Model of Organization, Management
and Control ex D. Lgs 231/2001
The Decree 231/2001 introduced for the first time the principle of administrative liability for the companies with regard to offences committed in the interest of or to the benefit of the entity, by persons in a senior position or by persons under the direction or supervision of a senior manager.
To ensure the prevention of the violations defined in the Decree, the Board of Directors of Italcoat S.r.l. and IPS Industrial Packaging Solution S.r.l. adopted a Model of Organization, Management and Control according to the Decree 231.
The current Model 231 of each company was approved in the Board of Directors on 16th December 2025.
The Board of Directors, with Model 231, formalizes and describes principles, rules of conduct and controls for specific sensitive processes, in order to prevent and counteract the risk of committing illicit acts.
Each Company disseminates the Model and the Code of Ethics, inside and outside the Company, so that administrators, managers, staff and collaborators as well as, in general, people who have relationships with the Company, can view them and comply with its principles, values and ethical-behavioral norms.
A specific system of sanctions, structured according to the different types of subjects, is defined in case of violation of the provisions of the Model.
The Decree 231/01 defines the creation of a Supervisor Body with independent powers of initiative and control, whose duty is to supervise the functioning of and compliance with the Organization and Management Model and to ensure its updating.
The Supervisory Body of Italcoat S.r.l. and that of IPS Industrial Packaging Solution S.r.l., appointed by the respective Board of Directors, have a collective body, adequate to characteristics, dimensions and activities of the company.
To the Supervisory Body can be reported violations of the Model 231 and the Code of Ethics, or can be requested further information, at the email odvitc231-2001@italcoat.com or odvips231-2001@ipsariflex.com.
Code of Ethics of the Group
The Code of Ethics encompasses all the values that guide the activities of the Laminazione Sottile Group and represents the tool for sensitizing employees, collaborators and all stakeholders to respect the highest standards of transparency and correctness in carrying out their duties.
Code of Conduct for Suppliers
The Code of Conduct for Suppliers represents an extension of our Code of Ethics, to share the Group’s values with our partners and define the principles and rules of conduct that they must adopt in managing commercial relationships with the LS Group.
Anti-Corruption & Anti-Fraud Policy
Our Anti-Corruption and Anti-Fraud Policy, in compliance with laws prohibiting the corruption of public officials and corruption between private individuals (including Legislative Decree 231/2001 enacted in Italy), establishes the LS Group’s commitment to:
- conduct its activities in compliance with all applicable anti-corruption and fraud regulations in the countries where it operates
- promote a preventive culture based on the “zero tolerance” principle for all forms of fraud and corruption
- disseminate rules to which all personnel and stakeholders are required to adhere, in order to minimize the risk of behavior that may be attributable to corruption and/or fraud