COMPLIANCE

Organizational Model 231/2001, GDPR or EU Reg. 2016/679

and Integrated Management System ISO 9001 and ISO 27001.

For Digitronica.IT, Compliance means fairness and ethics in the course of its daily activities. It is not just respect or compliance to the law, it is working transparently with the primary objective of continuous improvement in all business processes, acting with responsibility and loyalty towards all stakeholders which are involved in business activities, monitoring the effectiveness and efficiency of business activities overall.

The Organizational Management and Control Model in accordance with Italian Legislative Decree 231/01 (MOGC 231) is an integral element of all company processes, as for the implementation of the GDPR n. 2016/679 or General Data Protection Regulation and the Integrated Management System (IMS)  ISO 9001 (Quality Management System) and ISO 27001 (Information Security System).  In Digitronica.IT, Compliance follows step by step the Deming Cycle or PDCA (Plan Do Check Act), taking care of the management of individual activities in order that they can be planned, performed, verified and controlled with accuracy and conformity. Every single process, every single procedure must be performed in compliance with Model 231, with the GDPR and with the QMS, following the regulations, such as the Compliance with the Company Ethic Code.

Through Compliance, Digitronica.IT wants to make perceptible to all stakeholders, the working method, its working integrity and the related “modus procedendi”, which are essential requirements for the company’s going concern.

The General Terms and Conditions are part of this process as a contractual document that settles the relationship between the parties.

Furthermore, the Company has adopted the MOGC 231, creating the basement for a deeper internal awareness, achieved on a careful analysis of the company structure and processes representing a risk, considering thus the entire organizational system.

All that led to the implementation of the MOGC 231, so composed:

  1. General Part, identifies the structural characteristics as well as the methods of creating the model and its diffusion in our Company.
  2. Special Part, details the articulation of authority and the delegation system, as well as the specific examination of risks related to individual predicate  offenses.
  3. Code of Ethics of Conduct, reports the rules which every person involved in the business activities must comply to, originating the disciplinary              system in case of non-compliance with these rules.

An integral part of Model 231 is the so-called Whistleblowing Protocol. The term whistleblowing refers to the spontaneous disclosure by an individual, called “whistleblower,” of an offence or irregularity committed by the company, which the individual witnessed in the course of his/her duties. By virtue of the entry into force of the EU Directive No.2019/1937 on Whistleblowing, the company has set up special reporting channels with the aim of ensuring the correct methods of communication to all those who become aware of incorrect or unethical acts that occurred within the organization.

The Procedure applies both to the management of Reports relevant under the Whistleblowing Decree and Legislative Decree No. 231/2001, and to the management of Ordinary Reports too. For the latter, a different regime applies in relation to the provision of the protections provided by the Whistleblowing Decree. In the case of Digitronica.IT, as of today, Reports can only concern illegal conduct relevant to the 231 discipline or violations of the Model. The Supervisory Board (OdV) of Digitronica.IT S.p.A. is the owner of the management process of Reports concerning the Company, without prejudice to the responsibilities and prerogatives of the Board of Statutory Auditors on the reports addressed to the same, including complaints pursuant to Article 2408 of the italian civil code. For further information, please refer to the appropriate “Policy according to articles 13 and 14 of the GDPR“.

The adoption of the Organizational Models, the IMS or the GDPR conformity, are the expression of the company’s compliance, responding to the need of risk prevention and the occurrence of any form of irregularity in the performance of  each activity, not only to limit the risk of committing certain types of violations, but also to ensure the proper flow of the entire organization, with the correct training, in a systematic way. Fair working and trust are the roots of the culture and reputation in Digitronica.IT.