Model 231/01

Comecer has always been inspired by respect for deep moral values in carrying out its business activities, in the belief that entrepreneurial success should not be separated from a socially responsible, ethical business conduct and the pursuit of well-being for the entire community.

The very nature of the business, centred on ensuring the safety of nuclear medicine laboratories, and whose ultimate aim is therefore to help deal with and try to improve the health conditions of individuals, institutionally enhances the importance of Comecer’s moral commitment, and is a source of pride for all the people who work to promote it.

In line with this Vision, Comecer has adopted an organizational, management, and control Model as a key instrument for crime prevention since April 2012, pursuant to Italian Legislative Decree No.  231/01.

The adoption of this Model not only allows the company to benefit from the exemption provided for by Legislative Decree No. 231/2001, but aims to raise awareness among all those who work in the name and on behalf of Comecer, as well as to improve Corporate Governance and the environment of corporate control in general.

Among the features and essential elements of our organizational model are:

• A Code of Ethics
• A reference to the system of corporate procedures and controls
• A Disciplinary System to punish regulation violations
• The identification of a Supervisory Body

The Supervisory Body has the task of:

• ensuring the updating of the Model and verifying its effectiveness
• reporting on the implementation of the Model to other governing bodies
• coordinating training and information to all recipients both inside the company (employees and directors) and outside (customers, suppliers, collaborators, and affiliates)

Comecer’s Supervisory Body can be contacted by anyone who wishes to ask for clarification and further details, or to submit reports concerning non-compliance with the rules, at the following addresses:

• by e-mail:
• by ordinary mail
  Comecer Supervisory Body,
  Via Maestri del Lavoro, 90
  Castel Bolognese (RA)
  48014 Italy

Our Organizational Model consists of the following sections:

• A General Section illustrating the contents of Legislative Decree no.  231/01, the basic principles of the Organizational Model, the major criminal offence categories (highlighting “activities at risk”), the “preventive protocols”, the function of the Supervisory Body, and the disciplinary and sanctioning system
• A Special “A” Section, named “Code of Ethics and Conduct“, which explains the rules of conduct that all employees and collaborators must respect and follow
• A Special “B” Section, name “Audit and Governance Activities”, which describes the business organization, and the main processes (purchasing, order management, payments, etc.) adopted by the company

All recipients of the Organizational Model are required to comply with applicable laws, regulations and procedures. In no event shall the pursuit of Comecer’s interest or advantage justify a behaviour which does not comply with a responsible, honest conduct, or any actions in conflict with the law.

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