CISA S.p.A. is committed to promoting and consolidating a culture of transparency, integrity, lawfulness and control, in line with the values and principles supported by Allegion plc.
Allegion is proud to protect people and businesses worldwide and, to effectively pursue its mission, pays particular attention to protecting its brand, its reputation and its people. The Ethics and Compliance Program is designed to reinforce our commitment not only within our organization but also with our commercial partners and relevant communities.
In alignment with Allegion’s guidelines and behavioral directives, CISA established governance tools aimed to ensure the operation of the organization while safeguarding transparency in management decisions, crime prevention, efficiency and effectiveness of internal controls, discipline of potential conflicts of interest and principles of conduct for managing intra-group relations. These tools are set out and described in various documents that together constitute the Compliance System (Articles of Association, Group Code of Conduct, Behavioral Guidelines, Business Partner Code of Conduct, Organizational Charts, Policies and Procedures, Systems of delegations and powers of attorney, etc.).
Model 231
To ensure effective prevention of the violations referred to in Legislative Decree no. 231 of 8 June 2001 (Discipline on the administrative liability of legal persons, companies and associations, including those without legal personality), CISA has adopted an Organization, Management and Control Model (Model 231) pursuant to Article 8. The addressees of Model 231 include all those who represent, administer, or manage the Company (corporate bodies, i.e., members of the Board of Directors and the Board of Statutory Auditors). The Model also applies to all employees/managers of the Company, who are required to comply with the provisions and controls contained therein with the utmost correctness and diligence, as well as with the related implementation procedures. The Model also applies, within the limits of the existing relationship, to those who, although not belonging to the Company, operate on mandate or on behalf of the Company or are otherwise linked to the Company by relevant legal relationships and maintain commercial relations with CISA (consultants and business partners, i.e., distributors, agents, suppliers, intermediaries, contractors, etc.).
CISA’s Model 231 is made available on the company website (Modello 231) and is considered both a mandatory reference in matters of ethics and compliance for all those who collaborate with CISA and an integral part of the contracts entered into by the Company.
Whistleblowing
CISA S.p.A. has implemented a reporting management system (whistleblowing), including anonymous reporting, applicable in Italy and abroad and consistent with the provisions of applicable law and Allegion plc policies.
Pursuant to Directive (EU) 2019/1937 and its transposition laws (in Italy, Legislative Decree no. 24 of 10 March 2023), to the Organization, Management and Control Model under Legislative Decree 231/2001, and to internal guidelines, a System made up of various channels (as described below) has been adopted and made available to manage reports, including anonymous ones, received from subjects covered by the regulations. Through the application of the System, receipt, management, analysis and processing of reports received, including anonymous reports, are ensured, along with a response to the reporter within the timeframes and according to the procedures set out in Allegion’s Whistleblowing Policy and related addenda.
Regardless of the channel used, the System ensures the management of reports submitted by employees, former employees, job applicants, business partners, customers, suppliers, consultants, collaborators, shareholders and, more generally, all stakeholders, including persons with administrative, management, control, supervisory or representative functions.
Reports must concern conduct that violates the Code of Ethics, laws, regulations, internal rules, provisions of the Authorities, or Model 231, and must be sufficiently detailed — i.e., contain enough information to allow verification of the reported facts (for example: elements enabling identification of the persons involved, the context, the place and the time period of the reported facts, and supporting documentation).
The System is not available for commercial complaints or for disputes and requests related to personal interests.
The highest degree of confidentiality is guaranteed with respect to the subjects and facts reported, as well as the identity of the reporting persons, so that those who make a report are not subjected to any form of retaliation.
Reports can be submitted by one of the following means:
Employees may also communicate facts or concerns (including anonymously) to Allegion’s Chief Compliance Officer by e‑mail at EthicsandCompliance@allegion.com, or by letter to: Chief Compliance Officer Allegion plc 11819 N. Pennsylvania Street Carmel, Indiana 46032 United States of America
Without prejudice to the preferential use of the reporting channels made available by CISA, in the cases strictly indicated in Article 6 of Legislative Decree no. 24/2023, it is also possible to submit reports to the national competent authority (ANAC).
Personal information and data provided in the context of reports are processed to manage and follow up on the reports themselves, to investigate any alleged conduct and to take necessary measures in accordance with applicable laws, including data protection legislation. For more information on the methods and purposes of personal data processing — including data contained in reports and collected during the procedure — please consult the privacy notices on data processing pursuant to the European Regulation on Data Protection (GDPR).