Corporate Governance

MOG 231 ORGANISATION MANAGEMENT AND CONTROL MODEL

The Organisation, Management and Control Model (MOG) adopted by the Board of Directors of Milan Bergamo Airport, effective from July 2003 pursuant to Legislative Decree 231/01 on the subject of administrative responsibility of bodies is an integral part of the internal control system within the framework of corporate governance.
Its primary purpose is to prevent the commission of unlawful acts by its directors, employees and consultants in various ways through the prevention protocols designed to limit the potential risk of occurrence of crimes specified in catalogue 231.
The Model consists of a General Part, which can be downloaded from the link below, which sets out the principles, the composition, the architecture and the scope of the Model and a Special Part where for each single offence committed the relative prevention protocols are identified aimed at minimising the risk of occurrence of the crime itself.
The Model is governed by the Supervisory Board, a body with autonomous powers of initiative and control, which has the task of supervising the operation of the Model, ensuring its effectiveness and suitability and taking care of its regular updating. The Supervisory Board of Sacbo consists of 3 members of which 2 are external and one internal held by the Head of Corporate Internal Auditing.
All recipients of the Model are required to report any violations to the Supervisory Board by e-mail organismodivigilanza@sacbo.it


GROUP CODE OF ETHICS

SACBO SpA pursues the primary objective of acquiring at every level and in all circumstances an image and a corporate reputation aimed at the scrupulous compliance with behavioural principles such as credibility, loyalty, honesty in relationships and, not least, morality.
Our company operates in compliance with these principles, which became over time its "genetic" heritage: they must be constantly reflected in the actions of all employees. The observance of these principles combined with compliance with the rules of ordinary diligence and the regulatory framework in place will ensure that SACBO SpA preserves the solid reputation gained in the airport business.
Therefore it is essential that everyone operates, within the assigned corporate function, with maximum transparency, especially focusing on the improvement of everyday relations in respect of colleagues, suppliers, customers and users.
With this in mind the Board of Directors reviewed the "Code of Ethics", which contains a series of behavioural rules to be observed and to be enforced in order to maintain strong ethical principles in the company, and is one of the essential components of the Organisation and Management Model adopted by SACBO pursuant to Legislative Decree 231/2001.

The Chairman of SACBO


ANTI-CORRUPTION POLICY

In carrying out its business, the Corporate Group SACBO (hereinafter “Group”) is inspired by principles of ethics and integrity, by performing its business activities on a best efforts basis, with utmost honesty, collaboration, loyalty and professional accuracy; in compliance with laws, guidelines and anti-corruption standards, and in line with the strategic significance of the business sector and the legal and social environment in which the Group operates. To pursue these objectives the Group has voluntarily adopted a "Special Anti-corruption Section" within the Organization Management and Control Model pursuant to Legislative Decree 231/01 (MOG 231) to prevent “active corruption” (in the interests of the Group) and "passive corruption” (in disadvantage of the Group). The model is completed by a "Whistleblowing Procedure", which regulates the reporting of illicit conducts or infringements of the MOG 231.


WHISTLEBLOWING

The Corporate Group S.A.C.B.O. considers the whistleblowing reporting tool an effective instrument to counteract the corruptive phenomenon and it gives the possibility to report unlawful conduct or violations of the Organization, Management and Control Model pursuant to Legislative Decree 231/2001. These reports can be submitted to the "Whistleblowing Committee" through two channels: an IT platform, reachable by the link https://milanbergamoairport.segnalazioni.net/ or sending a paper report to the post office box no. 2 at the post office located in Orio al Serio.

It remains established that S.A.C.B.O. has decided not to take into account anonymous reporting.