Model 231/01

Comecer’s Organisation Model

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

The very nature of the business, focused on ensuring the safety of nuclear medicine labs, and whose ultimate aim therefore consists in helping to face and try to improve the health conditions of individuals, institutionally exalts the importance of Comecer’s moral commitment and represents a source of pride for all the people who work within the company.

In line with this Vision, since April 2012, at Comecer we have adopted an organisation, management and control model as a fundamental crime prevention instrument (“Model”) according to Legislative Decree 231 of June 8, 2001 (“Italian Legislative Decree 231/01”). The Comecer Model has been periodically updated due to the regulatory and organisational changes that have occurred since its original adoption.

The adoption and effective implementation of the Model allow the Company not only to be able to benefit from the exemption provided for by Legislative Decree 231/01, but also to constantly raise awareness in everyone who operate in the name and on behalf of Comecer regarding the correct way to act and to pursue the continuous improvement of Corporate Governance and, more generally, of the company organisation.

The Model document is made up of the following parts:

The General Part contains a concise explanation of Legislative Decree 231/01 and its contents, in addition to the rules and general principles of the Model; the identification of the Supervisory Body and the definition of the tasks, powers and functions of this body; the definition of a Model communication, information and training system; as well as the provision of periodic checks and updating of the Model.

Then there are the individual Special Parts, among which, in particular, SPECIAL PART A containing the identification of the types of crime deemed relevant for the Company, the related activities and processes at risk, as well as the preventive protocols adopted regarding each category of crime; SPECIAL PART B containing the Comecer CODE OF ETHICS; SPECIAL SECTION C relating to the disciplinary system.

As part of the Model, the Company’s Board of Directors has appointed the Supervisory Body, entrusting it with the task of supervising the functioning and observance of the Model and ensuring its updating and implementation.

Comecer’s Supervisory Body can be contacted by anyone who intends to request clarifications and more details regarding the Model, or for reports concerning the suspicion of violations of the Model, of committing one of the crimes envisaged by Legislative Decree 231 / 01 or the fraudulent violation and circumvention of the principles and prescriptions of the Model, as well as the ethical values and rules of conduct contained in the Company’s Code of Ethics, to the following addresses:

• by e-mail: [email protected]
• by ordinary mail:
  Comecer’s Supervisory Board
  via Maestri del Lavoro, 90
  Castel Bolognese (RA)
  48014 Italy

taking care to indicate that the content of the package is strictly confidential.

All recipients of the Model are required to comply with the rules and principles of conduct expressed in the same, as well as with the laws and regulations in force. In no case can the pursuit of Comecer’s interest or advantage justify conduct that does not comply with a responsible and honest line of conduct or an act contrary to current legislation.