The Italian Legislative Decree 231/2001 “Discipline of the administrative liability of legal persons, companies and associations, including those without legal personality” (‘231 Decree’) has introduced into the Italian legal system a regime of administrative liability for entities for offenses committed in the interest or to the advantage of the entity by: (i) individuals who hold positions of representation, administration, management or control (including de facto) of the entity or organizational areas with financial and functional autonomy and who carry out, including de facto, the management and control of the entity itself; (ii) individuals subject to the management or supervision of the above-mentioned individuals (so-called “subordinates”); (iii) individuals acting for and on behalf of the entity pursuant to a mandate and/or any collaboration or assignment agreement.
Based on these provisions, Orthofix S.r.l. has adopted the Organization, Management and Control Model (“231 Model“), which contains an organic system of principles, values, operating guidelines and ethical rules that Orthofix S.r.l. considers fundamental and inalienable for the conduct of all company activities, and of which it requires the most careful observance by the members of the corporate bodies and management, its employees, and all those who work, even de facto, for Orthofix S.r.l., including third parties such as, purely by way of example and not limited to, agents, collaborators, consultants, etc.