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D.lgs. 231/2001


Organization, Management and Control Model pursuant to Legislative Decree 231/2001.

As part of the initiatives to strengthen its internal control system, FITD and the Voluntary Intervention Scheme (VIS) have adopted an Organization, Management and Control Model, pursuant to Legislative Decree 231/2001, for monitoring risk of offences as regards the Fund and VIS activities.
The 231 Models of the FITD and VIS are periodically reviewed and updated, in the light of monitoring by the Supervisory Bodies and staff support.

On 15 December 2022, the FITD Board and the VIS Management Board approved the latest updates to the Models to give effect to updated regulatory provisions.

Objective of the Organization Management and Control Model

The Model sets out a system of prevention and control to reduce any risk of offences connected with the Fund’s activities. It cautions all who carry out activities for and on behalf of the Fund - in particular, in activities considered at risk - of the possibility of incurring legal and administrative charges for violation of these provisions.

Composition and Supervisory Bodies

The members of the Supervisory Bodies, as decided by the Bodies on 17 November 2022, are Luigi Panella (Criminal lawyer and Supervisory Board Chairman) and auditors Prof. Maurizio Comoli and Dr. Francesco Passadore.

The 231 Models consist of a General Part containing the core principles - including those relating to the functioning of the Oversight Committee - and a Special Part outlining various categories of offenses covered by the Decree and applicable to the FITD and Voluntary Scheme.

How to submit a report

Based on the provisions of the Model, communications on events that could relate to the FITD pursuant to Legislative Decree 231/2001, can be sent to the following e-mail address: panella.odvfondo@fitd.it.
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