231 MODELS AND WHISTLEBLOWING
231 Model and reporting channels
The organisational Model and whistleblowing channels, updated for the new artificial-intelligence offences entering the organisation's catalogue.
The 231 Model is the tool through which an organisation structures itself to prevent the offences that can give rise to its administrative liability, and its effectiveness depends on being tailored to real risks and kept up to date. The catalogue of predicate offences keeps expanding, and it now includes categories tied to the use of artificial intelligence: a Model frozen at the time of its adoption leaves exactly the most exposed areas uncovered. In parallel, whistleblowing rules require compliant reporting channels, with protections for the reporter and traceable handling. I build or update the Model starting from a map of the actual risks, integrate the new relevant offences and set up reporting channels so that they are both compliant and genuinely usable.
WHAT IT INCLUDES
What it includes
Mapping of offence risks
Analysis of the organisation's activities and the relevant predicate offences, as the basis for a Model true to reality.
Drafting or updating the Model
Building the 231 Model or revising the existing one, with a general part and protocols on the identified risks.
New AI-related offences
Integrating the categories tied to artificial intelligence that enter the catalogue of predicate offences.
Whistleblowing channels
Setting up compliant reporting channels, with protections for the reporter and confidential handling of the flows.
Supervisory Body
Support for setting up and running the Supervisory Body, from information flows to periodic checks.
Training and rollout
Sessions for staff and management on the Model's content and the correct use of the reporting channels.
WHO IT IS FOR
Who it is for
The service is aimed at organisations that want to adopt a 231 Model or update one adopted in the past, at those required to set up compliant whistleblowing channels, and at those using AI systems in their processes who must assess the new related offence risks. It is useful both for a first adoption and for a targeted revision of areas that have become critical.