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Model 231

In line with Legislative Decree No. 231/01, Polo Strategico Nazionale (PSN) has adopted Model 231 as an organizational, management and control tool. 

The goal is to prevent the commission, by any member of the company, of any offences and misdemeanours that could entail administrative liability for Polo Strategico Nazionale, if carried out in the interests of or to the advantage of the company.

Model 231 follows the development of current regulations, organisational and corporate changes, so as to offer an up-to-date and structured document that is integrated with the company’s guiding principles


By adopting this model, Polo Strategico Nazionale wants to communicate that:

  • it condemns any conduct in breach of regulatory provisions, its own internal regulations and the principle of transparency;
  • heavy administrative penalties may be imposed on PSN in the event that offences are committed;
  • efforts are made to intervene at an early stage, through monitoring actions, to prevent or counteract the commission of any kind of offence.

Structure of PSN’s Model 231

Model 231 consists of: 

  • a General Part, which describes the relevant regulatory framework, the Governance system and organisational structure, the adopted methodology, the powers and duties of the Supervisory Board, and the Disciplinary System, including internal training and information activities. 
  • a Special Part, which defines in detail the map of Sensitive Activities, as well as the system of controls put in place to monitor and protect these activities. 

The Model is completed by the Code of Ethics and Conduct, the Anti-Corruption Charter and the Whistleblowing Management Procedure.


The Supervisory Board

Polo Strategico Nazionale has appointed its own Supervisory Board, which has been entrusted with the task of monitoring and promoting the correct implementation and compliance with Model 231. 

The Supervisory Board is vested with powers of initiative and control, with the following requirements:


  • Autonomy and Independence. The Supervisory Board must act independently and must be able to perform its duties without any interference or influence. It must not find itself in any potential conflict of interest situation. 
  • Professionalism. The Supervisory Board must have the appropriate expertise to effectively perform its activities. 
  • Integrity. There must be no circumstances that could undermine or influence the integrity of the members of the Supervisory Board by compromising their independence and reliability. 
  • Continuity of action. The Supervisory Board carries out continuous and constant supervisory activities on the proper implementation of Model 231 to ensure its full effectiveness.