INTRODUCTION

Legislative Decree n. 231 of 8 June 2001 (Lgs. Decree no. 231/2001) provides for a direct liability of legal entities, companies and associations for certain crimes committed by their representatives in their interest or advantage.

Predicate offenses
Over time the law has been extended, and the following principal crimes may trigger a company's liability:

• Tax crimes
• Crimes to the detriment of the State or public bodies
• Corruption and misappropriation of public funds
• Falsifications or counterfeiting of money, public credit cards and tax stamps
• Money laundering
• Corporate crimes
• Market abuse
• Crimes pertaining to terrorism and subversion of the democratic order
• Mutilation of female genitals
• Crimes against the person
• IT crimes and illegal data treatment
• Homicide and serious injuries through violation of the rules on safety in the workplace
• Cross-border crimes
• Environmental crimes
• Organized crimes
• Employment of illegally staying third-country nationals
• Crimes related to copyright infringement
The company's liability could be triggered if such crimes have been committed by persons in its interest or advantage.

Sanctions
Where crimes have been committed and the company cannot prove to have done what is necessary to prevent such crimes, the company may be subject to the following sanctions: pecuniary; suspension or revocation of licenses, permits and authorisations; disqualification from contracting with the Public Administration; disqualification from advertising goods and services and disqualification from financing, subsidies and other contributions. The court decision may be also published in the media.

THE ORGANISATIONAL MODEL
EX D.LGS. n. 231/2001

IMA Italia Assistance S.p.A. and IMA Servizi S.c.a.r.l. ("Company") is focused on conducting business legally and ethically, in order to prevent the commision of crimes. They adopted a Model of Organisation, Management and Control ("Model") and nominated autonomous supervisory bodies, which have to supervise the efficacy of the Model (OdV).

The adoption of the Model, the Code of Ethics (an integral part and essential general principle of Model 231) and the Anti-corruption Policy, are valid ways to sensitize employees, collaborators, suppliers etc. to ensure transparency and legacy in all transactions and behaviours in order to prevent the commission of such crimes.

OdV
The OdV of the two companies of the Group, IMA Italia Assistance S.p.A and IMA Servizi S.c.a.r.l. are collegial and supervisory bodies.
ODV, in order to carry out tasks, could access to every corporate informations and receive flow of informations from the corporate functions.

Everyone could contact the OdV to the following e-mail:

- for IMA Italia Assistance S.p.A.: odvimaitalia@imaitalia.it ;

- for IMA Servizi S.c.a.r.l.:odvimaservizi@imaitalia.it