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Whistleblowing

03/15/2016 - 11:00 AM

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The term "whistleblowing" means any information regarding suspicious conduct not compliant with what is established in the Code of Ethics and of Conduct of the Telecom Italia Group, the Policy for Respect of Human Rights and in the 231 Organizational Model adopted by the Group, the internal procedures and the external rules and regulations however applicable to the Group, as well as allegations and complaints received by the Boards of Statutory Auditors of the national companies of the Telecom Italia Group for topics for which they are responsible.

The "Whistleblowing Procedure", which applies to all unlisted national companies of the Telecom Italia Group and to the two subsidiaries established under San Marino law, Telecom Italia San Marino S.p.A. and Telefonia Mobile Sammarinese S.p.A. and which forms a reference for the listed national companies and for the foreign ones, regulates the process of receiving, analysing and handling the allegations sent or transmitted by anyone, even in anonymous form.

The  Head of Internal  Audit Department is responsible for handling the Whistleblowing allegations.

Telecom Italia makes available to anyone (employees, associates, consultants, labour providers and Third Parties, also in business relations with Telecom Italia Group) the Whistleblowing Channel, to send or share, with the maximum guarantee of confidentiality, allegations related mainly to:

  • requests for clarification on correctness of behaviours, own or another’s, in order to fully comply with the Code of Ethics and of Conduct and with the Values also mentioned in the Policy for Respect of Human Rights;
  • communications of alleged breaches, requests or incentives to breach Laws or Regulations, requirements of the Code of Ethics or internal procedures, with reference to the activities or services of Group interest;
  • alleged violations of the 231 Organizational Model;
  • communications coming from Third Parties regarding alleged matters, irregularities and reprehensible actions;
  • allegations on accounting, internal accounting control or auditing matters submitted from anyone or concerns submitted by employees of the Company and the Group, regarding questionable accounting or auditing matters of the direct and sole responsibility of the Board of Statutory Auditors of Telecom Italia (acting also as the Audit Committee).

The Whistleblowing Channel, in order to guarantee total anonymity, does not gather information on the whistleblower or on the method of access (e.g. server, IP address, mac address) and assigns a unique ID code to each allegation entered, which allows the whistleblower to check its processing status in total anonymity.