since 2017

Adoption 231/01 MODEL


since 2018




Rating Legality


The Graded Governance system guarantees an effective and reliable control system and efficient, healthy and correct management in compliance with the principles of the Code of Ethics and the Social Accountability 8000 (SA8000) certification, thanks to the implementation and application of the organizational Model ex D. Lgs. N. 231/01, of the GDPR model (General EU Data Protection Regulation 2016/769) and of the integrated internal control system consisting of the set of tools, organizational structures, rules and corporate rules.

The management of the Company is the responsibility of the Board of Directors which adopts the strategic and organizational decisions necessary for the implementation of the corporate purpose, in compliance with the principles of transparency and fairness on which the Company’s work is inspired and which, in accordance with the provisions by the Civil Code, has delegated part of its management skills to the CEO.


Graded recognizes the importance of ethical and social responsibilities in carrying out its activities, as an essential element for consolidating the relationship of trust with the various stakeholders (partners, customers, employees, suppliers, commercial partners and other legitimate stakeholders in the areas in which the Company is present with its activities).

The objective of the code of ethics is to guide the company’s operations towards compliance with the law, in a business conduct framework governed by the principles of fair competition, honesty, integrity, fairness and good faith in the socio-economic contexts in which the Company is called. to use.

This objective requires the adoption of an ethical-corporate reference model structured on a set of values, behavioral methods and responsibilities that the Company recognizes, accepts, shares and makes its own in the relationships established internally and externally , communicating its contents to its stakeholders, in order to ensure the highest level of knowledge.


  • The corporate bodies and control bodies (shareholders, administrative body, delegated bodies, board of statutory auditors);
  • the Company’s personnel (managers, employees, workers, external collaborators) classified in staff regardless of the type of contractual relationship in place;
  • the Consultants and Suppliers of goods or services (including professional), and anyone who delivers services in the name and / or on behalf of the Company, including partner companies or subcontractors;
  • the Customer (whether private or public administration), the limits of applicability of this Code to their conduct;
  • any other private or public entity, also of an institutional nature, with which the Company establishes in any capacity, directly or indirectly, permanently or temporarily, in Italy or outside, operational relations.

The recipients of the rules of the Code are required to observe the provisions contained therein and to adapt their behavior and actions to the principles expressed. Each of them is required to know and comply with the provisions of this Code.


  • Ethics in business management
  • Work ethics and employee protection and enhancement
  • Commitment to sustainable development and social responsibility
  • Ethics in relationship management (PA and customers)
  • Ethics in economic/financial reporting


Graded has adopted the organization and management model envisaged by Legislative Decree 8th June 2001, n. 231, which introduced introduced the administrative liability of the Entities/Companies for certain administrative crimes and offenses committed in their interest or to their advantage by subjects who hold a top position in the structure of the Entity, Company or by subjects subject to the supervision of the latter, even if not in the organization chart, providing for the exclusion (or limitation) of the administrative liability of the Company if the Company itself demonstrates that it has adopted and effectively implemented “Organization, management and control models” suitable for preventing crimes.

The Organization and Management Model, originally adopted in 2016, has been updated, strengthened and integrated over time in relation to legislative and regulatory changes (e.g. expansion of the category of crimes).
The Organizational Model pursuant to Legislative Decree 231/01 updated by GRADED is an expression of the corporate policy oriented towards the prevention of corporate criminal risk which involves, substantially, the entire audience of recipients (top and subordinate subjects). On a formal level, it is based on a series of documents which are to be considered as a single manual made up of several sections.

The manual consists of a “general” part, a “special” part and two accessory sections: the disciplinary system and the catalogue of 231 offenses. This division responds to the need for a more efficient future update, given that the various documents are which can be updated separately, each with a code and an edition date that will allow to keep track of it and safeguard the confidentiality of certain sections (e.g. the types of activities sensitive to the risk of crime which will be detailed in the Special Part of the Model). To further oversee the corporate organization aimed at preventing crimes,there is the corporate Code of Ethics which expresses the ethical and ethical principles that the Company recognizes as its patrimony of values and on which it calls for compliance by all those who work for the achievement of social objectives.

The Organizational Model pursuant to Legislative Decree no. 231/01 adopted to ensure healthy and correct management also includes the ” WhistleBlowing ” procedure.

Article 6, paragraph 1, lett. b) of Legislative Decree 231/2001 requires, as a condition for seeing the exemption of administrative liability recognized, that a body of the Company, endowed with “autonomous powers of initiative and control”, be entrusted with the task of supervising the operation and compliance with the provisions of the Model, as well as supervising its updating.

Graded has appointed a collegial Supervisory Body (SB) consisting of three external members, guaranteeing all the prerogatives of autonomy, professionalism and independence explained above, which remains in office for three years from the date of appointment, unless otherwise determined by the administrative body.

The Supervisory Body must be informed of events that could generate Graded’s liability pursuant to Legislative Decree 231/2001 by means of special reports from employees, corporate bodies, suppliers, consultants and individuals in general with whom the Company has relationships.

Communications to the SB can also be made the e-mail address


The General Part of the Model represents and describes the control environment examined in the risk assessment, defined on the basis of the following parameters:

a) regulatory references;

b) corporate governance system;

c) internal company organization;

d) objectives of Model 231 and criteria followed for its preparation;

e) harmonization of Model 231 with the Code of Ethics;

f) establishment of the Supervisory Body, description of its constituent features and related tasks;

g) the intra-company communication system of the Model and staff training criteria on the behavioral protocols it prescribes.

The Disciplinary System set up to specifically oversee the provisions of the Model also forms an integral part of the General Part.


The Special Part of the Model – formalized in a separate document from the General Part – details the organizational measures adopted for risk management in the individual areas subject to detection during the risk assessment phase, highlighting in particular:

  • abstractly perpetrable offenses;
  • the types of activities sensitive to the risk of crime;
  • the corporate functions that operate in the context of sensitive activities;
  • the relevant control principles within the individual risk areas;
  • the principles of conduct to be respected in order to reduce and, where possible eliminate, the risk of committing crimes;
  • the information flows to the Supervisory Body.


Modello di organizzazione e gestione 231 – Parte Generale – aggiornato a dic. 2020

Modello di organizzazione e gestione 231 – Parte Speciale – aggiornato a dic. 2020

Modello di organizzazione e gestione 231 – Parte Speciale Art.30TUS – aggiornato a dic. 2020

Codice Etico

Sistema disciplinare


Modello di organizzazione e gestione 231 – Parte Generale – aggiornato a dic. 2020

Modello di organizzazione e gestione 231 – Parte Speciale – aggiornato a dic. 2020

Modello di organizzazione e gestione 231 – Parte Speciale Art.30TUS – aggiornato a dic. 2020

Codice Etico

Sistema disciplinare