Governance
Institutional governance encompasses rules and practices to ensure transparency and corporate integrity. The 231 Model and Whistleblowing are central tools for preventing misconduct and promoting ethical behavior, strengthening internal control and regulatory compliance.
231 Model
Legislative Decree No. 231 of June 8, 2001 (“Regulation of the administrative liability of legal entities, companies, and associations, including those without legal personality, pursuant to Article 11 of Law No. 300 of September 29, 2000”) introduced administrative liability for entities under Italian law for certain types of offenses committed in their interest or to their advantage by specific individuals.
Accordingly, Thaleia has adopted, in compliance with this Decree, an organizational, management, and control model (“231 Model”), which includes a code of ethics (“Code of Ethics”), and has appointed a Supervisory Body to oversee compliance, operation, and updates of the 231 Model. You can review it by clicking the link below.
231 Model and Code of Ethics
Whistleblowing
Legislative Decree No. 24 of March 10, 2023 (“Implementation of EU Directive 2019/1937 of the European Parliament and Council, dated October 23, 2019, concerning the protection of individuals reporting violations of EU law, and provisions regarding the protection of individuals reporting violations of national regulations”) introduced protections for individuals who report misconduct or violations encountered within the scope of their employment.
In accordance with this regulation, Thaleia has implemented a specific procedure (“Whistleblowing Procedure”) to provide guidelines on how to make and manage reports, its scope, and protective measures.
Thaleia offers employees, directors, shareholders, and third parties collaborating with the company the opportunity to report—also anonymously—any misconduct or violations they have become aware of in the course of their working relationship with Thaleia. This can be done through an online platform that allows users to describe the reported events while safeguarding the confidentiality of the report's content, the identity of the whistleblower, and any involved parties.
“Violations” refer to actions, omissions, or conduct that could harm the public interest, public administration, the company, or violate the company's administrative, management, and control model (the “231 Model”) adopted in accordance with Legislative Decree 231/2001.
The management and verification of reports’ validity are handled by the Report Manager, who in Thaleia’s case is the Supervisory Body. The Supervisory Body may collaborate with external consultants or relevant internal departments. Any personal data processed will be treated in compliance with applicable regulations and retained strictly for the time necessary to manage the report, and in any case for no more than five years after the report's closure.
Through the links below, you can review the Whistleblowing Procedure, the Whistleblowing Privacy Notice, and access the dedicated platform for submitting a report.