Compliance

Legislative Decree no. 231 of 8 June 2001 (Lgs. Decree no. 231/2001) provides for a direct liability of legal entities, companies and associations for certain crimes committed by their representatives. The Italian legislator has constantly widened the scope of application of Lgs. Decree no. 231/2001 by ext ending the list of relevant crimes. Comapnies are more and more required to adopt an organisational, management and control scheme in compliance with this law.

Integré decided to adopt an organisational, management and control scheme because, beyond the legal obligation, it will be a positive driver to enforce Management Group's responsibility, transparency and efficiency. The adoption of the organisational, management and control scheme represents a milestone in preventing crimes (i.e. corruption, misappropriation of public funds, money laundering, market abuse, otehr corporate crimes...) and in a continuous improvement of operations and of the organisational model.

See attached the two documents "General organisational, management and control scheme" and "Code of ethics".

Whistleblowing 

Whistleblowing is the lawful disclosure of information a discloser reasonably believes evidences wrongdoing to an authorized recipient . It is the mechanism to get the right information to the right people to counter wrongdoing and promote proper, effective, and efficient operation. In 2019, the European Union (EU) passed a groundbreaking Whistleblower Directive (2019/1937) to enact greater protections for whistleblowers by shielding them from retaliation and creating “safe channels” to report violations of the law. The Directive is enforce in Italy by Legislative Decree no. 24/2023.

Integré, in compliance with Legislative Decree no. 24/2023, has identified specific and dedicated communication channel for whistleblowing:

  • Telegram messenger secret chat: +39 3287725198 
  • Email: odv.integre@gmail.com. Please be aware not to use an email address that can be traced back to the sender 
  • Mail: Studio Associato Ambrosetti, Piazza del Duomo 5, 36100 Vicenza  

Whistleblowing manager and personal data protection policy 

Whistleblowing manager: Integré Supervisory Board, appointed as per 231/2001 

Whistleblowing data controller: Integré Supervisory Board