Model 231

Model 231

Butterfly Trasport is equipped with Organizational Model 231.
Legislative Decree 231/2001 identifies the Organizational and Management Model 231, correctly drawn up, adopted and updated, as the preferred tool for exempting a company from its administrative liability resulting from crime.
An Organizational and Management Model pursuant to Legislative Decree 231/2001 is a set of protocols, which regulate and define the company structure and the management of its sensitive processes. The 231 Organizational Model, if correctly applied, reduces the risk of committing criminal offences.
The typical protocols of a 231 Organizational Model are:

  • the Code of Ethics;
  • the disciplinary system;
  • The SB – Supervisory Body;
  • The set of specific procedures for areas sensitive to the risk of crime.


In order for an Organizational Model to be developed, adopted and updated effectively, an organization must:

  • Carry out risk assessment to identify, analyse, measure and treat the risk of committing crimes in the various areas of company activity (both consolidated and developing ones);
  • Implement specific procedures capable of managing risk, preventing the implementation of illicit conduct in areas where the risk of crime is higher. These topics are covered above all in the Special Part of the 231 Organizational Model.
  • Define the management structure for the prevention of crimes, i.e. the ethical principles, resources (human, economic, training, information), responsibilities and information flows, which allow the application and updating of prevention procedures and the detection, over time, the emergence of new risk areas. These issues are developed above all in the Code of Ethics and in the General Part of the 231 Organizational Model.


Crime Risk Management, implemented through the 231 Organizational Model, is a preventative activity: it identifies those company areas in which managers and/or employees could choose to act in the interest or to the advantage of the company, harming, to at the same time, a series of widespread and legally relevant interests (e.g. the health of workers, the interests and assets of the Public Administration, the privacy of employees or third parties, the environment, human rights, etc.).
The risk does not depend, therefore, on the actual desire to commit crimes, but on the possible conflict that could arise between the economic interests of the company and the other interests that can be damaged by the commission of the crimes provided for by Legislative Decree 231/2001.
The Organizational Model, therefore, will try to prevent this conflict, through suitable controls and careful management of the system of delegations and powers.