Organizational model

Aeroporti di Roma (“ADR”), always committed to combining economic growth optimisation with fundamental business ethics, in addition to having implemented the Atlantia Group Code of Ethics and Anticorruption Policy to discipline proper execution of its operations, has also adopted an Organisational, Management and Control Model (Model), compliant with Legislative Decree 231/2001. Such a Model has defined a structured system of rules and controls that all of its recipients are called on to comply with, in order to pursue the social purpose in full compliance with prevailing legal provisions.

Legislative Decree 231/2001 introduced into Italian law an administrative liability regime applying to entities (meaning companies, associations,…) for a series of specified offences committed in the interest or to the advantage of the Entity by directors, executives or employees in the interests or for the benefit of the Entity…

The adoption of the Model represents an important step towards the achievement of the goals commonly considered as good company practices, as it provides shareholders, financial community and stakeholders a guarantee that the laws and regulations relevant for business activities are being properly applied.

The Model has been adopted in 2007 and constantly updated in light of the regulatory development and corporate organizational changes. It was reviewed most recently: i) in 2018 with regard to the evolution of best practices and of the legislation concerning the responsibility of the entities, ii) in 2019 with regard to trading in influence crime, iii) in 2020 (tax crimes and adoption of EU directive UE 2017/1371 know ad “PIF Directive”). The latest Model updates were approved in October 2021.
The Model describes the inspiring principles and the operational methods followed to draft and update it, disciplines requirements, functions and powers of the Supervisory Body, as well as the characteristics of the reporting system and information flows, the disciplinary system and the method of distribution of the Model itself within ADR and to third parties.
The document contains a description of the set of control and behaviour principles deemed suitable for disciplining the processes for which there is a potential risk of committing offences relevant for the Legislative Decree 231/2001.

The Model applies to all ADR employees and it is brought to the attention of all third parties who have business relationships with ADR.

Supervisory Body

task of supervising the functioning and the observance of the Model and its update, pursuant to Art. 6 of Legislative Decree 231/2001.
The relevant circumstances for compliance with and functioning of the Model itself must be reported to the Supervisory Body, as well as any unlawful conduct or violations of the Model, guaranteeing that the reports are detailed and founded on precise and consistent factual elements.

Every report received is managed by the Supervisory Body, in compliance with the provisions of Art. 6 of Legislative Decree 231/2001. In particular, ADR guarantees the confidentiality of the identity of the reporting person and his/her protection against any form of reprisal, discrimination or prejudice, directly or indirectly connected to the report.

The company makes alternative channels available (electronic mailbox and postal address) for transmission of the reports.
Specifically, reports can be sent:
• online using the digital platform “Whistleblowing” accessible from the home page of the website link and via the specific link from the Intranet
• via e-mail, to the following electronic mail address:
• via post to the attention of: Organismo di Vigilanza Aeroporti di Roma - Via Pier Paolo Racchetti 1, 00054 Fiumicino - Roma