Legislative Decree no. 231 of 8 June 2001, concerning "Regulations on the administrative liability of legal entities, companies and associations with or without legal personality" (hereinafter, "Decree 231"), introduced for the first time into the Italian legal system a "punitive system" for legal persons (companies, associations, foundations, etc.) for certain specific offences (so-called "predicate offences"), committed by top management (directors, managers, etc.) or employees/collaborators in the interest of or for the benefit of the organisation.

This responsibility is in addition to (and does not replace) that of natural persons who materially committed the offence and is directly liable before Judges in a Criminal Law Court for the offence committed.

In the event of ascertainment of liability as referred to in Decree no. 231, the sanctions to be imposed on the entity may be of a pecuniary nature, established by the Judge based on the seriousness of the act and the responsibility of the entity, or disqualifying, i.e., affecting the activity of the entity in various ways (e.g., exclusion from subsidies, financing or grants, disqualification from carrying out the activity, etc.).

All these responsibilities and consequences can be avoided or reduced if the entity has adopted and effectively implemented a compliance programme suitable for preventing the offences referred to in Decree no. 231 ("Compliance Programme") from being committed and has set up a supervisory and control body with the task of supervising compliance with the Compliance Programme.

Therefore, exemption from liability of the entity depends on a judgement on the suitability of the compliance programme adopted by it as to whether it is able to prevent the risk of committing the crimes provided for in Decree no. 231.

The Mediaset Group, like other major national and international groups and companies, has adopted a Code of Ethics establishing a set of values that the Mediaset Group recognises, accepts and shares, at all levels, in the performance of its business activities.

The provisions of the Code of Ethics express the fundamental principles and values that inspire the Mediaset Group and provide specific examples of the general duties of diligence, honesty and fairness that characterise the performance of work and conduct in the workplace.

The Code of Ethics was adopted - and subsequently updated - with the aim of setting out and/or confirming those values whose observance is essential for the regular performance of its activities, and the reliability of its management and its image, in the belief that ethics in business is to be pursued as a prerequisite condition for the company's success.

The principles and provisions of the Code of Ethics are a shared set of values for all Mediaset Group companies and shall be binding on the members of company bodies, all persons bound by an employment contract with the Mediaset Group and all those who work for/with Group companies, regardless of the relationship, even temporary, in place between them.

This version of the Mediaset Group's Code of Ethics was approved by the Board of Directors of Mediaset S.p.A. on 5 February 2019 and, subsequently, also by the other Italian subsidiaries.

Future updates of this Code of Ethics, resulting from regulatory changes, changes in civil society, or otherwise, shall be adopted by the Board of Directors and promptly circulated to all Recipients.

Legislative Decree no. 231 of 8 June 2001 ("Legislative Decree 231") introduced for the first time into the Italian legal system an "administrative liability" system for companies for certain crimes or administrative offences committed in their interest or to their advantage by persons acting in their name or on their behalf.

Within the framework of the existing preventive control system, Mediaset S.p.A. and its Italian subsidiaries have adapted and professionally updated their Compliance Programmes to the requirements of this legislation, with the aim of establishing a structured and comprehensive system of general, behavioural and operational rules, which meets the objectives of Legislative Decree no. 231/01 both in terms of preventing the offences provided for by it, and in terms of control over the effective implementation of these programmes.

The first version of the Compliance Programme of Mediaset S.p.A. was approved by the Board of Directors on 29 July 2003 and subsequently amended and supplemented several times until the current version dated 5 February 2019.

With reference to the Italian subsidiaries, similar initiatives have been taken to adapt and implement the respective Compliance Programmes pursuant to Legislative Decree 231, taking into account the structure of each and the specific company operations.

In compliance with the provisions of Legislative Decree no. 231/01, the Compliance Programmes pursuant to Legislative Decree 231 provide for the appointment, for each company, of a body with independent control and initiative powers, called upon to oversee the proper functioning of the Compliance Programmes as well as their constant updating.
In order to ensure that the Compliance Programmes are actually and effectively implemented, the Body must have the following characteristics:
Autonomy;  Independence;
Professionalism;  Continuity of action.

The Supervisory and Control Body has mainly a collective composition, as it is considered suitable to meet the need to entrust this role and responsibility to persons who fully ensure the effective autonomy and independence that this body must necessarily have.
The Compliance Programmes pursuant to Legislative Decree 231 require that the Supervisory and Control Body be appointed by the Board of Directors, subject to verification (i) of the requirements of integrity similar to those of the directors and of professionalism appropriate to the role to be filled; (ii) of non-subsistence of incompatibility and conflict of interest with other corporate functions and/or positions.
The Supervisory and Control Body carries out the tasks and activities provided for by the Compliance Programmes pursuant to Legislative Decree 231 and may at any time carry out checks on their application.
The Compliance Programmes pursuant to Legislative Decree 231 set out information obligations of the various company functions vis-à-vis the Supervisory and Control Body.
For information purposes as well as for reporting violations or unlawful conduct relevant to the purposes of Legislative Decree 231/01, the Supervisory and Control Bodies have specific e-mail addresses, accessible solely by their members, as indicated below:

odv.mediaset@mediaset.it 
odv.rti@mediaset.it 
ovc@publitalia.it 
ovc@digitalia08.it 
odv.elettronicaindustriale@mediaset.it 
odv.medusafilm@mediaset.it
odv.taodue@mediaset.it 
odv.radiomediaset@mediaset.it 
odv.monradio@mediaset.it
odv.RadioStudio105@mediaset.it 
odv.VirginRadioItaly@mediaset.it 
odv.rmcitalia@mediaset.it
odv.r2@mediaset.it 
odv.radiosubasio@mediaset.it 
odv.mediasetitalia@mediaset.it

In compliance with the provisions of the current legislation (Law no. 179 of 30 November 2017 on "Provisions for the protection of the authors of reports of crimes of irregularity of which they have become aware in the context of a public or private employment relationship"), the Mediaset Group has consolidated its system for reporting violations and illegal conduct relevant to Legislative Decree no. 231/01 by providing, in addition to the appropriate e-mail addresses assigned to the Supervisory and Control Bodies of the various Group companies, for the use of a dedicated computer system, accessible via the Internet at the link to "segnalazioni.mediaset.it", in accordance with the terms and conditions set out in the Organisational Guidelines ("Reporting violations and illegal conduct relevant under Legislative Decree 231/01").

Reports must be detailed and based on accurate and consistent factual elements, must relate to facts/acts/events known and directly verified by the whistleblower and must be accompanied, where possible, by adequate documentation proving what has been reported.

Any reports received are managed ensuring, without prejudice to legal obligations, absolute confidentiality on the identity of whistleblowers whose personal data are stored by using an algorithm that ensures maximum security, as required by current legislation, also in order to avoid retaliation or any form of discrimination or penalisation against them.

To obtain the credentials to access the system see the document below.

PDF LGO ("Reporting of violations and illegal conduct relevant under Legislative Decree 231/2001") here: