Corporate Compliance
At Central Cargo, the implementation of corporate compliance highlights the value of responsibility and innovation. The activities carried out by Compliance take the form of a process of constant adaptation, with training and refresher courses for all personnel in the corporate supply chain on the subjects of risk management, safety, and internal controls
in the broader context.
Compliance Central Cargo is therefore responsible for maintaining compliance in all company activities in terms of procedures, regulations, legal provisions, and codes of conduct. It adopts monitoring and internal control methods in accordance with international standards, implements certification processes in order to improve the quality of services, and carries out integrated assessments of company risks related to active and passive security, money laundering, corruption, and privacy. It also supports the Supervisory Body in monitoring activities to verify the adequacy and compliance of the company’s business with the adopted Model 231, in order to prevent the commission of the offences defined in the aforementioned decree, also implementing third-party technologies and applications for AML, CFT, and KYC monitoring to protect against legal and reputational risks.
Model 231 - Legislative Decree no. 231, dated 8 June 2001
Central Cargo Srl, in compliance with the provisions contained in Legislative Decree No. 231 of June 8, 2001, on the “Regulation of the administrative liability of legal entities,” with a resolution of the Board of Directors on September 30, 2024, has adopted an Organizational, Management, and Control Model pursuant to Legislative Decree No. 231/2001. Management and Control Model pursuant to Legislative Decree No. 231/2001.
The 231 Business Management Model, consisting of a General Part and a Special Part, identifies the operating procedures that Central Cargo Srl adopts to reduce the risk that senior management and subordinates commit crimes for the benefit of the company. The Central Cargo Srl Model 231 is a document whose preparation involved examining every department of the company, allowing for a preliminary analysis of “sensitive” activities considered to be at potential risk under Legislative Decree 231/2001, establishing general principles of conduct, prevention measures, and essential control measures designed to prevent or mitigate illegal acts. Central Cargo Srl’s Model 231 is a dynamic document that is adapted to regulatory and organizational changes in order to ensure its adequacy and suitability.
The Code of Ethics of Central Cargo Srl is an integral part of Model 231 and defines the set of values and principles that inform the company’s activities, establishing rules of conduct for relations with employees, customers, suppliers, and partners.
The adoption of Model 231 is a necessary prerequisite for Central Cargo Srl to be exempt from administrative liability in the event of the commission by its directors and employees, as well as by persons acting in the name and on behalf of Central Cargo Srl itself, of the types of offenses provided for by Legislative Decree No. 231/2001.
The Board of Directors of Central Cargo Srl has also appointed a Supervisory Body (SB), with autonomy of action and specific powers, tasked with verifying compliance with the rules of Model 231, updating it, and reporting to the Board of Directors any possible situations of non-compliance with the provisions of Model 231 itself.
Reporting Violations to Model 231 and UNI PDR 125/2022 CENTRAL CARGO SRL
Reports to the Supervisory Body regarding violations of the company’s Model 231 can be sent by email to:
• email: odv@centralcargo.it
• regular mail addressed to:
Supervisory Body CENTRAL CARGO SRL, Via A. Einstein, 35/45 – 50013 Campi Bisenzio (FI)
Reporting procedure – Whistleblowing
Whistleblowing is the reporting by an employee or by those who, in general, work on behalf of or in favor of CENTRAL CARGO SRL or who have business relations with the latter through any type of contract or assignment, who, in the performance of their duties within the organization to which they belong, have become aware of illegal conduct or irregularities in the workplace that could harm the integrity of the Company or cause damage to third parties.
By implementing Model 231 and UNI PDR 125/2022, CENTRAL CARGO SRL has sought to pay particular attention to the prevention of risks that could compromise the responsible and sustainable management of its business. In compliance with Model 231, UNI PDR 125/2022 and the ANAC whistleblowing guidelines, CENTRAL CARGO SRL provides the Reporting Procedure Portal – Whistleblowing. This area is a web tool available to anyone who wishes to report situations that could cause damage or harm to CENTRAL CARGO SRL, whether it be a potentially dangerous situation, a generic risk, or potential fraud.
