CODE OF ETHICS

The Italian Legislative Decree 231/2001 introduced a new regime of direct criminal-administrative liability for Companies, related to crimes and offences committed by individuals in top-level positions or under their management or supervision in their own interest and/or to their advantage.

In the event of an infringement of any of the Legislative Decree’s provisions, a company may be held liable and, consequently, subject to monetary penalties and/or prohibitory measures; which could seriously affect its business activity.

The Decree provides corporate liability exclusion only where the Company can demonstrate that:

  1. prior to committing the illegal or infringing act, it adopted and implemented a suitable Organizational and Conduct Model to prevent the commission or occurrence of the crime or illegal act;
  2. Has appointed a Supervisory Body, which exercises independent powers of initiative and control, with the task of monitoring compliance with the Model;
  3. Individuals having committed the offence, fraudulently circumvented the Model;
  4. There was no omission or insufficient degree of surveillance by the Supervisory Body.

In light of the foregoing and in compliance with the Legislative Decree 231/2001, the Creative Academy adopted its Organizational and Conduct Model and its own CODE OF ETHICS, published in this section.