COMPLIANCE

Fidiger SpA Revisione ed Organizzazione Aziendale, founded in 1970, has offices in Milan and Rome and a staff of about 90 employees who provide administrative and accounting assistance to Italian and international Firms and Companies. Fidiger SpA is authorised to carry out auditing activities pursuant to Law no. 1966 of 23/11/1939 and Royal Decree no. 531 of 22/04/1940 and as such is subject to control and supervision by the Ministry of Economic Development.
The company is a highly reputed firm thanks to its high ethical standards and strict compliance with the law. The accurate selection of our employees and their continuing training are our distinctive marks and enable us to maintain the best professional standards.
The drive towards evolution and innovation has always enabled us to keep up with the times.
Fidiger SpA is well aware of the need to ensure that business and professional activities are conducted with integrity and transparency, for the protection of its role and image, of its stakeholders’ expectations and the work of its management and staff, and for this reason it has decided, consistently with its values, to adopt an Organizational, management and control Model pursuant to Legislative Decree No 231 of 8 June 2001.
Legislative Decree No 231 of 8 June 2001, which introduced into Italian legislation the “Rules on the administrative liability of bodies corporate, companies and associations, with or without legal personality” (implementing Enabling Law No 300 of 29 September 2000), as part of broader anti-corruption legislation, has aligned the relevant Italian legislation to International Conventions entered into by Italy.
Legislative Decree No 231 of 8 June 2001 provides for the administrative liability (basically equivalent to criminal liability) of bodies corporate, in addition to the liability of the individual who actually committed the crime, and is designed to involve in the criminal prosecution of an offence also the entities in whose interest or to whose advantage such offence was committed.
In the following pages you will find the General Section of the Model as well as the Code of Ethics, which stipulates the principles and rules of conduct for the intended recipients of the Model (employees, staff, management) and any third parties (external consultants to the Firm, suppliers etc.), expressly designed to prevent the commission
of predicate offences.
The Firm has appointed a Supervisory Body (Organismo di Vigilanza), to whom anyone who finds himself in the circumstances mentioned in the Model may:
- send an e-mail (to the address odv@Fidiger.com) or
- send a letter addressed to the Supervisory Body of Fidiger SpA, Via Vittor Pisani 16, 20124 Milan.
Likewise, Client Satisfaction and Information security are of paramount importance to the Firm. Fidiger SpA is committed to ensuring maximum Client satisfaction and protecting the security of the information managed through an efficient organization.
Information is essential to offer quality services and information security is of paramount importance.
The accurate management of IT systems has always been of great importance for us and protecting our Clients’ information is an absolute priority.
For these reasons, Fidiger has obtained the ISO 27001:2017 certification on information security. UNI CEI ISO/IEC 27001:2017 is an international standard setting the requirements for establishing and maintaining the Information Security Management System and covers logical, physical and organizational security issues with the

key goal of establishing a system for the management of risk and protection of information and ICT assets.
Control and supervisory activities are supplemented by the audit of financial statements by the independent auditor, with the support of the Board of Statutory Auditors (“Collegio Sindacale”) for the purposes of ascertaining strict compliance with the law and fair conduct of business.