Anti-corruption governance system

Penta is committed to fostering a business culture characterised by fairness, transparency and adherence to the law.

In furtherance to this commitment, we have adopted our Organization, Management and Control Model pursuant to Italian Legislative Decree 231/2001 on the administrative liability of companies (the “231 Model”). This comprehensive framework establishes a structure and organic system of control principles and procedures to prevent the commission of offences in the interest or to the advantage of Penta, outlined in the Italian Legislative Decree 231/2001. It applies to the Foundation staff and people collaborating with the Foundation.

Penta’s Surveillance Body has the duty of supervising the adequacy, effectiveness and correct functioning of the 231 Model.

Click on the links below to read and download the documents which refer to our Model:

  • 231 Model (General Part): ENG | ITA
  • Annex 1 ”Crimes” to the 231 Model: ENG | ITA
  • Code of Ethics, which establishes Penta’s ethical principles and which, accordingly, must be followed by all those within the Foundation and with whom the Foundation deals: ENG | ITA
  • Conflict of Interest policy and Interest Disclosure form
  • Fraud Prevention, Anti Bribery and Anti Corruption policy

Reporting violations

According to the Italian Legislative Decree 24/2023 (“Whistleblowing Decree”), Penta guarantees the reporting, in complete confidentiality, and, if desired, also anonymously, of potential offences relevant for the Italian Legislative Decree 231/2001 through the following channels:

  • Reporting platform (available in English or Italian)

At the end of the process, you will receive a report number (randomly assigned) and you will set a password. Keep them in a safe place, you will need them to monitor the status of your report (even if you choose anonymity).

  • By contacting the Surveillance Body to request a face-to-face meeting at the following address: Via Orazio Marinali 22, 36061 Bassano del Grappa (VI), Italy, to the attention to the Surveillance Body of Penta

The reporting process is an integral part of Penta’s 231 Model. Please, read the whistleblowing policy before reporting a violation.


Who can report?

Employees, suppliers, members of the Foundation’s governing bodies, board members, consultants, trainees who work for Penta and who became aware of the violation at that time.

Can I report anonymously?

Yes, you can decide whether you want to report anonymously or not. The reporting platform allows you to choose how to report and if you choose anonymity, Penta will never be able to discover your identity. Please be aware that the reporting platform will assign you a report number and you will have to set a password even if the report is anonymous. This will not affect your choice to remain anonymous.

What can be reported?

Unlawful behaviours covered by the Decree, violations of the 231 Model and the Code of Ethics (e.g. bribery, harassment, discrimination).

What cannot be reported?

Disputes, complaints or requests related to an individual’s interest exclusively concerning each individual employment relationship (e.g. lack of salary increases); communications or complaints relating to activities carried out by Penta (e.g. complaints regarding the trainings organisation/topics/etc.).


Access the reporting platform (read the whistleblowing policy first).