The web page dedicated to CENTRAL CARGO SRL’s Whistleblowing Procedure is one of the tools adopted with Model 231 and UNI PDR 125/2022 for internal monitoring and control, to ensure the regularity, correctness, and transparency of activities and as a tool to combat corruption and protect the image, position, and reputation of the Company.
For CENTRAL CARGO SRL, every report is important and, for this reason, must be made in good faith and not anonymously. Therefore, in order to protect the “whistleblower” and the “reported” in the best possible way, the necessary security measures have been adopted. CENTRAL CARGO SRL guarantees the confidentiality of the identity of the writer and the content of the report by adopting an internal protocol using encryption tools that protect personal data and information, including any attachments.
The Supervisory Body appointed by CENTRAL CARGO SRL is the company body responsible for managing reports. The process of managing reports in accordance with the adopted Model 231 and UNI PDR 125/2022 guarantees whistleblowers protection from direct or indirect pressure and discrimination by those responsible for verifying reports. The identity of the whistleblower is never revealed without their consent, except in cases where the investigations carried out following the report fall within the scope of criminal, administrative, or tax investigations, or give rise to disciplinary proceedings based solely on the report received, where knowledge of the whistleblower’s identity is absolutely essential for the defense of the accused.
For CENTRAL CARGO SRL, whistleblowing is an important tool in the security system. The CENTRAL CARGO SRL Whistleblowing Procedure Portal protects the following thanks to its protocols:
• the identity of the whistleblower, allowing disclosure only with their explicit consent;
• the identity of the reported person;
• the confidentiality of the information in any context following the report;
• computerized management with the archiving of reports (ref. Legislative Decree 24/2023) entrusted to the company bodies responsible for receiving and verifying them;
Communication and distribution of Model 231
Central Cargo Srl promotes communication of Model 231, using methods suitable for ensuring its dissemination and effective knowledge by all “Recipients of the Model” as identified in the General Section and Special Section. Model 231 is made available to all employees through publication in a specific section of the company intranet and is available for consultation in paper format at all Central Cargo Srl offices. Model 231 is also brought to the attention of all those with whom Central Cargo Srl establishes contractual relationships, including employees at the time of hiring.
In particular, the commitment to comply with the law and the principles of Model 231 by third parties who have contractual relationships with Central Cargo Srl is governed by specific contractual clauses within the agreements which, depending on the activity regulated by the contract, commit the counterparties to comply with Legislative Decree 231/2001, the principles of this Model 231, and the Code of Ethics. These clauses also provide for specific contractual remedies in the event of non-compliance (e.g., right of termination and/or the right to suspend the execution of the contract and/or penalty clauses).
All those who work with Central Cargo Srl are required to be familiar with and comply with the principles contained in these documents. Violation of these principles will result in the termination of the relationship of trust.
Cultural code - Making a difference
Gender Equality
Central Cargo Srl has officially undertaken the process of obtaining Gender Equality Certification, in compliance with the requirements set out in UNI/PdR 125:2022.
Step by step, we have chosen to embark this journey motivated by the desire to translate into a certification the essence of our company and the values that Central Cargo identifies with and that have always led the way we do business: promoting an inclusive, fair and respectful working environment that recognises the uniqueness of every individual, where everyone can feel valued and have equal opportunities for growth and development.
Our Gender Equality Policy, which you can download at this link, reflects who we are as a company and, above all, the value we place on people.
It is a guideline that recognises work as a source of dignity, justice and freedom.
For us, gender equality is a fundamental element of a culture in which everyone can express themselves with confidence and autonomy, feeling free and respected for their uniqueness.
To formalise these principles, we have engaged Certiquality, an accredited certification body, with whom we are currently undergoing the audit process.
Our Policy does not remain merely on paper; it is in line with our daily activities, our procedures, our way of working and adopted 231/01 Compliance Model.
