Anti-corruption governance system

Penta is committed to implementing a business culture marked by fairness, transparency and legality. To this end, we have decided to adopt our Organization, Management and Control Model pursuant to Legislative Decree 231/2001 (the “Model”) so as to create an organic and structured system of control principles and procedures designed to prevent the commission of the offences set forth in the Legislative Decree 231/2001 and to adopt correct and transparent conduct.

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

  • Organization, Management and Control Model (General Part): ENG | ITA
  • Annex 1 ”Crimes” to the Organization, Management and Control Model: ENG | ITA
  • Code of Ethics: ENG | ITA
  • Conflict of Interest policy and Interest Disclosure form
  • Fraud Prevention, Anti Bribery and Anti Corruption policy

Reporting violations


Penta appointed Avv. Luca Andretta as Surveillance Body. Reporting violations to the Surveillance Body (see section 17 of the Code of Ethics) can be submitted as follows:

by e-mail toodvfpenta@gmail.com

by standard mail to the address of the Surveillance Body: 

S.B.A. Avvocati, all’att.ne dell’ Avv. Luca Andretta, via Orazio Marinali, n. 22, 36061, Bassano del Grappa (VI) (ITA)

S.B.A. Avvocati, to the attention of Mr. Luca Andretta, via Orazio Marinali, n. 22, 36061, Bassano del Grappa (VI) (ENG)

orally to the Surveillance Body.