Organisation and Management model

Organisation and Management model

Model 231

CUOA Business School has adopted an Organisation and Management Model pursuant to Legislative Decree no. 231 of 8 June 2001, as amended. This model was approved by the CUOA Board of Directors on 23 November 2016 (so-called “Model 231”).
Legislative Decree no. 231/2001 introduced the principle of administrative liability of entities (natural persons, companies and associations, including entities without legal status) with the provision that they can be held liable for certain offences committed in their interest by representatives, agents, directors, executives, managers, employees and everyone who works in the name and on behalf of the entity itself, if they gain interest or benefit from such offences. The liability of the entity translates into heavy fines and into the suspension or disqualification of business activities.
The entity may not be deemed liable of committing these offences if it proves to have adopted and effectively implemented, before the offence was committed, an “Organisation, Management and Control Model” designed to prevent crimes such as that which occurred and if it has set up an internal Inspection Body in charge of supervising the functioning, effectiveness and compliance with the model.
In the implementation of Model 231, the CUOA Business School, in view of the activities performed and their characteristics, also wanted to consider additional specific cases deriving from Law no. 190 of 28/11/2012 and the National Anticorruption Plan of the National Anticorruption Authority of 28/10/2015 (corruption cases).
These measures also meet the need for effective management and prevention of the risk of pursuing private purposes in the performance of duties by people acting on behalf of CUOA (risk of maladministration).
The Model consists of a complex set of principles, rules of conduct, protocols and procedures to be followed by those working on behalf of the CUOA Business School in order to prevent the commission of the offences set forth in Leg. Decree no.  231/2001 within the scope of processes considered to be risk-sensitive.
Below is a list of some of the documents that make up Model 231 of the CUOA Business School:
- the General Part of the Model, which describes the purpose and functioning of the Model, and duties of the Inspection Body;
- the Code of Ethics, which defines the values and behavioural principles to be followed by people belonging to the administration and control bodies, managers, employees, trainees, collaborators, faculty members, consultants, suppliers, partners and anyone else who acts on behalf of CUOA or collaborates with it, also in order to achieve the objections for the application of the Model;
- the System of Sanctions, structured according to the different types of entities, which defines the sanctions resulting from violation of the provisions of the Model.

A collegiate Inspection Body was also appointed to carry out, within the limits of its competence, the functions of supervision, control and compliance of the Model provided for by Leg. Decree no. 231/2001. Any reports of violations or suspected violations to Model 231, the Code of Ethics or requests for further information can be made to the Inspection Body:
- by e-mail at
- by ordinary mail to Inspection Body 231 c/o the CUOA Foundation, CUOA, Via G. Marconi 103, 36077 Altavilla Vicentina (VI).
The Inspection Body guarantees absolute confidentiality and anonymity of those who report offences, subject to the legal obligations and protection of rights of the CUOA Business School.

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