MODEL 231

The 231 Organization, Management and Control Model is a cohesive set of principles, provisions and behaviors to be adopted when carrying out activities and dealing with various internal and external stakeholders. Any reference policies, procedures and operating instructions are considered an integral part of the Model.

Bocconi University has therefore aligned its Model with current legislation (Legislative Decree no. 231/01), preparing its own 231 Model.

The proper adoption of the Model represents the most important safeguard designed to prevent the "administrative liability" of the University as defined by the Decree for offenses committed or attempted by its directors, employees and collaborators.

To prevent the risk of committing the offenses mentioned in the legislation, all staff and faculty must comply with the principles and provisions of Model 231. All other subjects who engage with them in various ways (clients, donors, students, suppliers, partners, collaborators, etc.) must also comply with the principles and provisions of the Model.

Scope of the Model

to clearly represent the Governance system in a manner that is integrated with regulatory and organizational requirements;
to establish principles and rules of conduct aimed at promoting and enhancing an ethical culture, which supports equity and transparency in the conduct of all university activities;
to set up a structured and organic system of prevention and control aimed at reducing the risk of committing offenses related to the University's activities;
to increase awareness among anyone working in the name of and on behalf of Bocconi in the "areas of activity at risk" that, in the event of violation of the provisions contained therein, they may incur an offense punishable by sanctions both against the perpetrator of the violation (at the civil, disciplinary and, in some cases, criminal level) and against the University (administrative liability pursuant to the Decree);
to notify anyone who operates in any capacity in the name of, on behalf of or in the interest of Bocconi that the violation of the provisions contained in the Model entails the application of appropriate sanctions, and possibly the termination of the contractual relationship;
to reiterate that Bocconi does not tolerate unlawful conduct of any kind and for any purpose, as such conduct – even if the University were seemingly in a position to take advantage of it – is contrary to the ethical principles to which Bocconi intends to adhere;
to effectively censure conduct in violation of the Model through the application of disciplinary and/or contractual sanctions.

For more information, please refer to the document: Bocconi University Organization, Management and Control Model pursuant to Legislative Decree No. 231/2001

For clarifications and further information on the 231 Model, please contact:

231 Compliance and Internal Audit
procedure231@unibocconi.it

Regulatory body

The task of supervising the Model's observance and operations as well as generally maintaining and keeping it updated has been granted to the University Board and to a collective body named the Regulatory Body. This body has been given autonomous powers of initiative and control.

The Regulatory Body is composed of:

Avv. Bruno Giuffré
Dott. Enrico Maria Bignami
Dott.ssa Rosalba Casiraghi

Any violation or suspected violation of Model 231 and/or any other information pertaining to accomplishing its goals can be reported non-anonymously to the Regulatory Body, who will then ensure the confidentiality of the person making the report.

Reports must be sent by email to
organismo.vigilanza@unibocconi.it