Organizational and management model

Sea Energia Spa, in order to ensure conditions of fairness and transparency in the conduct of business and company activities, has decided, in accordance with its own policies and those of the Group to which it belongs, to proceed with the adoption of an Organization and Management Model in line with the provisions of Legislative Decree 231/01 and the Guidelines issued by Confindustria.

The "Organization and Management Model" sets out the principles adopted and the activity carried out by the company to prevent the crimes covered by Legislative Decree 231/01 and the incurring of administrative and criminal liability of the legal persons regulated therein.

The MOG adopted by Sea Energia Spa consists of two "parts":

  • a "General Part
  • a "Special Section", prepared for the different categories of crime covered by the decree.


The "General Section" illustrates and describes, in summary: the contents and implications of Decree 231, the basic principles and objectives of the OMC, the steps taken to comply with the regulations, the guiding principles underlying the company protocols and the system of delegations/proxies for the exercise of powers, the penalty system, the recipients and scope of application of the OMC, the task and responsibility of the Supervisory Board, the way in which it is disseminated and reported, the way in which it is controlled and updated.
The "General Part" is approved - on the proposal of the Supervisory Board - by the Company's top management body (BoD).

The "Special Part" of the MOG, designed to supplement and complete the content of the "General Part", identifies:

  • the types of offence envisaged by Legislative Decree 231/01;
  • the sensitive activities considered more specifically to be at potential risk of offence;
  • the "General principles of conduct" with which the recipients of the Model must comply in order to prevent the occurrence of the offences envisaged;
  • the "Specific procedural principles" adopted as prevention measures (protocols).

The "Special Part" is also closely linked to the individual components of the MOG prepared and periodically updated by Sea Energia Spa; these are constituent elements of the Model:

  • Risk mapping
  • Code of Conduct
  • Company organizational system
  • Corporate and group procedural system
  • Authorization and signature powers
  • Reward system and sanctioning apparatus
  • Staff communication and training
  • Corporate Information System
  • Other Control activities.

The "Special Part" is approved - upon proposal of the Supervisory Body - by the Company's top management body (BoD).


The recipients of the Model are all those who work to achieve the purpose and objectives of the Company, and therefore the members of the corporate bodies (Directors and Statutory Auditors) and employees of SEA Energia, as well as external parties who deal with the Company (consultants, customers, suppliers).
Each recipient is required to be familiar with the Model, to actively contribute to its implementation, as well as to report any shortcomings to the Supervisory Body.


For reports relating to the Organisation and Management Model pursuant to Legislative Decree 231/01:

Via web

Click here to access the computerized reporting channel.
(Browsers are required to access the Platform: Internet Explorer - version 10 or higher; Google Chrome)

By letter (personal confidential in closed envelope)

Supervisory Body pursuant to Legislative Decree 231/01 SEA ENERGIA

Supervisory Body of Sea Energia ex D. Lgs. 231/2001
c/o SEA - Società per Azioni Esercizi Aeroportuali
Airport Milan Linate - 20090 Segrate Milan
c/o Auditing Management
Personal Reserved

Ethics Committee

Ethics Committee
c/o SEA - Società per Azioni Esercizi Aeroportuali
Airport Milan Linate - 20090 Segrate Milan
Personal Reserved