Model 231

Xenia's guidelines for managing company activity

General principles

Italian Legislative Decree no. 231 of 8 June 2001 introduced into the Italian legal system a series of administrative responsibilities for institutions – including joint stock companies –  for certain crimes committed by directors, managers, or employees in the interest of or to benefit the institution.

Adoption of the organisational structure

In order to comply with the provisions of Legislative Decree 231/01 as amended, so as to guarantee that company activities are performed in a just and ethical manner, Xenia deemed it appropriate to provide itself with an Organisational Structure for risk management, with the goal of building a structured, organised system of guidelines, operating procedures, and other specific tools inspired by criteria of good practice in company management and aimed, among other things, at preventing the crimes provided for by the Decree.

Supervisory Board

With reference to the above and in compliance with the provisions of Legislative Decree no. 231/01, Xenia has formed a Supervisory Board (composed of three members independent of the company – Mr Luigi Pecorario, serving as Chairman; Mr Marco Giuliani and Mr Francesco De Luca as members) in charge of overseeing its functioning, efficacy, and compliance with the requirements of the Organisational Structure on the part of all those it addresses, assessing any need for updating.

Members of the Supervisory Board are appointed for three years, until February of 2022.