Menu

Reporting complaints and breaches

05/17/2016 - 05:15 PM

- + Text size
Print

Procedures for reporting complaints and breaches

Compliance with the Group's Code of Ethics and Human Rights Policy is required - within the limits of their respective powers, functions and responsibilities - of all corporate bodies, managers and employees of all Group Companies, as well as collaborators and third parties in business relationships with the Group.

I. Whistleblowing

Pursuant to article 4 of the Code of Ethics and Conduct of the Telecom Italia Group, the requirements of the US Sarbanes Oxley Act (sections 301-302-806) and the Principles of Conduct of the Organisational Model 231 applicable to the Telecom Italia Group Companies, as of November 2015 a Whistleblowing Procedure has been in force across Telecom Italia, all the TI Group's national unlisted companies and subsidiaries registered in San Marino (Telecom Italia San Marino SpA and Telefonia Mobile Sammarinese SpA), and constitutes a benchmark for national and foreign listed companies.

The procedure establishes a process to guarantee the receipt, analysis and processing of whistleblowing reports regarding suspicious conduct that is not consistent with the provisions of the Code of Ethics and Conduct of the Telecom Italia Group, the Group's Human Rights Policy, the Organisational Model 231 adopted by the Group, the internal procedures and external regulations applicable to the Group, as well as reports and complaints received by the Boards of Statutory Auditors of Telecom Italia Group companies on matters relevant to them.

The procedure, which is available on the company Intranet and at www.telecomitalia.com, provides for the centralised handling, by the Audit Department, of all whistleblowing reports, using a computer app (the “Whistleblowing Portal”), which the Telecom Italia Group provides to anyone (employees, associates, consultants and third parties, including any in business relationships with the Telecom Italia Group), to submit, with a maximum guarantee of confidentiality, whistleblowing reports regarding the following in particular: 

  • requests for clarifications regarding the appropriateness of one's own or other people's conduct in order to ensure full compliance with the Code of Ethics and Conduct and with the values stated in the Human Rights Policy;
  • communications regarding alleged violations, requests or inducements to violate legal provisions or regulations, provisions of the Code and internal procedures with regard to the activities and services of interest to the Group;
  • communications regarding alleged violations of Organisational Model 231;
  • reports from third parties regarding alleged anomalies, irregularities and reprehensible actions;
  • statements regarding accounting issues, internal accounting controls or auditing, whoever they may be from, as well as reports of queries, submitted by employees of the Company and the Group, regarding accounting or auditing matters deemed to be questionable, which come within the exclusive competence of the Board of Statutory Auditors of Telecom Italia (including as Audit Committee).

All whistleblowing reports undergo rigorous analysis by the Audit Department, in full compliance with the principles established by the International Standards for the Professional Practice of Internal Auditing issued by the Institute of Internal Auditors (IIA), and the Code of Ethics and Conduct of the Telecom Italia Group.

II. Measures taken

As for Telecom Italia's own staff, the most significant disciplinary sanctions related to infringements of the Code of Ethics during 2015 amounted to 18 actions. The cases involved were the following:

  • Private use of materials, equipment, corporate services
  • Forgery or alteration of documents or equipment to gain unfair advantages
  • Undue acceptance of money from customers or request for monetary contributions to the customers

As for relations with suppliers subject to 231 self-certification (a certification stating compliance with Telecom Italia's Code of Ethics as well as with other requirements)

  • 55 haven't provided any certification, yet
  • 4 are not compliant with 231 requirements