Organisation and Management Model

Since 2003, SEA has adopted an Organisation and Management Model in line with the provisions of Legislative Decree no. 231/2001, and taking into account the guidelines published by Confindustria, in order to ensure correctness and transparency in the conduct of business and in corporate activities.

The Organisation and Management Model, which was recently amended and supplemented with the Board of Directors resolution of 25th March 2021, contains the principles adopted and the activity carried out by SEA to prevent crimes subject of Legislative Decree no. 231/2001 and avoid incurring the administrative and criminal liability of legal entities pursuant to said decree.

The Organisation and Management Model adopted by SEA is composed of two parts:

  • a General Part;
  • a Special Part, designed for the various categories of crimes contemplated by the Decree.

The two parts of the Organisation and Management Model

The General Part, approved by the Board of Directors, illustrates and describes in summary: contents and implications of Legislative Decree no. 231/2001, basic principles and objectives of the model, requirements put in place to comply with the law, inspiring principles forming the basis of corporate protocols and of the delegation/attorney system for the exercise of powers, sanctioning system, recipients and the scope of application of the model, duties and responsibilities of the Supervisory Board, methods of dissemination and providing information, model control and updating procedures and the reference to anti-corruption measures pursuant to Law 190/2012.

The Special Part, approved  by Board of Directors on proposal of Supervisory Board, supplements the General Part and identifies and specifies: 

  • types of crimes provided for by Legislative Decree no. 231/2001;
  • sensitive activities considered more specifically at potential risk of crime;
  • general principles of conduct to be followed by recipients of the Organisation and Management Model in order to prevent the occurrence of the envisaged crimes;
  • specific procedural principles adopted as prevention measures (protocols).

Moreover, the Special Part is strictly related to the individual components of the Organisation and Management Model periodically updated by the Company.

The following elements constitute the SEA Organisation and Management Model: 

  • risk mapping
  • Code of Conduct;
  • corporate organisational system;
  • corporate procedural system;
  • powers of authorisation and signature;
  • management control system;
  • reward system and sanction system;
  • communication and staff training;
  • corporate information system;
  • corporate governance system;
  • other control activities.

Target audience of the Organisation and Management Model

The target audience of the Model is all those who work for attainment of the Corporate purpose and objectives, and therefore members of the Boards (of Directors and Statutory Auditors) and employees of SEA, as well as external entities having relations with the Company (consultants, customers, suppliers). 
Each recipient is required to be aware of the Model, actively contribute to its implementation, as well as report to the Supervisory Board and any shortcomings.  


To submit reports relating to the Organization and Management Model pursuant to Legislative Decree No. 231/2001, choose one of the following options:

Online report submission

Click here to access the reporting channel.

By letter

Supervisory Board pursuant to Legislative Decree No. 231/01
SEA – Società per Azioni Esercizi Aeroportuali
20090 Segrate Milano - Aeroporto Milano Linate
c/o Auditing Department - confidential