Model 231

ACI Infomobility S.p.A. – Management and Control Organisation Model
(pursuant to Legislative Decree No. 231 of 8 June 2001 and subsequent additions and amendments)


For the first time, Legislative Decree No. 231 of 2001 introduced the criminal liability of entities in our legal system, in addition to that of the natural person who materially committed the offence.

The regulatory innovation is of great importance, as it establishes that the company is liable for offences committed by its top management or even by simple employees, provided that they have acted in the interest or to the advantage of the company itself.

ACI Infomobility, in compliance with Legislative Decree No. 231/2001 and in consideration of Confindustria’s guidelines, decided to adopt an adequate organisation, management and control model (Model 231) which was approved by the Board of Directors on 20.03.2014.

The adoption of an organisation, management and control model is optional for the Company and not an obligation. ACI Infomobility has decided to adopt its own Model 231 also as it believes that by doing so it strengthens the image of correctness and transparency that the company’s activities have always been geared towards, in line with the commitments declared and undertaken with the Code of Ethics towards stakeholders.

The Board of Directors has appointed the Supervisory Body, which has the role of monitoring the adequacy and application of the model itself, acting as Guarantor of the Code of Ethics and the body to which any breach or suspected breach of Model 231 may be reported. The address of the Body is:


Supervisory Body of ACI Infomobility S.p.A.

Via Stanislao Cannizzaro 83/A – 00156 Rome

e-mail: ​

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