Model 231

Lottomatica Group - in order to ensure that all those who operate on its behalf or in its interest always conduct themselves in a manner conforming to principles of honesty and transparency in the course of carrying out company business and activities – has seen fit to proceed to adopt a Model, in line with the requirements of the Decree and with the relevant case law recommendations, as indeed on the basis of the Guidelines issued by Confindustria.

The Model drawn up by the Group is based on a structured and functional system of documents, which include procedures, operational instructions and other documents regulating the Company’s operations (hereinafter abbreviated to “procedures”), as well as control activities that:

• single out areas of possible risk in the company’s business, i.e. activities in whose framework the perpetration of offences is considered theoretically possible;
• define an internal regulatory system, aimed at preventing offences, which includes, inter alia, the Code of Ethics, a system of proxies and powers of attorney, formalised procedures and a penalty system;
• find their prerequisite in an organisational structure consistent with the company's activities, aimed at inspiring and controlling the correctness of conduct, guaranteeing a clear and organic allocation of tasks, applying a fair segregation of duties and ensuring that the desired structures of the organisational structure are actually implemented.

Lottomatica Group has also established, pursuant to Legislative Decree No. 231/2001, the Supervisory Body with full and autonomous powers of initiative, intervention and control over the operation, effectiveness and compliance with the Model, in order to prevent the risk of offences from which the Company's administrative liability may arise.

Lottomatica promotes the knowledge of the Model, the Code of Ethics and the Company's procedures among all employees who are therefore required to know their contents, to comply with them and to contribute to their implementation. The training course includes classroom training seminars as well as the possibility of using "e-learning" modalities.