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Corporate governance

Corporate Governance

 

Legislative Decree 231/2001

Base Digitale Platform has consistently combined its expertise in technical and technological innovation with a Corporate Governance framework based on a rigorous organisational and management model. In accordance with the provisions of Legislative Decree No. 231/2001, as subsequently amended, the Company has adopted tools designed to place corporate administrative liability at the centre of its governance system and to ensure that such liability remains distinct from that of the natural persons acting in the name and on behalf of the Company.

Organisation, Management and Control Model

The approval by the Board of Directors of a system such as the Organisation, Management and Control Model (MOGC), as provided for by law, ensures an approach aimed at promoting a culture of legality and responsibility among directors, managers, employees and collaborators. This means that each business process is brought within the framework of appropriate conduct, the correctness and validity of which can always be verified both ex ante and ex post. The quality of this approach is further ensured by the integration of the organisational and management model with compliance certifications under the voluntary standards ISO 9001 and ISO 27001.

GDPR: Responsibility and Accountability

The implementation of the measures set out under Legislative Decree No. 231/2001 anticipated the key concept of accountability introduced on 25 May 2018 by the new European Regulation on the protection of personal data. In fact, the GDPR (General Data Protection Regulation) combines, through the concept of accountability, the meaning of “responsibility” with that of “demonstrating” and “providing evidence of” the measures adopted for this purpose. This is something that Base Digitale Platform had already implemented for some time, not only in the area of privacy, but also with regard to health and safety in the workplace, environmental offences, corruption-related offences, and all other offences covered by the Decree.

Whistleblowing

Alongside our core values and the general principles of compliance with the law, honesty, transparency, fairness and good faith, we place particular emphasis, among our sustainable development objectives, on the well-being of the people who work with us and on our responsibility towards the local community.

We have adopted a process for the receipt, assessment and handling of reports, including anonymous reports, concerning our organisation, submitted by third parties and by our employees and/or collaborators.

This process complies with the regulatory provisions introduced by Legislative Decree No. 24 of 10 March 2023, implementing Directive (EU) 2019/1937 of the European Parliament and of the Council of 23 October 2019, concerning the protection of persons who report breaches of Union law, and setting out provisions regarding the protection of persons who report breaches of national law (the so-called “Whistleblowing Decree”). The whistleblowing management process forms an integral part of the Organisation, Management and Control Model pursuant to Legislative Decree No. 231/2001.

Below are the main internal reporting channels made available for reporting information relating to company personnel and/or third parties concerning breaches of laws and regulations, the Code of Ethics, the Organisation Model 231, as well as the system of rules and procedures in force within Base Digitale Platform S.p.A.

  • By ordinary mail, addressed to the Head of the Whistleblowing System, Via V Maggio 81, 16147 Genoa (GE), Italy
  • Verbally, by means of a statement made by the reporting person during a dedicated meeting arranged for this purpose
  • Through the website: https://whistleblowing.sesa.it

 

These channels are not available for commercial complaints or for disputes and requests relating to personal interests.

Absolute confidentiality is guaranteed to the reporting person, the facilitator and the persons involved in the report. In the case of anonymous reports, the identity of the reporting person cannot be traced. In any event, no form of personal or professional retaliation as a result of a report is permitted or tolerated.

If you believe you have suffered retaliation as a consequence of a report, you may notify the Italian National Anti-Corruption Authority (ANAC). For further information, please consult: https://www.anticorruzione.it/-/whistleblowing