Page 16 - Parmalat 2017 Consolidated Statement

Organization, Management and Control Model

Parmalat S.p.A. and its Italian subsidiaries, when deemed appropriate, adopted an Organization, Management and
Control Model pursuant to Legislative Decree No. 231/2001 (hereinafter “the Model”), based on a risk assessment
process that made it possible to map those activities within which potential risks deriving from the perpetration of
the crimes listed in Legislative Decree No. 231/2001 could be identified. The Model, which also addresses some of
the issues of Decree No. 254/2016, is continuously updated in order to ensure that it is constantly aligned with the
applicable regulations. At this point, regarding potentially unlawful conduct, the Group has identified the main
activities that could entail the risk of perpetration of the following crimes:
• crimes against the Public Administration;
• corporate crimes, including the crime of corruption between private parties;
• market abuse crimes and administrative violations;
• involuntary manslaughter or serious and extremely serious bodily harm resulting from violations of
occupational health and safety laws;
• receiving, laundering and using money, assets or benefits of unlawful origin, including self-money
laundering;
• crimes against industry and commerce and crimes involving the counterfeiting of currency, public credit
instruments, revenue stamps and identification tools or signs;
• crimes involving copyright violations;
• environmental crimes;
• crime of employing citizens of a foreign country who are not lawful residents.

For each one of the types of crimes listed above, the corresponding sensitive activities were identified and the
general principles that guide the Parmalat Group in defining the organization and management rules for the
abovementioned activities and the respective prevention procedures were identified.

The Supervisory Board (SB) is the entity responsible for monitoring, on an ongoing basis, the implementation of
and compliance with the Model and ensure that it is kept up-to-date. In addition, the Group Internal Auditing
function performs audits of the internal control system relative to its compliance objectives regarding laws and
standards, as well as Company regulations and procedures, with special emphasis on the Organization,
Management and Control Model pursuant to Legislative Decree No. 231/2001.

Parmalat promote the dissemination and effective knowledge of the Model and punishes any behavior that is
contrary to law and does not comply with the provisions of the Model and the Code of Ethics. All parties to whom
the Model applies are required to cooperate for its full and effective implementation, immediately reporting any
violation. Parmalat also requires the implementation of mandatory training programs, with the aim of ensuring
and effective knowledge of the Decree, the Code of Ethics of the Parmalat Group and the Model by Parmalat’s
employees.

Parmalat promotes the adoption of the Model or, in general, of principles and organization and control rules
consistent with those of the Model also by foreign subsidiaries that do not operate in Italy. To that effect, Parmalat
adopted the “Guidelines pursuant to Legislative Decree No. 231/2001 for the foreign subsidiaries of Parmalat
S.p.A.,” specifying the organization principles and rules of conduct that the abovementioned companies are
required to comply with, while respecting the laws applicable in the countries where they are located and with
their existing organizational structure and internal policies.

16 Consolidated Non-financial Statement at December 31, 2017 Pursuant to Legislative Decree No. 254/2016