The internal control system described above is completed by:
- the Group’s Code of Ethics;
- the Group’s Policies;
- Organisational Model 231.
The Code of Ethics sets out the general principles which form the reference framework to perform and conduct business within Pirelli; the Code of Ethics indicates the targets and the values underlying the Company’s business activities. Indeed, Pirelli performs its internal and external business activities based on compliance with the Code of Ethics in the belief that business success cannot be separated from business ethics.
In particular, the Policies contain the “operative” statement of the principles contained in the Code of Ethics and establish rules for the entire Group designed to prevent the creation of an environment that is favourable to committing offences in general.
The Code of Ethics and the Policies have been translated in all the languages in use within the Pirelli Group (22 different languages).
The Organisational Model 231 was revised and updated constantly following changes in the laws and regulations and endeavours to assure the fine tuning of a system that is based on the specific requirements arising from the coming into force of Legislative Decree No. 231/2001 concerning companies’ administrative liability for the offences committed by their employees and is based on a structured pyramidal system of principles and procedures which can be outlined as follows, starting from the base:
- the Group’s Code of Ethics, which have already been described;
- the general internal control principles, which characterise the Internal Control System and of which the field of application extends continuously throughout the different organisational levels;
- the Policies, which have already been described;
- Internal Control schemes, which list the principal phases of each high and medium risk operative process and the specific control activities referred to the instrumental processes, aimed at achieving a reasonable prevention of the risk of committing offences, as well as special information flows to the Supervisory Body to highlight situations of possible non-compliance with the procedures established in the organisational model.
A summary of the organisational model’s guidelines is available on the Pirelli Internet website.