We have equipped ourselves with an Organization, Management and Control Model, pursuant to Legislative Decree 231 of 8 June 2001, which is constantly updated in relation to regulatory and organizational changes in the company.
The model ensures fairness, integrity and transparency in the conduct of business activities, protecting the position and image of the company, the expectations of shareholders and the work of employees.
The model is divided into this “General Part”, which contains the fundamental principles and a “Special Part”, the content of which refers to the types of offence provided for by the decree and considered potentially verifiable within the company.
The general provisions describe: i) the legislative decree 231/2001; ii) the governance model and organizational structure; iii) the company’s organization and management model; iv) the supervisory board; v) the disciplinary and penalty system; vi) the communication and staff training.
We have established a specific corporate body with the task of continuously supervising the effective functioning and compliance of the company’s organizational model, taking care of its updating, and proposing amendments and/or additions to the Board of Directors.
The Supervisory Body currently in office was appointed by the Board of Directors on January 17, 2025, and is composed of three members, chosen from individuals inside and outside the company for their adequate preparation and professionalism. The members of the Supervisory Body, with autonomous powers of initiative and control, are the lawyer Alberto Capitani (Chairman) and Dr. Gianluca Rosboch.
The Supervisory Body can be contacted at the email address odv.lenovys@legalmail.it.
Lenovys, part of the Tinexta Group, has adopted and implemented the Tinexta Code of Ethics and Conduct, which sets out the moral and professional values and standards which guide us.
Through this Code we intend to guide and regulate internal and external relations, to ensure unequivocal behavior and preserve the company’s reputation.
Through a system of internal control we ensure compliance with laws and company procedures.
We entrust all members of our community with the responsibility to perform their professional duties following criteria of fairness, transparency and objectivity.
Lenovys has an internal reporting system in compliance with the requirements of Legislative Decree No.231/2001 and Legislative Decree No. 24 of 10 March2023, implementing EU Directive 2019/1937 on the protection of persons who report breaches of Union law.
In particular, in compliance with the provisions of the Decree,Lenovys employees and persons who, for various reasons, have relations with the Company(by way of example: consultants, suppliers of goods and services,business partners, shareholders, trainees) may be subject to reporting:
Reports can be made through adedicateplatform, accessible at the following link: https://digitalplatform.unionefiduciaria.it/whistleblowingnew/it/accessoprincipale/identificazionegruppo?TOKEN=TINEXTAWB , which guarantees the confidentiality of the reporter’s identity and the information containedin the report through encryption systems.Instructions for reporting can be found at the following link https://cdn.lenovys.com/uploads/2025/01/Manuale-Utilizzo-Segnalante-Whistleblowing-ENG.pdf
