Organization, management and control model

In 2011, the UN Human Rights Council unanimously endorsed the UN Guiding Principles on Business and Human Rights (UNGPs). The Guiding Principles emphasized, on one hand, the State duty to protect human rights, and, on the other, business enterprises’ responsibility to respect them. In order to meet their responsibility to respect human rights, business enterprises should conduct a “human rights due diligence” (HRDD) process aimed at identifying, preventing, mitigating and accounting for negative human rights impacts in their business relationships. Given the high level of consensus around the UNGPs, human rights due diligence has become a fundamental notion for today’s Businesses.

Within this framework, Italian Legislative Decree (L.D.) No. 231/2001, which introduces a due diligence process that covers both specific  human rights violations and specific severe impacts on the environment, can reasonably be considered a pioneer example of mandatory due diligence legislation.

A parent company can be held responsible under L.D. No. 231/2001 for a crime committed within another company of the group, provided that a natural person acting on behalf of the holding company contributed to the crime in order to pursue the interests of the holding company. 

With the adoption of the Organization, Management and Control Model, IGLI intends to comply with the principles underpinning Italian Leg. Decree 231/01 and to fully implement it, as well as to make its Control and Corporate Governance systems more effective, in particular in preventing the commission of offences involving liability pursuant to and for the purposes of the law.

This Model is part of the broader Internal Control and Risk  Management System ( SCIGR) of the Company, the essential elements of which are defined in Internal Control and Risk Management System Guidelines approved by the Board of Directors. The SCIGR is inspired by best practice existing nationally and internationally. In particular, this system takes into account the recommendations of the Corporate Governance Code of Borsa Italiana and is defined consistently with the models Enterprise Risk Management – Integrated Framework ( CD COSO Report) is Internal Control – Integrated framework, issued by the Committee of  Sponsoring Organizations of the Treadway Commission, which represent the reference models, internationally recognized, for the integrated analysis and evaluation of the effectiveness of the SCIGR.