Compliance D. Lgs 231
Following the introduction of the Law by decree nr. 231/2001 into the national legal system, corporate Bodies like Companies and Associations, even those with no legal status, hold the administrative responsibility for some crimes committed by direct or subordinate subjects on behalf and to advantage of the same Bodies.
On this ground, if crimes provided for the law are committed in the terms specified by the law, the Company (as legal entity) can be considered directly liable, unless it proves to have adopted an organization, managing and control model, such that the action turns out to have been committed by a single person, violating the firm regulations.
In order to watch over working, observance and effectiveness of the organization model, the law by decree requires Bodies to set up a specific internal Watch Committee.
To be compliant with the regulations of the Law, ATS defined its own organization and managing model, and set up the internal Watch Committee, following a special resolution of the Board of Directors.
The ATS organization and managing model is the actual realization of the lawfulness, transparency, correctness and loyalty principles, which have ever characterized its work and relationships with stakeholders.
Furthermore, in order to express principles of correct behavior and deontology in the Company, ATS defined an Ethical Code through which it exhorts all members of the firm, employees, co-operators and in general all persons taking part to the work of the firm, to conformity with such principles.
The Ethical Code of ATS, an initiative which fulfills the directives of Law nr. 231/2001, points out the set of rights, duties and responsibilities hold by the Company toward its stakeholders, and aims at recommending, promoting or forbidding particular behaviors, while harmonizing focal values of the firm with legal obligations.