Mia‑Platform Governance

Principles and tools we adopt to sustain the Company's management and growth.

Mia‑Platform reception wall with the 3D company logo and lettering, blue lounge sofas, and colored hexagon outlines overlaid on the photo

Compliance

Organization, Management and Control Model 231/2001

How we prevent unlawful conduct and keep our growth aligned with our values.

Mia‑Platform has adopted the Organization, Management and Control Model under Italian Legislative Decree 231/2001, with procedures designed to prevent unlawful conduct that could expose the Company to liability. The Model integrates a sustainability risk assessment inspired by the United Nations 2030 Agenda.

It raises awareness among everyone acting on behalf of Mia‑Platform about legal compliance and our ethical principles, and it creates value for our stakeholders through legitimacy, fairness and transparency.

A Supervisory Body oversees the Model’s functioning, effectiveness and ongoing update.

If you become aware of any violation of the Model or our Code of Ethics, you can report it to odv@mia-platform.eu.


Whistleblowing

Whistleblowing

An internal channel for reporting unlawful conduct and irregularities, under Italian Legislative Decree No. 24/2023.

Mia‑Platform, in compliance with Legislative Decree No. 24/2023, has set up an internal reporting channel as a tool for reporting unlawful conduct or irregularities.

With the entry into force of Legislative Decree No. 24/2023, on 30 March 2023, a new regulatory framework on whistleblowing was introduced into the Italian legal system. The measure, implementing European Directive No. 2019/1937, brings together in a single piece of legislation the entire regulatory framework on reporting channels and the protections afforded to reporters, in both the public and private sectors.

Reports must be submitted through the specifically designated channels; the choice of reporting channel is no longer left to the discretion of the whistleblower, as priority use of the internal reporting channel is promoted.

In compliance with Legislative Decree No. 24/2023, the Company has set up a platform as an internal reporting channel, in addition to the external ANAC channel, as a tool enabling the whistleblower (employees and all those falling within the categories contemplated by the Legislative Decree) to report unlawful conduct or irregularities, even if presumed, of which they have become aware. The subject matter of reports is not limited to criminal offences, but also includes other conduct considered relevant insofar as it concerns behaviour, risks or irregularities that harm the public interest or the integrity of the entity.

Use of the platform allows the anonymity of the identity of the reporting person, the person involved and any person mentioned in the report to be maintained, as well as the content of the report itself and any related documentation. Once the report has been submitted, the system will issue a receipt bearing the identifying number of the report, which the whistleblower is required to retain.

Legislative Decree 24/2023 provides for the possibility of an external report where:

  • An internal report has already been made and no follow-up action has been taken.

  • The internal reporting channel is not active or, even if activated, does not comply with the requirements of the legislation.

  • There are reasonable grounds to believe that, if an internal report were made, it would not be effectively followed up, or that the report itself could give rise to retaliation/discrimination.

  • There are reasonable grounds to believe that the breach could constitute an imminent or manifest danger to the public interest.

In the cases listed above, the report must be submitted exclusively to ANAC through the methods provided for and available on the Authority’s website.

Reference: Legislative Decree No. 24/2023.