Travel Security: Special Section of MOG 231

The special section of MOG 231 on travel security has been introduced to manage international assignments.

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Travel security special section: to whom it is addressed

The Travel Security Special Section is addressed to all those Companies operating across national borders that have adopted the Organizational and Management Model (MOG) pursuant to Legislative Decree 231/2001.
Although MOG 231 governs corporate practices, business travels abroad are rarely duly covered.

what is it?

organizational and management model 231

What is the aim of the travel security special section?

The Special Section on Travel Security aims at identifying practices that a Company must integrate in its corporate procedures to prevent any risk related to posting workers abroad and to protect its employees during international assignments.

The Travel Security Special Section aims at integrating Model 231 with a preliminary framework followed by a special analysis of work activities carried out abroad.

This analysis enables the Company to define risk factors to which an employee may be exposed, considering the territory where an assignment is supposed to be carried out.

why implement it?

guiding health & safety officers and HR

Why integrate it in MOG 231?

The Special Section on Travel Security provides guidelines for management figures, particularly for Health & Safety Officers and HR managers, allowing them to define policies that would comply with the Italian legislation as regards safety and security of workers posted abroad.

The Company is obliged to ensure safety both for its employees and contractors (i.e., Freelance Professionals, Business Contractors), whether sending them abroad as independent external contractors or on the company’s behalf.

what includes

practices and procedures to follow before, during and after the assignment

What does the Special Section provide for?

1. Documents Storage

to keep track of secondments abroad

2. Risk Assessment

only government and supranational resources

3. Implementing Procedures

to protect itinerary and place of stay

1. Storage of Travel Security Documentation

to keep track of all business trips

The Travel Security Special Sections imply the creation of an archive accessible to designated staff members (i.e., employees and HR) that allows keeping formal track of employees’ business travels or relocations.

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Role-based sets of permissions may be granted to employees to access the archive, i.e., read-only or write access modes.

The Archive allows for

  • Data and documentation tracking
  • Proof of Company's procedures to prevent risks before and during the trip
  • Storage and availability of data entered in compliance with Statute of limitations

2. Risk Assessment

based on official government sources

Before assigning employees a mission outside their permanent place of work in Italy, Companies must assess the Risk level thoroughly, by paying attention to specific areas in the Country of destination, taking into account the anticipated itinerary of the employee.

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classifying destinations according to level of risk

  • Government Resources and Supranational Bodies (i.e. EU, UN, WHO)
  • Designated scale with 4 levels of risk
  • Objective classification of areas risk level

3. Applying Procedures

according to the level of risk of itinerary and stay

Based on the level of risk attributed to the itinerary and/or place of stay abroad, the Company, in collaboration with Safety Managers, undertakes to follow the established procedures. The procedure may differ depending on the level of risk identified.

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The Travel Security Special Section allows managers to act consistently, by being guided exclusively by objective factors. Actions determined by subjective decisions and potential inaccurate assessments are thus avoided.

The Company shall:

  • Monitor risk levels throughout the trip
  • Adjust protection levels according to levels of risk
  • Monitor the travel until workers return home

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7. Is the company part of a corporate group?*
8. Is there an updated organizational chart?*
9. Is there any updated function-gram?*
10. Are there any internal written procedures?*
11. Is there an integrated risk management system?*
12. Is there a Quality business function?*
13. Is the corporate function Legal Department available?*
14. Has the company adopted the risk management system (ISO 31030 :2021)?*
15. Has the company adopted the risk management system (ISO 31000 :2018)?*
16. Has the company adopted the occupational safety and health management system (ISO 45001:2018)?*
17. Has the company adopted additional certified management systems?*
18. Does the company have a formalized organizational system of derogations/proxies for occupational health and safety?*
19. Has the company taken care of privacy compliance?*
20. Does the company employ or transfer, even for short periods, workers abroad?*
21. Has the company adopted its own Travel Risk Policy?*
22. If adopted, does the Travel Risk Policy define the levels of risk the company is willing to accept?*
23. In the fulfillment of Duty of Care, is there a preparatory structure in place to organize travel with the necessary expertise to identify and assess risks and define related mitigation measures?*
24. In defining the risk factors referable to the individual travel situation, including those of a health nature, is the timely involvement of the RSPP and the competent Doctor ensured?*
25. Has the company planned appropriate procedures and tools to ensure that the workers, in advance and during travel, receives adequate training and correct information on the risks to which they may be exposed and, therefore, on the lifestyles to be assumed in the specific travel situation?*
26. Does the company have a constantly updated knowledge framework regarding Visas and vaccines prescribed for the purpose of the worker's lawful entry into the foreign Country?*
27. Does the company, for the entire duration of the assignment abroad, provide a personnel tracking and monitoring system?*
28. Does the company, in compliance with Article 2 of Decree-Law No. 317/1987 as amended by Article 18 of Decree-Law No. 151/2015, also provide in the employment contract for the stipulation of a special insurance policy for each outward journey to the place of destination and return, for cases of death or permanent disability?*
29. Does the company have a Team to handle emergency situations promptly?*
30. Does the company, upon completion of the trip, undertake to implement the review of the prevention and protection procedures adopted and the verification of their degree of effectiveness?*
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