"231" Organizational Model and Code of Ethics
ORGANIZATIONAL MODEL
In alignment with ethical and governance principles and the objectives set out in its Integrated Management System, Axactor Italy Servicing S.r.l. adopted an Organization, Management, and Control Model via a Board of Directors resolution dated July 31, 2023. The Model consists of a “General Part” and a “Special Part,” the latter being accompanied by control protocols addressing the crime-related risks identified within the Model.
Concurrently with the adoption of the “Organization, Management, and Control Model,” the Company appointed a Supervisory Body (OdV) in the form of a sole member—Attorney Paolo Mascitelli—supported by an internal contact person.
A dedicated communication channel with the Supervisory Body has been established at the email address odvcrservice@gmail.com; this address is to be used for submitting reports in accordance with the Whistleblowing policy (which also provides for other internal reporting channels) and is accessible exclusively to the Supervisory Body.
Furthermore, to ensure the proper application of ethical and compliance principles, the Axactor Group—of which Axactor Italy Servicing S.r.l. is a part—has adopted a dedicated reporting platform.
CODE OF ETHICS
An integral part of the Model is the Code of Ethics, a document setting out the principles and rules of conduct to be adopted in dealings with stakeholders, public bodies, associations, the media, local communities, non-profit organizations, and regarding the environment and future generations.
All employees and collaborators of Axactor Italy Servicing S.r.l. who are aware of, or even merely suspect, a violation of the law, the Model, ethical standards, or company procedures must notify the Supervisory Body. The confidentiality of the report will be guaranteed, and any form of retaliation, discrimination, or adverse action against the person making the report will be prevented.
Reports regarding violations of the "Model 231" may be submitted via email to compliance@crservicesrl.eu.
By joining the UNIREC-Consumers Forum, Axactor Italy Servicing S.r.l. adopts the "Code of Conduct for credit management and protection processes" drafted in May 2017, thereby committing to "...compliance with the provisions contained therein."