governace

Organisational Model 231/01: Governance, Transparency and Crime Prevention

What is the 231/01 Organisational Model and why does it matter for a company

Legislative Decree no. 231 of 8 June 2001 introduced into Italian law the administrative — and in practice criminal — liability of corporate entities for offences committed by directors, managers or employees in the interest or to the benefit of the company. The Organisation, Management and Control Model (OMCM, commonly known as the Modello 231) is the tool companies can adopt to prevent these risks and, in the event of legal proceedings, demonstrate that all necessary measures were in place.

For Sacemi Gamar, an Italian manufacturer of industrial electric pumps and motors, adopting the 231/01 Model is a deliberate statement of responsibility towards its customers, partners, suppliers and the wider community.

Why Sacemi Gamar adopted the Modello 231

Adopting the Modello 231 is not a box-ticking exercise — it is an investment in the strength of the organisation. The concrete benefits include:

• Prevention of predicate offences: corruption, fraud, environmental crimes, cybercrime and the many other violations covered by the decree.

• Exemption from or reduction of administrative liability: where an effective OMCM and an active Supervisory Body are in place, the company can exclude or limit its own liability.

• Stronger internal governance: more structured processes, effective controls and greater transparency in decision-making.

• Competitive advantage: a substantive requirement for access to public tenders and for building relationships with major clients and international partners.

• Protection of corporate reputation: it demonstrates to stakeholders that the company operates according to rigorous ethical standards.

How Sacemi Gamar's Modello 231 is structured

Sacemi Gamar's 231/01 Model is built around the components required by law and by Confindustria's Guidelines:

• Risk area mapping: identification of all company activities sensitive to the risk of offences.

• Operational control protocols: procedures and rules of conduct designed to neutralise or reduce identified risks.

• Supervisory Body (SB): an autonomous and independent body with powers of initiative and oversight, responsible for monitoring the effective implementation of the Model.

• Disciplinary system: sanctions for failure to comply with the procedures set out in the Model.

• Training and communication: programmes to embed a compliance culture at every level of the organisation.

Download Sacemi Gamar's 231/01 Model

The full documentation of the Organisational Model 231/01 adopted by Sacemi Gamar is available for consultation. Downloading the document allows customers, suppliers and partners to verify the company's commitment to ethical management and compliance with current regulations.

→ Download the 231/01 Model [PDF]

Compliance and continuity: an ongoing commitment

The Modello 231 is not a static document. Sacemi Gamar is committed to keeping the OMCM continuously up to date, incorporating regulatory changes — such as the expanded list of predicate offences introduced by Law 112/2024 — and integrating industry best practices to ensure the highest effectiveness of its internal control system.