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Telecom Italia’s anti-corruption commitment

Telecom Italia has always been committed to fighting corruption, which is widely recognised in Italy as the main obstacle of economic and social growth and the wellbeing of citizens.

The Telecom Italia Group implements its activities in full compliance with anti-corruption measures and with the ethical principles inspired by the values of transparency, correctness and loyalty.

To date, no incident of corruption has been found in the Group’s companies and no legal proceedings have been started, over the last three years, against any of the Group’s companies as a result of corruption.

Identifying, preventing and controlling any risk of corruption

Organisational Model 231, pursuant to ex Legislative Decree no. 231/01, and the Group’s Anti-corruption Policy are the tools used to identify, prevent and control any risk of corruption.

The Telecom Italia Group’s Organisational Model 231, which includes the Group’s Code of Ethics and Conduct, the “General Principles of Internal Control”, the “Principles of Conduct regarding relations with third parties” and the “Procedures of Internal Control” are checked and updated from time to time according to relevant legislative developments.

Moreover, the Organisational Model 231 is an integral part of the Compliance Programme for the application of anti-corruption regulations such as the FCPA  (Foreign Corrupt Practices Act) and the UK Bribery Act.

Anti-corruption Policy

According to the Anti-corruption Policy adopted by the Group, it is forbidden to directly or indirectly demand or offer a public or private entity any type of payment (gifts, financial benefits or freebies) that may be considered to arbitrarily and illegally influence relations between the Group’s companies and a third party.

Furthermore, no “facilitation payments” are permitted, i.e. non-official payments, even small amounts, made for the sole purpose of speeding up, facilitating and ensuring the implementation of an activity, which, however, should be provided for by public or private entities, with which the Group’s companies have business relations.

 The sensitive areas identified for the occurrence of possible corruption practices are:

  • gifts and entertainment expenses
  • events and sponsorships
  • donations /membership fees
  • consultancy, brokerage, relations with business partners and suppliers
  • joint ventures, acquisitions and disposals.

Training

One of the strengths of the Telecom Italia Group’s Compliance Programme is training: Telecom Italia has implemented two training campaigns based on Organisational Model 231 for all its employees. It is an e-learning programme, with classroom training for managerial staff.

In Brazil, Telecom Italia has introduced anti-corruption training activities, focusing on the new anti-corruption law adopted locally. 

Initiatives

Telecom Italia is a member of the "231 e Legalità" workgroup, an initiative organised by Confindustria.
In 2015, Telecom Italia took part in workgroups created  at the Business 20 (B20) for the implementation of the G20/B20 recommendations concerning anti-corruption issues and for the development of an international training toolkit for small and medium enterprises which was presented at the Summit G20 (Antalya, November 2015).

Anticorruption Reporting

Telecom Italia obtained a fourth place in the TRAC (Transparency in Reporting on Anti-Corruption) Telecom Report 2015, for adopting an anti-corruption program. The assessment was carried out on a world basis by the international organisation called Transparency International and it involved 35 telecommunication companies.