The adoption of the Organisation, Management and Control Model pursuant to Legislative Decree 231/2001, together with the Code of Ethics, represents a natural and consistent step forward for Aton, in line with the path we have taken in recent years. Just like our decision to become a Benefit Company or to achieve certifications such as Gender Equality, ISO 27001, and B Corp, these initiatives are not simply a “badge”, but a true expression of our identity: building an innovative, resilient and responsible company, committed to creating value both for people and for the wider environment in which we operate.
We believe innovation is like a train in motion: a continuous, dynamic force that guides every strategic and organisational decision we make. For us, to innovate means to evolve, anticipate and experiment. But it also means doing so responsibly.
We are convinced that innovation cannot exist without ethics. That’s why we combine our drive towards the “new” with responsible, transparent and compliant behaviours—structured and certified through recognised frameworks.
Operating responsibly is an integral part of how we do business and how we build trust with customers, partners, institutions and our people – the atonpeople.
The 231 Model and the Code of Ethics give tangible shape to this vision: they define principles, roles, responsibilities and expected behaviours, strengthening a corporate culture based on fairness, integrity and respect for people—making innovation not only ambitious, but also solid and sustainable.
This journey has involved all functions through the analysis of business processes, the mapping of sensitive activities, the definition of control protocols, and the introduction of monitoring and reporting systems in line with best governance practices.
During the assessment phase, it became clear that many of the operating practices developed over time—thanks to a continuous improvement approach—were already aligned with the principles underpinning the Model. Attention to accountability, segregation of duties, traceability of decisions, and open dialogue across functions have long been part of how we work.
This process has allowed us to take a further step: making explicit, structured and shared what until now has largely lived within our culture and day-to-day practices.
A key element of assurance, for both us and our stakeholders, is the appointment of the Supervisory Body (Organismo di Vigilanza) – an independent body responsible for overseeing the effective implementation and continuous update of the 231 Model. Through ongoing control, monitoring and dialogue with the organisation, the Supervisory Body promotes continuous improvement of the safeguards in place, helping to strengthen a culture of responsibility and risk prevention.
The Code of Ethics lies at the heart of the 231 Model and encapsulates the values that guide Aton: legality, transparency, respect, responsibility and sustainability.
It applies to everyone who works with and for Aton – atonpeople, suppliers, partners and customers – and defines the framework for everyday behaviour, as well as internal and external relationships.
It is a living, evolving tool, designed to guide decisions even in the most complex situations, where choices are not straightforward and require a balance between innovation, effectiveness and responsibility. In this way, ethics becomes a daily reference point, embedded in our corporate culture, enabling us to act consistently and responsibly towards people, customers, partners and the wider community.
The adoption of the 231 Model and the Code of Ethics marks an important milestone—but not a final one.
It is the beginning of a journey that requires constant attention, training, listening and continuous updating, evolving alongside Aton and its governance tools.
This path strengthens our identity and helps us create long-term, sustainable value – protecting the company, its people, and all the stakeholders we work with.
Looking ahead, Aton reaffirms a clear belief: operating responsibly is a key enabler of business resilience and long-term growth.
Applying ethical principles and compliant behaviours strengthens the company’s credibility – especially in the international markets we are focusing on – and its ability to navigate complex and constantly evolving environments.
At Aton, legality and ethics are not formalities, but structural elements of how we operate: they guide daily decisions, protect people, and help build authentic, lasting relationships.
