The Organization, Management and Control Model of the “V. Florio ” Airport pursues the objective of ensuring an internal control system designed to prevent the commission of illegal conduct by its directors, employees, associates and partners, ensuring fairness and transparency in the conduct of business and business activities, To protect the Company’s position and image, employee expectations and employees’ work.
The Model, first issued in 2014 and affected by mere formal changes in 2016, was fully revised in 2020 in order to adapt it to the predicate offenses introduced by the legislator in recent years, as far as applicable to the company.
It also takes into account the changes made by the Decree implementing the PIF Directive, published in the Official Gazette on 14 July 2020 approved by the Council of Ministers on 6 July 2020 (Legislative Decree 75 of 2020). In fact, Legislative Decree 75 of 2020, relating to the fight against fraud affecting the financial interests of the Union through criminal law (the so-called PIF Directive), involves important changes in the area of administrative liability of entities pursuant to Legislative Decree no. . 231/2001, extending the catalog of predicate offenses and tightening up the sanctions set forth therein. In particular, it is noted first of all that new types of offenses relevant for the purposes of Legislative Decree no. 231/2001, such as:
– the crime of fraud in public supplies pursuant to art. 356 of the criminal code;
– the crime of fraud against the European Agricultural Guarantee Fund and the European Agricultural Fund for Rural Development pursuant to art. 2 L. 898/1986;
– the crime of embezzlement (except for the embezzlement of use) pursuant to art. 314, c. 1, c.p. and the crime of embezzlement through the profit of the error of others pursuant to art. 316 of the criminal code;
– the crime of abuse of office pursuant to art. 323 c.p .;
– inclusion of new tax offenses, in addition to those included in the previous update of the predicate offenses
– inclusion of smuggling offenses referred to in Presidential Decree n. 43/1973
The Model consists of a General Part and a Special Part. An integral part of the Model is also the Code of Ethics and, in line with ANAC Resolution no. 8 of 17 June 2015, completes and forms an integral part of the model the Three-year Plan for the Prevention of Corruption and for Transparency.
The task of supervising the functioning and observance of the Model is delegated to the Supervisory Body (ODV) of Airgest, which has autonomous powers of initiative and control. All recipients of the Model are required to promptly report any violations of the Model to the Supervisory Body and are also required to inform the Body about any official acts against them.
Reports of any violations of the Model pursuant to Legislative Decree 231/01 and/or any other information relating to its implementation, must be sent to the Supervisory Body, in writing, at the following addresses: firstname.lastname@example.org
The Supervisory Body guarantees absolute confidentiality to reports and to all parties involved, without prejudice to legal obligations and the protection of the rights of the Company or of persons accused erroneously and/or in bad faith. All communications will be taken over and examined by the Supervisory Body in order to promote, when founded, the necessary adaptation actions.
Airgest S.p.A. – Supervisory
Airport “V. Florio “of Trapani – Birgi, s.n.c.
91020 – C.da Birgi – Trapani (TP)
In addition to the aforementioned violations, strictly relating to the Company’s OMM-231, it is possible to report suspicious conduct relating to possible illicit acts, fraud, dangers or other serious risks that may threaten customers, employees, stakeholders, the general public or reputation. of society. In this regard, Airgest in order to facilitate these reports by keeping them completely confidential has created the following email address, independent and external, specifically dedicated to this: email@example.com
To download and view the digital copy of the MOG 231 click here (pdf version)