Model 231 and Code of Ethics | PwC TLS

TLS Associazione Professionale di Avvocati e Commercialisti| Organisation and Management Model pursuant to Legislative Decree 231/01

On 18 December 2023, the Management Committee of TLS Associazione Professionale di Avvocati e Commercialisti approved an updated version of its Organisation and Management Model, adopted pursuant to the provisions contained in Legislative Decree 231/01 (so-called "Model 231").

Consistent with what is expected by the reference legislation, a specific Supervisory Body is identified, which is responsible for:

  • supervise the effectiveness of the Model (which takes the form of verifying the consistency between the actual conduct and the established Model);
  • monitor the adequacy of the Model (i.e. its actual capacity to prevent, in principle, unwanted conduct);
  • analyse the maintenance over time of the soundness and functionality requirements of the Model;
  • report the opportunity to update the Model, making specific suggestions in the event that the analyses carried out make corrections and adjustments necessary, and take care of the related follow-up.

Any communications to the Supervisory Board may be made through the ordinary mail address "Organismo di Vigilanza PwC TLS, Piazza Tre Torri 2 - 20145 Milan", or through the dedicated mailbox it_odv.tls@pwc.com".
 

A special internal channel (Whistleblowing Channel) has been set up for making reports relating to the commission or attempted commission of offences covered by Legislative Decree 231/01, as well as to violations (or alleged violations) of the provisions contained in the 231 Model adopted by the Firm.