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Star7 S.P.A. discloses robust processes for sustainability oversight and conflict-of-interest management, noting that “The Consiglio di Amministrazione of STAR7 approves the Bilancio di sostenibilità” and that “all activities of the STAR7 Group must always avoid situations where the involved parties may find themselves in a conflict of interest.” It also describes its compliance framework under the “Modello di organizzazione gestione e controllo ex D. Lgs.231/2001” with an appointed Organismo di Vigilanza overseeing the Model. However, we found no evidence of any governance processes, defined oversight, or monitoring mechanisms specific to direct or indirect lobbying activities or policy engagement, and the company does not disclose any individual, committee, or policy dedicated to governing its lobbying efforts.
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