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assigned, reasons for ineligibility, dismissal, disqualification
and suspension of members, spending budget). Lastly,
the document deals with how the Model is distributed and
publicised, how its users are trained, and how it is adopted and
continuously updated.
(d) Decision-making and control procedures. For all
significant risks identified, these procedures govern:
- the roles and responsibilities of the persons involved;
- the decision-making/authorisation processes;
- how activities at risk are managed and controlled.
In order to guarantee better oversight of internal control
activities and in compliance with the recommendations of
Borsa Italiana's Code of Self-Regulation, the Board of Directors
has appointed the CEO - Valerio Battista - as the Executive
Director responsible for the risk management and internal
control system and made him responsible, among other duties,
for managing this system and monitoring constantly its overall
adequacy, effectiveness and efficiency. The Board of Directors
has also appointed an Internal Audit Manager and made him
responsible for verifying that the internal control system is
adequate, fully operational and effective at all times.
During 2012, the Internal Audit department worked with the
central HSE function and the local HSE managers to analyse,
with a view to updating, the Organisational Model pursuant to
Decree 231/2001 adopted by all Italian companies in the Group.
This analysis focused on the environmental risks associated
with the new offences added to those identified by Decree
231/01, in order to check on their applicability and how they
might be committed at the Group's Italian factories.
Interviews and selected site visits provided the information
needed to assess the adequacy and efficiency of the activities
at risk, considering the procedures and operational protocols in
place, the proper definition of roles, the existence of a system
of controls and the traceability of information. A number
of operational recommendations were made to improve
the traceability of environmental information. These were
implemented immediately at the locations concerned, and
will be extended to all Italian and Group operational units via
adjustment of their environmental management systems.
On completion of the work, an environment management
protocol was prepared for each company reviewed, defining
the control activities required and the behaviours needed to
address the potential commitment of environmental offences.
