Organizational Model and Code of Ethics

Organizational Model and Code of Ethics – Legislative Decree 231/01

Rainbow has grounded its business and performs its every days activities in respect of core values of efficiency, correctness and loyalty.
For this purpose Rainbow has adopted the Organizational Model (“Model”) pursuant to the Italian D. lgs. n. 231/2001, that has introduced the administrative and criminal responsibility of entities for some criminal offences therein foreseen, updating and implementing its organization in compliance with such regulation.
The adopted Model consists of several elements such as: analysis of activities bearing potential risks, principles, rules and regulation of conduct, instruments of controls, procedures and protocols of controls, activities of training and information, disciplinary code, Supervisory Board (“Organismo di vigilanza”) and information flows. The Model mainly aim to prevent from any occurrence of the criminal offences indicated by the D. lgs. n. 231/2001.
The Organizational Model ex D. lgs. n. 231/2001 has been adopted by Rainbow with BoD resolution on March, 31st 2011.
Principles, dispositions and prescriptions of such a Model are binding for directors, employees and all persons operating for whatsoever reason on behalf and in the interest of Rainbow.
Rainbow has also adopted the Code of Ethics defining all values that have been duly recognized, accepted and shared at all levels during the performance of any company’s activities. Principles and rules included in the Code of Ethics are specifications of general duties of diligence, correctness and loyalty that connotes any execution of working activities, any behavior within the work environment and any activity of the company itself.
The Code of Ethics has been also adopted by Rainbow with BoD resolution on March, 31st 2011.
Additionally, pursuant to art. 6 par.1, b) of D. lgs. n. 231/2001 with same BoD resolution on March, 31st 2011 Rainbow has appointed a dedicated Supervisory Board disposing of powers of decision and control having the task of supervising functioning and respect of the Model, as well as its update on regular basis.

Download Legislative Decree 231/01 Model

Download Code of Ethics

Whistleblowing Procedure

As part of its business purposes, Rainbow Group is committed to contrasting unlawful conduct both through the promotion and circulation of ethical values and principles and through the effective implementation of rules of conduct and control processes, in line with the requirements set by applicable regulations and international best practices.

In compliance with the legislative provisions on whistleblowing, Rainbow Group has established a secure channel, activated by the websites traceable to it, through which it is possible to report violations, including reasonable suspicions, of national and European Union regulations affecting the Company.

To this end, the Internal Reporting Channel has been identified in the Whistleblowing Platform and the Reporting Manager has been identified in Rainbow S.p.A.’s Board of Vigilance.

Rainbow therefore encourages anyone becoming aware of violations (conduct, acts, or omissions) of the law or internal company protocols that are, even potentially, detrimental to the public interest or the integrity of the Group, to make a report through the Whistleblowing Platform.
The Whistleblowing Platform is an IT tool designed, also via an encryption system, to guarantee that the identity of the whistleblower, the person involved and the person in any case mentioned in the report, as well as the content of the report and the related documentation, are kept confidential, enabling the competent office to communicate with the whistleblower by providing him or her with an acknowledgement of receipt of the report and feedback on the action taken or intended to be taken on it. Reports can be made through the Whistleblowing Platform either in written or oral form. For the latter, the reporting person may alternatively attach an audio file or request a direct meeting scheduled with the relevant office.

To make a report, please access the Whistleblowing page where further and more in-depth information is available on how to make a report and its handling.
The policy on the processing of personal data handled as part of whistleblowing is available on the Privacy Policy page.

Download Whistleblowing Procedure