Internal Control System

We adopt specific procedures for the management of risk factors that may affect the economic, equity related and financial situation of our Group

These procedures are the result of a management based on the values of the Code of Ethics (integrity, fairness and transparency, professionalism, sustainability and business continuity, attention to people and stakeholders) that pursues sustainable growth objectives for stakeholders.

We pay particular attention to the issue of compliance and anti-corruption, developing numerous activities to verify compliance with the regulatory environment, external and internal, aimed at preventing the risks of non-compliance, the non-observance of which could lead to sanctions, economic losses, harmful administrative measures, and reputational consequences.

Model 231

The Organisational and Management Model pursuant to Legislative Decree 231/2001 regulates the administrative liability of collective entities, that is, the principle according to which companies may be held liable, and consequently financially sanctioned, for certain offences committed or attempted, in their interest or to their advantage, by their directors or employees. Sesa’s Model 231 fits into the broader context of the company’s internal control system, constituting one of its characteristic components. The adoption of the Model, in addition to representing a deterrent to the realisation of any unlawful activities, intends to support a culture oriented towards correctness and transparency of behaviour in the conduct of business. The Model represents the connecting tool between the various areas of the Internal Control and Risk Management System (SCIGR) adopted by the main Group companies. The SCIGR is defined as the set of rules, procedures and organisational mechanisms put in place by top management to identify, measure, manage and monitor the main corporate risks.

Supervisory body

In implementation of the provisions of Legislative Decree 231/2001 and in accordance with the provisions of the Articles of Association, the Board of Directors appointed a Supervisory Body (“OdV”), which is entrusted with the task of overseeing the operation of and compliance with Model 231 and ensuring that it is updated.

The Supervisory Body oversees the operation of and compliance with Model 231 and monitors and evaluates the status of implementation of the prevention measures, reporting periodically to the Board of Directors and the Management Control Committee.

For any reports to the Supervisory Body please write to [email protected].

0 cases reported

as at 30 April 2023 of corruption, unfair competition, monopolistic practices or antitrust involvement


To ensure that management is consistent with the values of the Group’s Code of Ethics, any irregularities or any violation of applicable regulations or procedures may be reported through the internal whistleblowing system.

Our Model 231 therefore provides for a channel for reporting violations, including anonymously, with safeguards for the authors of reports and total confidentiality of their identity.

0 reports

as at 30 April 2023

Code of Conduct

The Group has adopted its own Code of Conduct containing guidelines concerning legal and professional obligations, customer and other business relations, organisational and administrative provisions as well as personal conduct. It is based on values and principles of professional and personal conduct generally required by our organisation. 

The Code of Conduct adopted by the Group defines, together with and in support of the Code of Ethics, the fundamental principles underpinning the Group’s reputation and the values that inspire its day-to-day operations, also describing the standard of conduct required of all Sesa employees and collaborators.

0 sanctions

as at 30 April 2023 for non-compliance with social and economic laws and regulations

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