{"id":693,"date":"2016-04-09T10:39:33","date_gmt":"2016-04-09T08:39:33","guid":{"rendered":"http:\/\/www.mesgo.it\/en\/modello-231\/"},"modified":"2026-02-19T14:38:29","modified_gmt":"2026-02-19T13:38:29","slug":"model-231-and-ethic-code","status":"publish","type":"page","link":"https:\/\/www.mesgo.it\/en\/model-231-and-ethic-code\/","title":{"rendered":"Model 231 and code of Ethics"},"content":{"rendered":"<h1>Model 231 and Code of Ethics<\/h1>\n<p>&nbsp;<\/p>\n<p><strong>MESGO<\/strong> has adopted its own organization, management and control model pursuant to Legislative Decree 231\/2001 and subsequent amendments and integrations (Model 231).<\/p>\n<p>Model 231 consists of a general section \u2013 outlining contents and objectives \u2013 and a special section \u2013 identifying offenses relevant to the company\u2019s activities, together with internal ethical principles.<\/p>\n<p>The main goal of Model 231 is to implement an effective internal control system capable of mitigating the risk of committing relevant offenses and, consequently, exempting MESGO from liability under the Decree.<\/p>\n<p>An integral part of Model 231 is the Code of Ethics, which expresses the core values of MESGO Group\u2019s business ethics: legality, honesty, transparency, and professional integrity.<\/p>\n<p>To request the latest version of the general section of Model 231 and\/or the Code of Ethics, please send a written request to: <strong><a href=\"mailto:info@mesgo.it\">info@mesgo.it<\/a><\/strong>.<\/p>\n<p>&nbsp;<\/p>\n<p><strong>HEXPOL Garlasco S.r.l.<\/strong>, committed to ensuring compliance with laws and regulations, integrity, and transparency in business conduct, has adopted its own organizational, management and control model (<strong><a href=\"https:\/\/www.mesgo.it\/wp-content\/uploads\/2026\/02\/Hexpol-Garlasco-Srl_Parte-Generale-MOG-231-en-GB.pdf\">231 Model<\/a><\/strong>) consisting of procedures, organizational safeguards and rules of conduct (integrated into existing management systems), with the aim of preventing unlawful behaviors under Legislative Decree 231\/2001 and fostering a culture of ethics, transparency, and legality.<\/p>\n<p>The <strong><a <a href=\"https:\/\/www.mesgo.it\/wp-content\/uploads\/2026\/02\/Hexpol-Garlasco-Srl_CODE-OF-ETHICS-en-GB.pdf\">Code of Ethics<\/a><\/strong> , an integral and substantial part of Model 231, outlines the values recognized by the company, behavioral principles, and rules to be followed in both internal and external relations, including those with institutions, suppliers, customers, and business partners.<\/p>\n<p>Model 231 and the Code of Ethics apply to:<br \/>\n\u2022 corporate governance, administrative, and control bodies;<br \/>\n\u2022 corporate officers: those who perform \u2013 formally or informally \u2013 functions of management, administration, direction, or control within the company;<br \/>\n\u2022 employees;<br \/>\n\u2022 all parties having relationships with HEXPOL Garlasco S.r.l. (e.g. customers, suppliers of goods, works, and services, business partners), and individuals not bound by corporate or employment ties who act on its behalf or in its interest (e.g. consultants and outsourcers, service contractors, agents, and intermediaries).<br \/>\nFailure to comply with the principles and rules set forth in the Model and Code of Ethics constitutes a disciplinary offense for employees and a cause for termination or penalties for third-party contractors (e.g. suppliers, business partners, agents, clients, consultants), without prejudice to compensation for any resulting damage.<\/p>\n<p>In compliance with regulations, HEXPOL Garlasco S.r.l. has appointed a Supervisory Body (\u201cSB\u201d) tasked with overseeing the functioning, effectiveness, and observance of the Model and Code of Ethics, as well as ensuring constant updates. The SB has been established as a single-person body, meeting the requirements of autonomy, independence, and professionalism set by applicable laws.<br \/>\nThe SB is also responsible for receiving and handling reports of suspected violations of the Model and\/or Code of Ethics through the internal reporting channel.<\/p>\n<p>&nbsp;<\/p>\n<p><strong>3A MCOM S.r.l.