CODE OF ETHICS AND MODEL 231

Administrative responsibility, management, control and conduct (“buone pratiche di comportamento”)

Ethics and solidarity

Pursuant to D.lgs (legislative decree) 231/2001 (“Modello 231”, or model 231) governing the administrative responsibilities of bodies, Fondazione Telethon adopted a “Modello di organizzazione, gestione and controllo” (organisation, management and control model). According to these rules, certain bodies (including non-profit bodies, with or without legal status) may be held responsible, and subjected to penalties, for certain criminal activities undertaken or attempted, favouring or beneficial to the such bodies, the said activities being perpetrated by “posizione apicale” (upper tier) or “soggetti sottoposti” (lower tier) individuals. In any case, the body shall not be held responsible if it proves it has “adottato ed efficacemente attuato” (adopted and effectively implemented) a model of management and control of the organisation capable of crime prevention.

Model 231

On 9 February 2012, the Board of Directors of Telethon approved “Modello 231” (model 231). By voluntarily adopting this model, in its work toward fulfilling its mission, the Fondazione wished to strengthen safeguards and guarantees for the benefit of stakeholders.

Code of ethics and vigilance body

Code of ethics

Alongside model 231, the Board of Directors, on the same day, approved the Telethon Code of Ethics, this being a key complementary component of the mechanisms for governance of administrative responsibilities within bodies. The Code of Ethics is an instrument that subsumes conduct (“buone pratiche di comportamento”). It also approves the principles upon which Telethon bases its work, and distinguishes between conduct that is in keeping or not in keeping with these principles. Lastly, in order to curb, to the greatest extent possible, arbitrary conduct in the absence of definitive rules, it provides guidance in regard to the conduct of individuals.

Vigilance body

The tasks of exerting vigilance over the functioning and efficacy of the Model, and compliance with the same, and exerting vigilance over the synergies created between Code of Ethics and the Model itself, is delegated to an “Organismo di Vigilanza” (OdV), or vigilance body, whose members are Massimiliano Lissi (a criminal lawyer, chairman) and Paolo Omodeo Salè (a professional accountant, formerly a member of the Board of Auditors). The OdV, whose members were selected and appointed by the Board of Directors, fulfils tasks and exerts functions that are duly specified in a set of rules, and that in any case conform with the provisions of D.Lgs. (legislative decree) 231/2001. Lastly, please note that the Fondazione has created its own disciplinary system.