Governance

CODE OF ETHICS AND MODEL 231

In order to strengthen and improve its corporate control and governance system, Garofalo Health Care S.p.A. adopted a Group Code of Ethics and its own organization and management model in compliance with the provisions of Legislative Decree 231/2001 ("Model 231") and an Anti-Corruption Policy approved by the BoD on 26 January 2023.

 

CODE OF ETHICS


The Code of Ethics of the Garofalo Health Care Group was approved by resolution by the Board of Directors on 8 August 2018 and updated on 14 November 2024. It was drawn up to clearly define the ethical values that form the basis of the Group’s corporate culture, as well as to define the rules of conduct by which staff carry out their professional duties, and the rules of conduct for dealing with shareholders, customers, suppliers, colleagues, public administration officials, and with all the other GHC stakeholders.

The Group's Mission was taken into account when drawing up the Code of Ethics. GHC’s Mission aims at developing the Group’s capacity to bring together health facilities of excellence, thereby strengthening GHC’s potential and leveraging its resources to enable it to become the first healthcare group of reference at national level. GHC’s mission also aims at creating a high-quality model through its "patient-centered" approach, which takes into account the preferences, needs and values of individual patients when making clinical decisions. In this way, the patient is firmly placed at the centre of the system.

The Group’s guiding principle: "Health is a person’s most valuable asset", was inspired by Prof. Raffaele Garofalo. All of the Group’s stakeholders abide by this principle and affirm the importance of health as a primary asset, as no human being can do without it, and as such, it must be safeguarded by guaranteeing professionalism and excellence.

Garofalo Health Care S.p.A., in the course of its management and coordination activities, undertakes to distribute the Code of Ethics to all of its member companies, in order to ensure that they formally adopt it as a management tool and as an essential element for the Group’s strategy and company organization.

Administrators, Statutory Auditors, Managers, Employees, and all healthcare, technical, nursing and auxiliary staff, as well as auditors, consultants and main suppliers, are required to take note of the Code and to adhere to the rules and provisions contained therein.

Garofalo Health Care Code of Ethics is available here.

 

231 Model - General Section 

231 Model, approved by the Board of Directors of GHC S.p.A. on 8 August 2018 and subsequently updated with a resolution of the Board of Directors of 30 July 2020 and finally with a resolution of the Board of Directors of 14 November 2023, responds to specific provisions contained in Legislative Decree 231/2001, aimed at preventing the commission of particular types of crimes (for facts which, apparently committed for the benefit of the company, may entail administrative liability for crime based on the provisions of the decree itself).

The Board of Directors of GHC S.p.A. has also established a Supervisory Body, equipped with autonomous powers of initiative and control, necessary to ensure effective and efficient supervision of the functioning and observance of Model 231 in accordance with the provisions of Article 6 of Legislative Decree 231 /2001.

In particular, the Supervisory Body is entrusted with the following tasks and powers to carry out and exercise its functions:

  • verify the adequacy of Model 231 ia with respect to the prevention of the commission of the cases referred to in Legislative Decree 231/2001 and with reference to the ability to highlight the occurrence of any illicit conduct;
  • verify the efficiency and effectiveness of Model 231 also in terms of correspondence between the operational methods adopted in practice and the procedures formally envisaged by the Model itself;
  • verify that the efficiency and effectiveness requirements of Model 231 are maintained over time;
  • ensure and promote the constant updating of Model 231, formulating, where necessary, proposals for any updates and adjustments to the management body;
  • promote the periodic updating of the identification, mapping and classification system of Sensitive Activities;
  • maintain a constant connection with the auditing firm, safeguarding its necessary independence, and with the other consultants and collaborators involved in the effective implementation of Model 231;
  • detect any behavioral deviations that may emerge from the analysis of information flows and from the reports to which the managers of the various functions are required;
  • promptly report to the management body, for appropriate measures, any confirmed violations of Model 231 which may give rise to liability for the Company;
  • manage relationships and ensure the relevant information flows towards the board of directors, as well as towards the supervisory body;
  • promote and supervise initiatives for the dissemination of knowledge and understanding of Model 231, as well as for staff training and raising awareness of the observance of the principles contained in Model 231;
  • promote and supervise communication and training interventions on the contents of Legislative Decree 231/2001, on the impacts of the legislation on the company's activity and on behavioral norms;
  • provide clarifications regarding the meaning and application of the provisions contained in Model 231; 
  • prepare an effective internal communication system to allow the transmission of relevant news for the purposes of Legislative Decree 231/2001, guaranteeing the protection and confidentiality of the reporting party;freely access any management and unit of the Company - without the need for any prior consent - to request and acquire information, documentation and data, deemed necessary for carrying out the tasks envisaged by Legislative Decree 231/2001, from all employees and manager; request relevant information from Consultants and Partners;

  • promote the activation of any disciplinary proceedings referred to in chapter 6 of Model 231.

    Any violation or suspected violation of Model 231 can be reported to the Supervisory Body.

Reports can be sent in the following way:

                                                             e-mail: odv231@garofalohealthcare.com;  
                                                  address: Supervisory Body of Garofalo Health Care S.p.A.        
                                                              Piazzale delle Belle Arti, 6 - 00196 Rome

In order to guarantee the availability, for potential whistleblowers, of an additional channel that complies with the requirements of the legislation on whistleblowing, reports can also be sent via email to the following personal email address (not relating to the domain of the Company) to which only members of the Supervisory Body have access:

                                                                           email: odvghc@gmail.com

 

231 Model - General Section is available here.

ANTI-CORRUPTION POLICY

The GHC Group, operating in the healthcare sector, has among its primary values ​​that of corporate ethics, through which it transmits a message of loyalty, correctness and respect which applies to the entire Group and which represents a point of reference in social reality in which it operates.          
The prevention of corrupt practices represents for the Group, as well as a legal obligation, one of the principles on which the Group's actions are based.     
For this reason, the Group has adopted the following Anti-Corruption Policy approved by the Board of Directors on 26 January 2023.

Anti-corruption Policy is available here.