The Legislative Decree no. 231 of June, 8th 2001 pertaining to the “Administrative liability of legal entities, companies and associations, including those lacking legal personality” (hereinafter: the “Decree”) is a piece of Italian legislation enacted to implement the commitments undertaken by Italy at community and international level in the fight against corruption. The Decree has indeed introduced in the Italian legal system the liability of entities in the case of administrative offences resulting from a crime committed by persons that represent an entity or who, in any case, perform certain duties within that entity.

Pursuant to the Decree, we have decided to adopt our organizational, management and control model (hereinafter: the “Model”), which will be periodically revised and updated, in the belief that it represents, inter alia, a tool for improving our organizational structure as well as an opportunity to raise awareness among all its recipients of the need to prevent and/or impede the commission of the offences referred to in the Decree 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

by standard mail to the address of the Surveillance Body: 

S.B.A. Avvocati, all’ 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.