<\/strong>, committed to ensuring compliance with applicable laws and regulations, integrity, and transparency in business activities, has adopted its own organizational, management and control model (<strong><a href=\"https:\/\/www.mesgo.it\/wp-content\/uploads\/2024\/12\/3A-MCOM_Parte-Generale-MOG-231-1.pdf\">Model 231<\/a><\/strong>) consisting of procedures, organizational safeguards and rules of conduct (integrated into existing systems), aimed at preventing offenses as defined by Legislative Decree 231\/2001 and promoting a corporate culture based on fairness, transparency, and legality.<\/p>\n<p>The <strong><a href=\"https:\/\/www.mesgo.it\/wp-content\/uploads\/2024\/12\/3A-MCOM_Codice-Etico-1.pdf\"><\/a><\/strong>, an integral and substantial part of Model 231, expresses the values recognized by the company, principles of conduct, and rules to be followed in dealings inside and outside the company, with institutions, suppliers, customers, and business partners.<\/p>\n<p>Model 231 and the Code of Ethics apply to:<br \/>\n\u2022 corporate governance, administrative, and control bodies;<br \/>\n\u2022 corporate officers: those who perform \u2013 formally or informally \u2013 functions of management, administration, direction, or control within the company;<br \/>\n\u2022 employees;<br \/>\n\u2022 all parties having relationships with 3A MCOM S.r.l. (e.g. customers, suppliers of goods, works, and services, business partners), and individuals not bound by corporate or employment ties who act on its behalf or in its interest (e.g. consultants and outsourcers, service contractors, agents, and intermediaries).<br \/>\nFailure to comply with the principles and behavioral rules outlined in the Model and Code of Ethics constitutes a disciplinary offense for employees and a cause for termination or penalties for third-party contractors (e.g. suppliers, business partners, agents, clients, consultants), without prejudice to compensation for any resulting damage.<\/p>\n<p>In compliance with regulations, 3A MCOM S.r.l. has appointed a Supervisory Body (\u201cSB\u201d) to monitor the operation, effectiveness, and observance of the Model and Code of Ethics, and to ensure their continuous update. The SB has been established as a single-person body, in accordance with legal requirements for autonomy, independence, and professionalism.<br \/>\nThe SB is also responsible for receiving and managing reports of suspected violations of the Model and\/or Code of Ethics submitted through the internal reporting channel.<\/p>\n<p>&nbsp;<\/p>\n<h1>Whistleblowing<\/h1>\n<p>&nbsp;<\/p>\n<p><strong>MESGO<\/strong> encourages the reporting of any misconduct, dishonest, or potentially illegal activity \u2013 whether potential, likely, or already committed \u2013 as well as behavior that may cause harm or damage, including reputational harm, to the Company.<\/p>\n<p>The operational procedure describes the methods and steps for submitting, receiving, and analyzing reports, in compliance with applicable legislation and current best practices. You can consult the procedure at this <strong><a href=\"https:\/\/www.mesgo.it\/wp-content\/uploads\/2024\/09\/Regole-procedurali-21mar24_bis.pdf\" target=\"_blank\" rel=\"noopener\">link<\/a><\/strong>.<\/p>\n<p>&nbsp;<\/p>\n<p>Download the reporting form at this <strong><a href=\"https:\/\/www.mesgo.it\/wp-content\/uploads\/2024\/06\/Modulo-invio-segnalazioni-27feb24.pdf\" target=\"_blank\" rel=\"noopener\">link<\/a><\/strong>.<\/p>\n<p>&nbsp;<\/p>\n<p>To submit a report, please send a written request to: <strong><a href=\"mailto:segnalazioni@mesgo.it\">segnalazioni@mesgo.it<\/a><\/strong>.<\/p>\n<p>&nbsp;<\/p>\n<p><strong>HEXPOL Garlasco S.r.l.<\/strong> is committed to operating ethically and responsibly and expects the same from its employees, consultants, and collaborators, in compliance with laws, regulations, authority provisions, company policies, and procedures.<br \/>\nThe company strongly encourages its stakeholders to report any misconduct, dishonest, or potentially illegal activity \u2013 whether potential, likely, or already committed \u2013 and any behavior that may cause harm or damage, including reputational damage, to the company.<br \/>\nTo this end, HEXPOL Garlasco S.r.l. has implemented a digital reporting channel that ensures confidentiality of the whistleblower\u2019s identity, the persons involved, the content of the report, and any related documentation, in accordance with Legislative Decree 24\/2023 implementing EU Directive 2019\/1937 on the protection of whistleblowers.