Rules, procedures and operational safeguards to make the company’s 231 compliance system effective
A 231 Organisational Model should not be an abstract document. It must be a practical tool capable of affecting the company’s actual operations. After the risk assessment, the work consists of translating sensitive areas into operating rules, decision-making protocols, internal procedures and clearly defined responsibilities.
Legislative Decree 231/2001 requires the model to include specific protocols designed to plan how the entity’s decisions are formed and implemented, procedures for managing financial resources in a way that prevents offences, reporting obligations and an appropriate disciplinary system.
The Firm assists companies in drafting or reviewing the model, the special sections and the protocols connected to the most relevant business processes, including dealings with Public Authorities, procurement, payments, consultancy agreements, suppliers, workplace safety, environmental matters, corporate governance and authorisation workflows.
Activities covered
Each assignment is tailored to the company’s size, business sector, decision-making processes and areas concretely exposed to the risk of liability under Legislative Decree 231/2001.
Why it matters
Making the Model usable
The model is built around the company’s actual structure, avoiding generic wording or rules that are difficult to apply in practice.
Defining roles and responsibilities
The procedures clarify who makes decisions, who authorises them, who carries them out and who verifies compliance with internal rules.
Ensuring traceability of sensitive processes
The protocols make it possible to document decision-making steps, authorisations and the controls performed.
Strengthening prevention
An organised system of rules, procedures and responsibilities reduces the risk of unlawful conduct and of organisational failings being challenged.
FAQ
What is the difference between a 231 Model and protocols?
Is a standard model sufficient?
No. A standard model may be ineffective if it does not reflect the company’s real structure, decision-making processes, internal delegations and actual risk areas.
What does a 231 Model usually contain?
Must protocols be separate from existing company procedures?
When should the Model be updated?
Is the Code of Ethics enough to avoid liability under Decree 231?
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