DATA4'S MISSION\nDATA4 creates Smart & Scalable digital facilities for our customers. Our network of highly connected, resilient and sustainable data center campuses underpins our customers’ digital growth in Europe.\nDATA4 Group finances, designs, constructs and operates its own data centers. Delivered through our data center campus model, we provide our customers with secure, scalable and high-performance data hosting solutions.\n\nDATA4 VALUES\nAt DATA4 we are driven by our values. These are the core of everything we do – from the proactivity we show in delivering great outcomes for our clients, to the responsibility we show as a key contributor to the digital economy. Our three values are:\nTo be entrepreneurial – we are teams of doers who make things happen - with autonomy, energy and a sense of responsibility\nTo always take responsibility – for our impact on the people we work with, the society we are part of, and the environment in which we operate\nTo constantly be adaptable – our business is designed to adapt, answering not only today’s challenges, but also anticipating what’s coming next.\n\n\n\nABOUT THE ROLE\nBased in our Italian office in Cornaredo (Milan), the Senior Legal Counsel Compliance acts as the local compliance lead and the primary bridge between the Italian subsidiaries (existing and future) and Group Headquarters. You will ensure that the Group’s global ethics strategy is seamlessly integrated with the complex Italian regulatory requirements. You will be responsible for the \"living\" nature of the 231 Model and for fostering an impeccable culture of integrity across all local operations.\n\n\n\nRESPONSIBILITIES\nItalian Compliance Leadership (Decree 231/01)\nModel 231 Governance: Lead the implementation, maintenance, and periodic updating of the Modello di Organizzazione, Gestione e Controllo (Model 231) to prevent corporate criminal liability.\nOrganismo di Vigilanza (OdV): Act as the primary legal support for the Italian Supervisory Body, ensuring all reporting obligations and flows of information are meticulously managed.\nLocal Risk Mapping: Conduct granular risk assessments focused on \"reati presupposto\" (predicate offenses), specifically tailored to the Italian business landscape, update of the local risk maps in light of ABC Program principles.\nEnsure all new Italian companies are compliant with the applicable legislation.\n\n\nIntegrated Risk Management (81/08 & 24/23)\nHealth & Safety (Decree 81/08): Monitor the compliance of the Health & Safety framework as a core component of the 231 Model to prevent unintentional offenses related to workplace safety.\nWhistleblowing (Decree 24/23): Ensure the Italian reporting channels are legally compliant with local specificities (Decree 24/2023), coordinating with the Group to ensure the protection of whistleblowers and adherence to local investigation protocols.\nRegular update of the ABC Program policies (whistleblowing policy etc.) in compliance with local legislation.\nDevelopment: ensure full local compliance of development activities with the ABC Program.\nPatronage and Sponsorship: management of the local requests, audit on NAVEX.\nProcurement: support to internal customers in the context of tenders and the implementation of the procurement policies.\nDOA: ensure compliance of the existing DOA with the applicable local legislation, collaboration with the corporate legal counsel to update the local DOA.\n\n\nContractual Compliance & ABC Review on CLM Juro (Local & Group)\nABC Clauses: Review and negotiate Anti-Bribery and Corruption (ABC) clauses in all local and cross-border commercial contracts to safeguard the Group.\nGDPR Clauses: Review and negotiate GDPR clauses in all local and cross-border commercial contracts to safeguard the Group.\nContractual Audits: Ensure that all Italian vendors and partners sign off on the Group’s Compliance Annexes and Code of Ethics.\nThird-Party Due Diligence & NAVEX\nNAVEX Expert: Serve as the local \"Power User\" for NAVEX tools (RiskRate) to automate third-party screening and policy management.\nKYC/KYS Oversight: Perform due diligence on Italian partners, analyzing screening results (Sanctions, PEPs) and providing risk-based recommendations.\nTraining, monitoring, audits & reporting\nTraining: Ensure a “compliance culture” at local level.\nInternal Audits: Execute regular compliance audits of Italian operations to ensure adherence to Group BP5 procedures.\nReporting: Prepare monthly or quarterly compliance status reports for the Compliance Legal Manager, Group Legal Director and the Italian Board of Directors.\nData Privacy & GDPR (Local & Group)\nDPA Liaison: Act as the main point of contact for the Italian Garante per la protezione dei dati personali and support the Group Data Protection point of contact/DPO in French CNIL matters or other applicable EU data protection authorities involved.\nPrivacy Operations: Ensure all local processing activities, marketing initiatives, and HR data flows are compliant with GDPR and the Italian Codic