Ethics and Compliance
Last update: 26 October 2025
Legislative Decree 231/2001
Organisational, Management and Control Model
Legislative Decree No. 231/2001 introduced rules governing the administrative liability of companies for certain criminal offences committed by employees or collaborators in the interest or for the benefit of the company..
The Organisational, Management and Control Model, as defined by the Decree, sets out a structured system of internal controls aimed at preventing the commission of such offences. It also guides those acting in the name and on behalf of the company to adopt lawful and ethical conduct.
KOS Group companies have long adopted an Organisational, Management and Control Model in accordance with the principles of Legislative Decree 231/01, ensuring its continuous alignment with regulatory developments.
In order to oversee the proper functioning and compliance of the Model, Supervisory Bodies have been appointed.
Supervisory Body
Each KOS Group company has appointed an autonomous and independent Supervisory Body (OdV), responsible for monitoring the effectiveness and compliance of the Model pursuant to Article 6(1)(b) of Legislative Decree 231/2001.
Members of the Supervisory Body
KOS S.p.A.:
Dr Stefania Chiaruttini (Chair)- Lawyer Fernando Massara
- Dr Laura Spennagallo
Operating Companies:
- Dr Vittorio Gennaro (Chair)
- Dr Laura Spennagallo
Reports may be submitted to: organismodivigilanza@kosgroup.com
Anti-Corruption Guidelines
KOS Group actively promotes a culture of transparency, integrity and accountability in the conduct of its operations and the management of assets, resources and corporate information.
In compliance with Legislative Decree 231/01 and inspired by national anti-corruption guidelines, the Group has adopted a set of rules, policies and procedures to provide a structured framework for all personnel and collaborators. These include specific prevention and control measures, particularly regarding interactions with public authorities and private entities, to mitigate the risk of offences covered by the Decree.
Code of Ethics
KOS Group recognises the ethical and social significance of its work and its role within the communities it serves. To reflect this, the Group has adopted its own Code of Ethics, which must be respected and applied by everyone working within or on behalf of KOS.
The Code of Ethics, adopted in 2008, outlines the ethical principles and behavioural standards that directors, managers, employees and collaborators are required to follow.
It defines rules aimed at preventing unlawful behaviour, enhancing efficiency and transparency in operations, meeting the needs of the public, and informing stakeholders of the conduct they can expect from KOS representatives.
The Code also formalises the Group’s ethical commitments and responsibilities, aligning behaviours with the highest standards of fairness and transparency.
It is issued by the Board of Directors of KOS, which is responsible for its promotion and implementation. The Code is an integral part of the 231 Compliance System.
Respect for the Code stems from shared values. Any breach or suspected breach of the Group’s ethical principles can be reported through the Whistleblowing System.
Violations of the Code of Ethics may constitute a breach of contract and may result in legal consequences.
Codice etico Gruppo KOS
Whistleblowing System
KOS Group is committed to upholding its values across all relationships with employees, commercial partners and suppliers. It actively opposes any conduct inconsistent with its values, policies, procedures, the 231 Model, the Code of Ethics or applicable Italian and European regulations.
In compliance with Legislative Decree No. 24/2023 (the “Whistleblowing Decree”), implementing EU Directive 2019/1937, KOS has established a Whistleblowing System to allow the reporting of unlawful conduct as defined by law.
Through this platform, individuals may report violations of the Code of Ethics or the 231 Model that they have directly observed in a professional context.
The reporting platform is accessible at: kosgroup.integrityline.com