<\/p>\n<p>&nbsp;<\/p>\n<p>The <strong><a href=\"https:\/\/www.mesgo.it\/wp-content\/uploads\/2026\/02\/Hexpol-Garlasco-Srl_Procedura-WB-en-GB-compresso.pdf\">Whistleblowing Procedure<\/a><\/strong> describes the methods and steps for submitting, receiving, and analyzing reports, in accordance with the legislation and best practices.<\/p>\n<p>&nbsp;<\/p>\n<p>Go to the <strong><a href=\"https:\/\/mesgoiridecolors.smartleaks.cloud\" title=\"Reporting form\" target=\"_blank\" rel=\"noopener\">Reporting Form<\/a><\/strong>.<\/p>\n<p>&nbsp;<\/p>\n<p>HEXPOL Garlasco S.r.l., in compliance with Legislative Decree 24\/2023, protects whistleblowers acting in good faith from any form of retaliation or penalization \u2013 even attempted or threatened \u2013 related directly or indirectly to the report, which causes or could cause unjust harm to the whistleblower. Personal data related to reports is processed in compliance with EU Regulation 679\/2016 and Legislative Decree 193\/2006 on data protection and proper data management. <strong><a href=\"https:\/\/www.mesgo.it\/wp-content\/uploads\/2026\/02\/HEXPOL-Garlasco-Srl_Informativa-whistleblower-en-GB.pdf\">Privacy Policy<\/a><\/strong><\/p>\n<p>&nbsp;<\/p>\n<p><strong>3A MCOM S.r.l.<\/strong> is committed to operating ethically and responsibly and requires its people, consultants, and collaborators to comply with laws, regulations, authority provisions, and company policies and procedures.<br \/>\n3A MCOM S.r.l. strongly encourages stakeholders to report any misconduct, dishonest, or potentially illegal activity \u2013 whether potential, likely, or already committed \u2013 and any behavior that may cause harm or damage, including reputational damage, to the company.<br \/>\nTo this end, 3A MCOM S.r.l. has activated a digital channel ensuring the confidentiality of the whistleblower\u2019s identity, the persons involved, and the content and documentation of the report, in accordance with Legislative Decree 24\/2023 and EU Directive 2019\/1937.<\/p>\n<p>&nbsp;<\/p>\n<p>The <strong><a href=\"https:\/\/www.mesgo.it\/wp-content\/uploads\/2024\/12\/3AMCOM_Procedura-WB-1.pdf\">Whistleblowing Procedure<\/a><\/strong> describes the methods and steps for submitting, receiving, and analyzing reports, in compliance with the law and best practices.<\/p>\n<p>&nbsp;<\/p>\n<p>Go to the <strong><a href=\"https:\/\/3amcom.smartleaks.cloud\" title=\"Reporting form\" target=\"_blank\" rel=\"noopener\">Reporting Form<\/a><\/strong>.<\/p>\n<p>&nbsp;<\/p>\n<p>3A MCOM S.r.l., in compliance with Legislative Decree 24\/2023, protects whistleblowers acting in good faith against any form (even attempted or threatened) of retaliation or penalization for reasons directly or indirectly related to the report, which causes or could cause unjust harm to the whistleblower. Personal data relating to such reports is processed in accordance with EU Regulation 679\/2016 and Legislative Decree 193\/2006. <strong><a href=\"https:\/\/www.mesgo.it\/wp-content\/uploads\/2024\/12\/Informativa_whistleblower_3AMCOM-1.pdf\">Privacy Policy<\/a><\/strong><\/p>\n","protected":false},"excerpt":{"rendered":"<p>Model 231 and Code of Ethics &nbsp; MESGO has adopted its own organization, management and control model pursuant to Legislative Decree 231\/2001 and subsequent amendments and integrations (Model 231). Model 231 consists of a general section \u2013 outlining contents and objectives \u2013 and a special section \u2013 identifying offenses relevant to the company\u2019s activities, together &hellip; <a href=\"https:\/\/www.mesgo.it\/en\/model-231-and-ethic-code\/\">Continued<\/a><\/p>\n","protected":false},"author":5,"featured_media":0,"parent":0,"menu_order":0,"comment_status":"closed","ping_status":"closed","template":"","meta":[],"acf":[],"_links":{"self":[{"href":"https:\/\/www.mesgo.it\/en\/wp-json\/wp\/v2\/pages\/693\/"}],"collection":[{"href":"https:\/\/www.mesgo.it\/en\/wp-json\/wp\/v2\/pages\/"}],"about":[{"href":"https:\/\/www.mesgo.it\/en\/wp-json\/wp\/v2\/types\/page\/"}],"author":[{"embeddable":true,"href":"https:\/\/www.mesgo.it\/en\/wp-json\/wp\/v2\/users\/5\/"}],"replies":[{"embeddable":true,"href":"https:\/\/www.mesgo.it\/en\/wp-json\/wp\/v2\/comments\/?post=693"}],"version-history":[{"count":32,"href":"https:\/\/www.mesgo.it\/en\/wp-json\/wp\/v2\/pages\/693\/revisions\/"}],"predecessor-version":[{"id":16148,"href":"https:\/\/www.mesgo.it\/en\/wp-json\/wp\/v2\/pages\/693\/revisions\/16148\/"}],"wp:attachment":[{"href":"https:\/\/www.mesgo.it\/en\/wp-json\/wp\/v2\/media\/?parent=693"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}