Code of Conduct

At Gemmo, we have always recognised the utmost importance of the values of integrity, fairness and transparency, and with this in mind we were among the very first companies to make our activities and processes compliant with the requirements Italian Legislative Degree 231/2001.

Reference legislation

The administrative liability of Entities was introduced into the national legal system by Legislative Decree No. 231 of 8 June 2001, which provides for its applicability to certain legal entities, including corporations, for certain offences committed by directors, managers or employees in the interest or to the advantage of the Entity.

The Organisational Model at Gemmo

Since 2004, the Gemmo has implemented a specific Organisation, Management and Control Model (Organisational Model) in line with the provisions of Legislative Decree 231 of 2001 on the administrative liability of legal persons.

The Organisational Model and the Code of Conduct, which sets out the values, principles of behaviour, commitments and responsibilities that Gemmo assumes both internally and externally, are an integral part of the Company’s Internal Control System.

The Organisational Model consists of a General Section, which contains the principles of prevention and corporate governance, regulates the functioning of the SB and sets out the prevention protocols. It also contains as Special Sections that describe, the various types of predicate offences relevant to Gemmo, following a logic of prevention and process risk management, and indicates the relevant containment and control measures.

Gemmo’s Board of Directors approved Edition No. 9 of the Organisation, Management and Control Model in February 2022, updating it to the latest predicate offences introduced by legislation.

Code of Conduct

The Supervisory Board

Gemmo has entrusted a Supervisory Board with the task of supervising the operation, compliance with and application of the Organisational Model.

The Supervisory Board of Gemmo S.p.A. is composed as follows:

  • Elisa Nascimben – Lawyer (President)
  • Andrea Valmarana
  • Enrico Maria Giarda – Lawyer


In order to ensure the application of Law No. 179 of 30 November 2017, the 231 Organisational Model provides for a reporting procedure with enhanced protection (whistleblowing), which guarantees confidentiality and the protection of the reporting party, intended directly and exclusively for the Supervisory Board.

According to the whistleblowing procedure, managers, employees, collaborators and consultants of Gemmo S.p.A. who become aware of information regarding conduct that does not comply with the principles and rules of conduct set out in Italian Legislative Decree 231/2001 or the Code of Conduct, may report the matter to the Supervisory Board using the dedicated e-mail address: