Supervisory Body u s anti money laundering laws

Supervisory body

Work in progress

In general, the supervisory body is entrusted with the following tasks:

• supervising the effectiveness of the model, which is concretely realised by controlling the consistency between actual behaviours and the model adopted;

• controlling the model’s suitability, that is its real (and not merely formal) ability to generally prevent unwanted behaviours.

Analysing the maintenance of the model’s solidity and functionality requirements over time:

• also making use of the various functions concerned, assessing the need to propose to the management board any model updates resulting from developments in the organisational structure or business operations and any regulatory amendments;

• supervising the consistency of the system of delegations and assigned responsibilities in order to ensure the model’s effectiveness.

On the operational level, the manutencoop facility management supervisory body is responsible for:

u s anti money laundering laws

• drawing up and implementing a plan to routinely check the effective application of business control procedures in “sensitive activities” and their effectiveness, keeping in mind that the primary responsibility for control over activities is in any case delegated to the operational management and is an integral part of business processes;

• collecting, processing and keeping significant information on compliance with the model as well as, when necessary, updating the list of information that must be obligatorily transmitted to the supervisory body or made available to it;

• monitoring sensitive activities. To that end, the supervisory body is kept continuously updated on the development of activities in the aforementioned risk areas, and has free access to all company records. All personnel must also report to the supervisory body on any business situations which could expose the company to the risk of offences;

u s anti money laundering laws

• conducting the appropriate internal investigations into alleged violations of the model’s requirements;

• controlling that the aspects set forth by the model for the various types of offences (e.G., adoption of standard clauses, carrying out procedures,

Separation of responsibilities, etc.) are in any case suitable and respond to the requirements of observing the provisions of the decree and, if not, requesting an update of those aspects;

• also relying on the contributions of the managers of the various business functions, promoting suitable initiatives to raise

Awareness and understanding of the model amongst all personnel;

• coordinating with the various managers of the different business functions to ensure that internal organisational documentation,

Needed to ensure that the model is functional, is prepared containing instructions, clarifications or updates.U s anti money laundering laws

Since the company is not one of the addressees, precisely listed in articles 10 et seq of italian legislative decree 231/2007 concerning anti-money laundering, the supervisory

Body is not subject to the notification duties set forth in art. 52 of the same decree.

However, should it become aware of sensitive events while conducting its activities, with respect to the cases of offence set forth in art. 25- octies

Of italian legislative decree 231/2001, the supervisory body is required to promptly assess the situation and undertake all actions that it deems opportune (notifications to the management board, activation of the penalty system, etc.).

In order to fully satisfy its duties, the supervisory body:

• has free access to all company functions, without prior disclosure and without the need for prior consent, in order to

Obtain all information or data deemed necessary to carry out the tasks set forth in the decree;

u s anti money laundering laws

• while carrying out the tasks assigned to it, can benefit from the cooperation – under its direct supervision and responsibility – of all company functions and structures or external consultants, relying on their respective skills and professional abilities;

• has a budget defined by the management board during the annual budgeting process, which is suitable to support the expenses that must be made to carry out its functions (specialist consulting, trips and travel, refresher courses, etc.).

The budget allows the supervisory body to work independently and with the appropriate instruments to effectively carry out the

Task assigned to it by this model, according to the provisions of italian legislative decree 231/2001.

• carries out its activities without being controlled other company bodies or structures, and responds only to the management board.