Ethics Code and Organizational Model
The pursuit of a sustainable future is fundamentally rooted in integrity as a driver of development and growth. The Code of Ethics adopted by the Sapio Group guides every decision, action, and relationship according to the principles of legality, transparency, ethics, and respect, in full alignment with the Group’s core values. Sapio operates with the objective of creating value for customers, suppliers, employees, and the wider community, while proactively protecting and preserving environmental resources.
The SAPIO Group recognizes the social importance and collective value of its activities. It conducts its operations in accordance with the ethical principles set forth in its Code of Ethics and requires compliance with these principles from all individuals and organizations involved in its business activities.
The SAPIO Group firmly believes that adherence to ethical principles is an essential prerequisite for sustainable growth. It considers its reputation and corporate image to be valuable assets that must be protected and enhanced through the widespread dissemination, sharing, and observance of the ethical and behavioral principles contained in its Code of Ethics.
The Organizational, Management and Control Model, adopted pursuant to Italian Legislative Decree No. 231/2001, complements the Code of Ethics and serves as an operational framework for implementing the principles it establishes.
SAPIO Group Code of Ethics
The definition of an “Ethical Company,” embraced by BioRep as part of the Sapio Group, reflects a deliberate strategic choice. This concept only partially captures the broader set of values and principles that guide the Group’s daily management, production, commercial, research, and development activities.
These ethical and behavioral principles shape the Group’s relationships with employees, customers, partners, suppliers, and other stakeholders, while also guiding its corporate governance practices.
Since its foundation, BioRep has recognized energy efficiency, environmental protection, sustainable development, social responsibility, education and professional training, support for the educational system, and technological collaboration with public institutions as fundamental drivers of its strategic decisions, reflected even in its everyday operations.
Organizational, Management and Control Model pursuant to Legislative Decree 231/2001
Italian Legislative Decree No. 231/2001 introduced into the Italian legal system a framework governing the administrative liability of legal entities, including companies, associations, and other organizations, for certain criminal offenses committed in their interest or for their benefit.
Under this legislation, organizations may be held liable for crimes committed by:
- Individuals holding representative, administrative, or managerial positions;
- Individuals responsible for the management or control of the organization, whether formally appointed or acting in practice;
- Individuals operating under the direction or supervision of the above-mentioned persons.
The liability of the organization is additional to the criminal and civil liability of the individual who committed the offense.
In accordance with the provisions of the Decree, organizations must establish an independent supervisory body responsible for monitoring the effectiveness, implementation, and updating of the Organizational Model. This body must be independent from the Board of Directors.
To ensure the effectiveness of its Organizational Model, BioRep has established independent Supervisory Bodies (Organismi di Vigilanza), to which reports of actual or suspected violations may be submitted via email at:
ovd@biorep.it
Whistleblowing
Following the implementation of Italian Legislative Decree No. 24/2023, which transposes EU Directive 2019/1937 on the protection of persons who report breaches of Union law and national regulations, the Company has established an internal reporting channel to enable the confidential and secure submission of whistleblowing reports.
GDPR and Personal Data Protection
The Sapio Group recognizes the protection of personal data as a fundamental right.
The protection of personal information has always been a key priority for the Group. Through its Privacy Organizational Model (POM), Sapio defines and communicates its approach to the processing and protection of personal data belonging to all individuals who provide their information to the Group or whose personal data are processed as part of the Group’s activities.
To ensure compliance with applicable privacy regulations and the highest standards of data protection, Sapio has implemented a dedicated Privacy Organizational Model, which may be requested by contacting:
GDPR@sapio.it