MODEL 231

Organization, Management, and Control Model (Legislative Decree 231/2001)

GEOSAT Srl’s Commitment to Legality, Transparency, and Corporate Responsibility

GEOSAT Srl has adopted its Organization, Management, and Control Model pursuant to Legislative Decree No. 231 of June 8, 2001, aware of the importance of operating in full compliance with the laws, ethical principles, and values ​​that have always distinguished its business. The adoption of Model 231 represents not only a regulatory requirement, but a strategic choice of corporate responsibility and ethical governance, aimed at promoting a culture based on integrity, transparency, and risk prevention.

What is Model 231?

Legislative Decree 231/2001 introduced into Italian law the administrative liability of legal entities for certain crimes committed, in their interest or to their advantage, by individuals holding positions of representation, management, or control. In other words, Legislative Decree 231 provides that companies may also be held liable for crimes committed by managers or employees if they lack adequate organizational prevention models.

To prevent such situations and demonstrate its commitment to legality, GEOSAT Srl has adopted an Organization, Management, and Control Model inspired by the principles of the Decree and the guidelines issued by trade associations. The Model consists of two main parts:

  • General Part – describes the structure, purposes, and principles of the internal control system, as well as the role of the Supervisory Board;
  • Special Part – identifies the risk areas and the control procedures adopted to prevent the commission of the crimes envisaged by the Decree..

The Code of Ethics

GEOSAT Srl’s Code of Ethics is an integral part of Model 231 and represents the charter of fundamental values ​​that guide corporate decisions and the behavior of all those who work with and for the company: directors, employees, collaborators, consultants, suppliers, and business partners.

The Code promotes principles such as:

  • integrity, transparency, and fairness in business relationships;
  • respect for people, the environment, and regulations;
  • loyalty and social responsibility towards customers, suppliers, and institutions.

The Supervisory Board (SB)

GEOSAT Srl has established a Supervisory Board (SB) with autonomy, independence, professionalism, and continuity of action. The SB is responsible for overseeing the effective implementation and compliance with Model 231, its adequacy and updating in relation to organizational and regulatory changes, and the emergence of any violations or non-compliant behavior. The SB of GEOSAT Srl operates with full autonomy and reports directly to the Board of Directors.

Anyone who becomes aware of behavior potentially in violation of Model 231 or the Code of Ethics can contact the Supervisory Board via the following dedicated email address:

📧 odv@geosatsrl.it

Whistleblowing and whistleblower protection

GEOSAT Srl has activated an internal whistleblowing channel compliant with Legislative Decree 24/2023, which allows employees, collaborators, and third parties to report violations or irregularities in good faith. Reports can be submitted via the secure internal channel available on the company website or via email to the dedicated address.