The 231 model is an essential element in the control infrastructure envisaged under the Italian Legislative Decree 231/2001 (and in the architecture of a company’s internal control and risk management system).

231 model: our innovative approach

A properly structured, implemented and supervised 231 model can avoid liability. It is also an indispensable guide for all employees and business associates.

231 models must be structured in accordance with the Italian Legislative Decree 231/2001 and best practice. They must be implemented effectively, as they bring no benefit to companies if they remain ‘on paper’.

231 model: the advantages of our digital approach

Our innovative approach is based on the digital transformation of your 231 model and the use of smart digital compliance technologies.

Our digital platform for the management of 231 models allows you to create, digitally manage and update your 231 model entirely on your own.

If you subscribe, you will have our cloud-based platform at your full disposal and avoid all the inevitable complexities of an IT project.

The only cost is an annual subscription fee – and you won’t need to break your general 231 budget.

Our digital platform allows you to:

  • create, constantly monitor and update risk assessments
  • conduct gap analyses and come up with action plans
  • create and update protocols for the model’s special part
  • support the drafting and management of reports and information flows between departments
  • support the supervisory body (SB) with drafting and managing reports
  • manage SB meetings, inc. the related minutes and documentation
  • plan and report on SB controls and monitoring
  • provide training courses

The following can be carried out on the platform.

Risk assessment

  • map business processes and identify sensitive activities (risk mapping)
  • engage process owners in evaluating risks (risk assessment)
  • conduct gap analyses and come up with action plans
  • produce customised reports and dashboards, which can be viewed by company, department, process, at-risk activities and offence class


  • manage external regulatory libraries to ensure they are always up to date
  • manage protocols and procedures
  • manage delegated powers and job descriptions


  • create and manage compliance plans
  • manage information flows between departments
  • schedule SB meetings and manage related minutes and documentation
  • support SB controls and monitor the level of employee knowledge and the application and effectiveness of protocols and procedures
  • support drafting annual reports

231 training

  • keep training materials on file
  • make the 231 app available to employees so they can stay informed, access protocols and procedures, do training and testing, ask questions and request support

Optimise the management of your 231 model using a digital platform

If you subscribe to our platform to digitalise your 231 model, you can also benefit from:

  • chat support and AI-supported virtual advisor
  • dedicated web app that gives you realtime access to your company’s 231 model, code of ethics, policies and procedures directly from your smartphone or tablet
  • full potential of Power BI to enable continuous monitoring by the responsible departments and by the SB
  • process owner engagement to conduct risk assessments and employee engagement to conduct 231 training
  • customisable libraries and documents (in shared mode) that allow you to add and modify content
  • training and testing on tablets and smartphones

The digital platform is also a useful tool to help SBs manage administrative tasks, schedule meetings, manage information flows, prepare SB activity plans, and assess the level of achievement of activity plan objectives.

Lastly, our digital platform allows you to: conduct periodic monitoring of your 231 model’s adequacy and effectiveness easily and autonomously, make all necessary variations to reflect developments in your company’s structure, changes in business processes, or the introduction of new predicate offences in the Italian Legislative Decree 231/2001 and carry out risk assessments as often as you like.

Where? Directly from your desk.

Expert advice on creating and updating 231 models

Do you want to prepare or update a 231 model with the support of expert consultants and an innovative digital approach?

Well now you can do it efficiently – and improve your employees’ user experience – with the help of our experts and digital platform.

Our approach is based on the digital transformation of 231 models and the use of smart digital compliance technologies. This makes creating, implementing and managing 231 models easier and more immediate, with significant benefits in terms of efficiency, employee engagement, and time and cost savings.

A team of experts to help you design and implement your 231 model

We help on several fronts:

  • risk assessments, which are necessary to ensure that a company’s 231 model accurately reflects the business, the organisational structure and the related risks
  • design and preparation of 231 models
  • organisation and planning of tasks relating to training and SBs needed to implement 231 models

Each activity involves the use of the following services on our digital platform:

  • risk definition and risk assessment
  • management of 231 libraries, 231 protocols and procedures
  • information flow planning and SB support/management
  • 231 training

Our work ensures that each 231 model is quickly tailored to the typical activities and risks of each business. We help you identify the sensitive activities that are exposed to the risk of predicate offences and the related control mechanisms.

From risk assessment to training on 231 models

Our team of experts is on hand to help you in the following areas:

Risk assessment

  • map organisational structure by company, department, process, control and procedure
  • interview department heads or whoever else is selected to be interviewed
  • map 231 risks by company, department, process and sensitive activity
  • assess risks for sensitive activities in terms of likelihood, impact, effectiveness of controls, residual risk, and gap analysis
  • identify a single risk assessment matrix with different views/structures (by department, process, sensitive activity, company and category of offence)
  • make interactive dashboards available with different views/structures based on risk assessment data

231 models

  • review or prepare the general part of the models based on the organisational structure identified during risk assessment
  • review or prepare the special part of the models based on mapping and risk assessment (the special part’s protocols are structured to incorporate and enhance existing procedures and controls and thereby avoid, to the extent possible, having to introduce new requirements that could complicate the company’s operations)
  • organise the special part by department/process instead of by category of offence if appropriate
  • include an adequate number of protocols that cannot be circumvented even in the event of a blatant violation


  • review or draft the regulations applicable to SBs
  • set reporting standards for the management bodies (BoD and board of statutory auditors)
  • identify departmental reporting systems and information flows to SBs
  • identify planning, monitoring and control procedures
  • create the format for information flows and periodic reports


  • differentiate 231 training procedures based on user type
  • create storyboards for online courses.

Once you have our digital platform up and running, you can also sign up for a subscription that, for a fixed annual fee, allows you to receive support with implementing, managing and monitoring your 231 model. A subscription includes:

  • monthly updates on changes to the Italian Legislative Decree 231/2001, the introduction of new offences, and related caselaw
  • monthly updates, directly through the digital platform, of the list of offences, risk libraries and standard process libraries, with notifications of any updates to risk assessments
  • constant access to our top-class legal help desk through the platform’s chat function, for answers to questions relating to the management and updating of 231 models

We can also provide project-based services at very low costs and with short lead times by exploiting the digital platform. Services include: conducting risk assessments, drafting and reviewing the general and special parts of 231 models, creating templates for powers of attorney, reviewing information flows, drafting and reviewing 231-related contractual clauses, assessing the effectiveness of 231 models, and supporting report management.

The services available on our platform include: