Thema’s business is based on an effective internal control system, which allows the company to be conducted consistently with corporate objectives and ethically, through a process capable of creating added value for all stakeholders.

Thema is committed to fully complying with the values of integrity and transparency that are the essence of our company’s culture and that everyone should know and respect. In the same way, we must share our path externally, to show you how we intend to carry out our business activities, continuing to invest in the growth of a culture of compliance.

The Company intended to launch a project for the profound renewal of its compliance in the area of corporate criminal liability by approving the Organisation, Management and Control Model under Legislative Decree No. 231/2001, as well as by appointing the relevant Supervisory Board.

By adopting the Model, the Company intends to prevent the risk that the exercise of its business activity becomes an opportunity for the commission of offences, with particular attention to those referred to in the decree mentioned above.

The Company has adopted a system for handling reports concerning unlawful or illegal conduct. This includes anonymous reports, provided they are adequately substantiated.

Reports can be made through the platform available at the link, which is considered a preferential channel as it can guarantee the confidentiality of the reporter’s identity in a computerised manner.

Through the platform, the reporter will be guided through each step of the reporting process and will be provided with a series of mandatory fields to be filled in, to better substantiate the report.

The Supervisory Board will handle reports.

Bona fide whistleblowers are protected against any form of discrimination, retaliation or penalisation, and the correct fulfilment of the reporting duty cannot lead to the initiation of disciplinary proceedings or the application of the relevant sanctions.
Adoption of the above-mentioned system does not preclude, however, reporting any violations of laws or government regulations to the competent authority.

The Whistleblowing Procedure is at your disposal.

The General Part and the Code of Ethics, designed to inspire and guide the behaviour of Thema’s staff and all our stakeholders, are at your disposal.

Download the Code of Ethics

Download the Management and Control Model – General Part

Download the Whistleblowing Procedure