANAC (National Anti-Corruption Authority), or through public disclosure.
In compliance with Model 231 and the ANAC whistleblowing Guidelines, WIT LOGISTICS SOC. COOP. makes available the Reporting Procedure Portal – Whistleblowing.
The ANAC guidelines, approved with Resolution no. 311 of 12 July 2023, provide details on the procedures for submitting and managing external reports. These guidelines include instructions on the transmission and acquisition of reports, as well as protections for whistleblowers, such as confidentiality protection and protection from retaliation.
For WIT LOGISTICS, Whistleblowing is an important tool in the security system. The Reporting Procedure Portal – Whistleblowing of WIT LOGISTICS SOC. COOP., thanks to its protocols, protects:

  • the identity of the whistleblower, allowing disclosure only following his/her explicit consent;
  • the identity of the reported person;
  • the confidentiality of the information in every context following the report;
  • computerized management with the archiving of reports (ref. Legislative Decree 24/2023) entrusted to the corporate bodies responsible for receiving and verifying them;
Strategic communication

Communication and dissemination of Model 231

Communication and dissemination of Model 231 are essential to ensure its effectiveness and adoption within a company.
It is essential that all employees are informed and trained on Model 231. This can be done through information meetings, training sessions, and the distribution of information material. Communication must be clear, detailed and periodic.

External partners, such as suppliers and customers, must also be informed about the adoption of Model 231.

The Supervisory Body (OdV) must receive regular information flows regarding the sensitive processes identified. This allows monitoring the effectiveness of the model and timely intervention in the event of critical issues.
Communication must be planned strategically, identifying the recipients and specific content for each group. For example, employees can receive detailed communications on operating procedures, while external partners can receive general information on the adoption of the model.

It is important to use various communication channels, such as email, company intranet, bulletin boards, and regular meetings, to ensure that the message reaches all recipients effectively.