Organizational Model pursuant to Italian Legislative Decree 231/2001 (MOG 231)
Carrara S.p.A. has adopted an Organizational, Management and Control Model pursuant to Italian Legislative Decree 231/2001 (“MOG 231”).
Although this regulation is specific to Italy, it is aligned with internationally recognized compliance and governance principles. The Decree introduced corporate liability for certain crimes (including corruption, fraud, environmental crimes, workplace safety violations and human rights–related offenses).
The MOG 231 is a structured compliance framework designed to:
- Prevent criminal conduct within the company
- Ensure lawful, ethical and transparent business operations
- Assign clear responsibilities and control mechanisms
- Establish monitoring and reporting procedures
- Protect stakeholders and corporate integrity
An independent Supervisory Body (Organismo di Vigilanza) is appointed to oversee the effective implementation of the Model, conduct audits, and verify compliance with the Code of Ethics and internal procedures.
Integration with ESG Governance
Carrara’s MOG 231 framework is fully integrated with its ESG governance approach. Compliance activities are not limited to legal conformity, but extend to structured assessment programs covering:
- Anti-corruption
- Human rights
- Health, Safety & Environment (HSE)
- Responsible supply chain management
These assessments are risk-based, periodic and documented.
Key Assessment Areas
- Anti-Corruption Assessments
Carrara conducts specific assessments aimed at preventing bribery and corrupt practices, including:
- Risk mapping of sensitive business activities
- Segregation of duties and approval controls
- Due diligence on intermediaries and third parties
- Monitoring of payments, gifts and hospitality
- Whistleblowing mechanisms with protection against retaliation
- Periodic internal audits performed by the Supervisory Body
These controls are designed to ensure full compliance with Italian law, international anti-bribery standards, and ESG governance principles.
- Stakeholder & Supply Chain HSE Assessments
Carrara extends its governance model beyond its internal perimeter through:
- Supplier qualification procedures including HSE criteria
- Contractual clauses requiring compliance with safety and environmental standards
- Audits and performance monitoring of key suppliers
- Verification of workplace safety practices
- Environmental compliance checks
Internal stakeholders are also subject to regular HSE audits, ensuring adherence to occupational health and safety laws and environmental protection standards.
- Human Rights Assessments
In line with ESG principles and international human rights standards, Carrara implements:
- Code of Ethics commitments aligned with fundamental labor rights
- Zero tolerance for forced labor, child labor and discrimination
- Monitoring of working conditions internally and within the supply chain
- Risk assessments related to human rights exposure
- Training and awareness programs for employees
These measures aim to ensure respect for human dignity, fair working conditions and responsible business conduct.
Governance Commitment
Through the adoption of the MOG 231 and its ESG-aligned assessment activities, Carrara ensures that:
- Governance processes are structured, documented and independently monitored
- Risks of corruption and misconduct are systematically mitigated
- Stakeholders are protected through transparent and accountable systems
- Business activities are conducted in compliance with applicable laws and international sustainability principles
The MOG 231 therefore represents not only a legal compliance tool under Italian law, but a robust governance framework consistent with global ESG expectations.
