Legislative Decree 231/2001 establishes the principle of the liability of legal persons for offences committed in the interest of or for the benefit of the legal person itself by persons exercising functions of representation, administration, management or management and control of the legal person or by persons subject to one of the aforementioned parties. 

In order to comply with the provisions of Legislative Decree 231/01, as amended, and to guarantee the correctness and ethics of the company's activities, Neogy has adopted its own organisation and control model, with the aim of making the company's shareholders, directors, employees and collaborators fully aware of the provisions and related consequences of Legislative Decree 231/01; thanks to the identified protocols, it is able to prevent the commission of the offences defined in the aforementioned decree. 

In view of the above, and in accordance with the provisions of Legislative Decree 231/01, Neogy has set up its own Supervisory Body with the task of monitoring the functioning, effectiveness and compliance with the Model by all recipients. 
Neogy has also adopted its own Code of Ethics, the purpose of which is to identify and disseminate the ethical principles and behavioural criteria to be observed by shareholders, directors, employees and all those who work to achieve the company's objectives, and to commit them to implementing the principles contained therein within the scope of their functions and responsibilities. To find out more, please see the documents attached below: 

•    Neogy Code of Ethics
•    Neogy 231 Organisation and Control Model 

Reports to the Supervisory Body can also be provided using the appropriate email address:

odv231@neogy.it  

The body will consider, at its discretion, whether to accept anonymous reports.

Anti-corruption measures

We develop initiatives aimed at preventing the commission of crimes of fraud against the State and the public administration, crimes of undue inducement to give or promise benefits, crimes of extortion and corruption against public administrations and private entities.

Whistleblowing reporting

Pursuant to Legislative Decree No. 24 of 10 March 2023 transposing Directive (EU) 2019/2023, NEOGY SRL has set up dedicated internal communication channels to ensure the receipt, analysis and processing of reports of violations of national and EU regulatory provisions of which they has become aware in the context of their work-related activities.

Reports of a personal nature (complaints, claims or requests linked to an interest of a personal nature of the person making the report that relate exclusively to his or her individual employment relationships) are excluded.

Employees, members of corporate bodies or third parties (e.g. consultants, freelancers, trainees, etc.), may send a report, even in confidential or anonymous form, with an absolute guarantee of confidentiality and privacy to the chosen internal channel, including

• the e-Whistle reporting platform (https://neogyewhistle.azurewebsites.net)
• via a voice-messaging telephone line (0471 98 60 34) through which an appointment with the Supervisory Body may also be requested.

For the handling of the report, it is absolutely essential to provide a mobile phone number to which a message will be sent confirming that the report has been taken into account and an access code to the specific software to follow the progress of the case.

The reports will be handled by the Supervisory Body in compliance with the obligations set out in Legislative Decree No. 24 of 10 March 2023 and in accordance with the provisions of the Privacy Law (Reg. 679/2016).

If certain conditions, expressly provided for by Legislative Decree No. 2 of 10 March 2023 are met, the reporting person may make an external report to ANAC (National Anti-Corruption Authority) in the same manner and with the same guarantees as for internal reporting: https://www.anticorruzione.it/-/whistleblowing