Code of Ethics and Model 231
Sourcesense inspires its actions on the values of fairness, integrity, transparency, reliability, sustainability and responsibility, translating the appreciation of these principles that characterize the company's way of operating into competitive advantage.
REGULATORY FRAMEWORK
Legislative Decree No. 231 of June 8, 2001 introduced into the Italian legal system a system of administrative liability of Entities - including companies - for certain crimes committed by directors, managers or employees in the interest or for the benefit of the Entity itself.
ADOPTION OF THE ORGANIZATIONAL MODEL
In 2024, Sourcesense adopted its own Organizational Model for the first time with the purpose of building a structured and organic system of guiding principles, operational procedures and other specific safeguards, inspired by sound business management criteria and aimed, in line with the corporate purpose and that of the Parent Company Poste Italiane S.p.A., at preventing the commission of crimes provided for by the Decree, as well as protecting the interests of stakeholders relevant to the company itself.
The Model consists of a General Part and Special Parts, each of which relates to a class of crime relevant to the Company. The General Part describes, adapting them to the specific business reality of Sourcesense, the contents explicitly required by Legislative Decree 231/2001 (e.g. the regulation, the Company's governance, the Supervisory Body, training/information activities, the sanctioning system, etc.) as well as the company's integrated internal control and risk management system (e.g. integrated risk management process, Corporate Regulatory System, Code of Ethics and Group Policies, Corporate Governance System); the individual Special Parts outline, according to a process-based logic, the different types of predicate offenses concretely and potentially relevant in the company, as well as the corporate processes, sensitive activities, behavioral rules and specific control principles analyzed for each class of crime.
Sustainability themes also assume significant importance in Sourcesense's Model 231, in line with the current strategic direction of the Parent Company and in consideration of the correlations and synergies present between these themes and Decree 231. Model 231 constitutes an instrument that, through the identification of specific control safeguards that allow preventing the commission of crimes attributable to Decree 231, also contributes to supporting the Company in achieving the objectives included in the 8 Pillars of the ESG Strategic Plan, as well as in the implementation of the themes related to the ESRS standards relevant to the Poste Italiane Group.
THE SUPERVISORY BODY
Sourcesense has entrusted a Supervisory Body (composed of two members external to the Company – Cesare Placanica, with functions of President, and Gianluigi Fiorendi) and one member internal to the Poste Italiane Group identified in the figure of Flavia Speranza), with the task of supervising compliance with the prescriptions of the Organizational Model, verifying their actual effectiveness and evaluating the need for any updates. The term of office of the Supervisory Body is three years, until the approval of the financial statements as of December 31, 2026.