STERLING AND THE 231 MODEL: A COMMITMENT TO RESPONSIBILITY

 

In recent days, you may have heard about the Organisation, Management and Control Model 231, which Sterling has adopted in accordance with Italian Legislative Decree 231/2001. But what does this truly mean for us?

It means that Sterling chooses to operate with transparency, integrity, and accountability. The 231 Model is not merely a regulatory document, but a structured system of shared values: a practical guide to prevent misconduct, manage risks, and ensure a healthy, safe, and ethical working environment.

WHY IT MATTERS TO ALL OF US

Corporate ethics Adhering to the 231 Model means placing ethical and transparent behaviour at the heart of every activity, across all levels of the organisation.

A culture of prevention The Model identifies risk-prone areas and outlines measures to prevent violations and mistakes, protecting the organisation and its people.

Empowering individual roles Everyone plays a part: each employee actively contributes to the effectiveness of this system, with awareness and a sense of responsibility.

Collective protection Following the principles of the 231 Model safeguards us as individuals and as a company, strengthening mutual trust and the confidence of our partners.

HOW DOES IT WORK IN PRACTICE?

The 231 Model consists of two main parts:

  • a general section, which outlines the principles, roles, and procedures;

  • a special section, which identifies risk areas and defines the appropriate control measures.

It is supported by key tools such as the Code of Ethics and the whistleblowing system, which ensures a safe and confidential channel for reporting concerns.

Oversight is entrusted to an independent body, headed by Avv. Raffaele Perfetto, which ensures the correct implementation and monitoring of the Model.

TOGETHER TOWARDS A STRONGER, MORE AWARE, AND MORE ETHICAL STERLING.

In recent days, you may have heard about the Organisation, Management and Control Model 231, which Sterling has adopted in accordance with Italian Legislative Decree 231/2001. But what does this truly mean for us?

It means that Sterling chooses to operate with transparency, integrity, and accountability. The 231 Model is not merely a regulatory document, but a structured system of shared values: a practical guide to prevent misconduct, manage risks, and ensure a healthy, safe, and ethical working environment.

WHY IT MATTERS TO ALL OF US

Corporate ethics Adhering to the 231 Model means placing ethical and transparent behaviour at the heart of every activity, across all levels of the organisation.

A culture of prevention The Model identifies risk-prone areas and outlines measures to prevent violations and mistakes, protecting the organisation and its people.

Empowering individual roles Everyone plays a part: each employee actively contributes to the effectiveness of this system, with awareness and a sense of responsibility.

Collective protection Following the principles of the 231 Model safeguards us as individuals and as a company, strengthening mutual trust and the confidence of our partners.

HOW DOES IT WORK IN PRACTICE?

The 231 Model consists of two main parts:

  • a general section, which outlines the principles, roles, and procedures;

  • a special section, which identifies risk areas and defines the appropriate control measures.

It is supported by key tools such as the Code of Ethics and the whistleblowing system, which ensures a safe and confidential channel for reporting concerns.

Oversight is entrusted to an independent body, headed by Avv. Raffaele Perfetto, which ensures the correct implementation and monitoring of the Model.

TOGETHER TOWARDS A STRONGER, MORE AWARE, AND MORE ETHICAL STERLING.