Ceccarelli Group (Ceccarelli Group S.r.l., Ceccarelli S.r.l., Cursor S.r.l., Euro's S.r.l. LME S.r.l., Loglab S.r.l., Transfriuli S.r.l.),a historical entity active in the logistics, transport and integrated warehouse services sectors, has adopted an Organisation and Management Model as provided for by Legislative Decree No. 231 of 8 June 2001 and subsequent amendments. The Model, approved by the Boards of Directors in December 2024, represents a fundamental tool for the prevention and proper governance of business activities (the so-called “Model 231”).

Purpose of Legislative Decree 231/2001

Legislative Decree 231/2001 introduced into the Italian legal system the principle of administrative liability of the entity, providing that the company may be held directly liable for crimes committed, in its interest or advantage, by individuals holding functions of representation, administration, direction or control, as well as by employees and collaborators. The consequences of such liability can be very serious and include monetary penalties, prohibitory measures or the suspension of activities.

However, the entity can be exempt from liability if it demonstrates that it has adopted and effectively implemented, prior to the commission of the offence, an organisational, management and control model suitable for preventing risks and if it has established a Supervisory Body with duties to oversee the functioning and compliance with the Model.

Structure of the Model

The 231 Model of Ceccarelli Group companies consists of an organic system of principles, rules of conduct, protocols and procedures that regulate the performance of activities most sensitive to 231 risks.

In particular, the Model is structured as follows:

• General Part, which illustrates the purposes and functioning of the Model and defines the tasks of the Supervisory Body;
• Ethical Code, which specifies the corporate values (integrity, transparency, reliability and customer centrality) and the principles of conduct that administrators, managers, employees, collaborators, suppliers, partners and all parties interacting with the Group must adhere to;
• Sanctioning System, which provides differentiated measures based on the type of subjects and defines the consequences of violations of the Model's provisions.
  

Supervisory Body

Ceccarelli Group has appointed a Supervisory Body, tasked with carrying out control activities on the functioning and compliance with the Model, in accordance with Legislative Decree 231/2001.