The company EBRILLE Ltd. with a resolution of 08/11/2019 approved the adoption of an Organizational Management Model (below MOG) under The Legislative Decree 231/2001 Also on the same date was appointed the Supervisory Board (below ODV) to which was entrusted with a budget of expenditure. The ODV is entrusted with all the functions and responsibilities provided by the MOG.
Depending on the involvement in potential areas at risk of crime, the following subjects are identified as recipients of the Model:

  • members and administrators;
  • employees;
  • supervisory body;
  • third parties (stakeholders): suppliers, customers, external collaborators, Public Administration, citizenship.

The Organizational Model represents a set of behavioural procedures and specific provisions applied in every area and in every process of the Ebrille Ltd in order to prevent the commission of crimes defined as prerequisite and regulated by the Legislative Decree 231/2001.
The Organizational Model adopted consists of:

  • General part
  • Special part
  • ODV regulation
  • Ethical code

In the general part, the company's intentions, the general provisions for all personnel involved and the list of offences mentioned above are indicated. The special part shows the provisions and procedures of activities related to the alleged crimes, are divided according to the offences applied and based on the correlation of the activities established by the Quality Management System and Risk Assessment Document adopted.
The ODV is entrusted with the task of supervising:

  • effectiveness and compliance with the Model;
  • model's effectiveness and adequacy in relation to the company structure and the effective ability to prevent the commission of crimes referred to in d.lgs. 231/01;
  • model upgrade, where there are needs to adjust to the Model in relation to changing business conditions and/or regulations.

All reports of alleged violations of the MOG's procedures must be forwarded via e-mail service to
Reports should contain:

  • the commission of the offence adopted by the MOG and therefore the non-enforcement of established procedures;
  • the precise indication of the incident and the identification of the person who committed the crime;
  • identification of the person responsible for the report.

For reports it is necessary to fill in all its parts of the reporting form to be sent to the ODV by e-mail always at the address Anonymous reports will not be accepted by the ODV.
The Code of Ethics establishes the behaviors, values and compliance with the procedures adopted by the MOG.