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- MODEL 231

Gommatex Spalmati Srl has adopted an organization, management and control model (Model 231) for the prevention of crimes committed in the interest or to the advantage of the company. Also in order to ensure effective application, Gommatex has developed a specific training program for all personnel.

The Legislative Decree 8.06.2001 n. 231 introduced, for the first time in our legal system, the provision of a personal and direct liability of the collective body for the commission of a series of crimes by the natural persons connected to it, who acted in the interest or to the advantage of body, who hold top positions.

Legislative Decree 231/01 establishes the responsibilities of the employer and the company in the event of offenses committed by its employees. In such cases, the employer can protect himself from legal actions if he can demonstrate that he has adopted and effectively implemented an organization, management and control model suitable for preventing crimes of the kind that occurred.

The "antidote" to avoiding the involvement of the company or the Entity by invoking the exclusion or limitation of one's liability deriving from one of the crimes provided for by law is first of all to have an adequate Organizational Model and to rely on a Supervision that controls its implementation.


The Gommatex Code of Ethics defines the principles of business ethics that the Company and its employees recognize, accept and promote. Model 231 is both a support tool and a central element of Gommatex's Code of Ethics. The Supervisory Body and the other forms of control and monitoring provided for in Model 231 are also fundamental elements of the Code of Ethics.

Model 231 is made up of an organic set of principles, rules, provisions regarding the management and control of each corporate process.

Gommatex pays great attention to the implementation of Model 231, with particular reference to the implementation of company procedures, staff training and the performance of specific control programs through internal audits.

First adoption of Model 231 by Gommatex Spalmati Srl and related updates 

Gommatex's 231 Model was approved for the first time in 2021. 

In this regard, a Supervisory Body has been appointed and all those who wish to communicate with the SB can do so using the following email

In compliance with Article 16 of Legislative Decree 81/2008, the delegation of functions, pursuant to Legislative Decree 231/2001, was drawn up in compliance with the essential requirements and adequately published. (attach proxies)

This model has been updated in accordance with the changes introduced by the European Union, in relation to the list of Predicate Offenses, issuing a revision of January 2022.

Training and involvement 

In line with the principles of continuous improvement of the control system and the awareness of transmitting the content of Model 231, both inside and outside the Company, in order to ensure effective application, training courses are periodically held .

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