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" (undergoing update), 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.
TIM makes available to anyone (employees, partners, customers, suppliers, consultants, freelance professionals, shareholders and, more generally, any third party who has information concerning the aformentioned conduct) the Whistleblowing Channel (in Italian), 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;
- alleged violations of the 231 Organizational Model - which fall under the direct responsibility of the Board of Statutory Auditors of TIM or of Group Companies (also in their capacity as 231 Supervisory Body), or of individual 231 Supervisory Bodies present in certain Group entities - also as a result of conduct at risk of crime and/or offence provided for by the 231 Organisational Model;
- communications of alleged violations of the Human Rights Policy;
- communications 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 responsibility of the Board of Statutory Auditors of Telecom Italia (acting also as the Audit Committee).
The Whistleblowing Channel guarantees the total anonymity of the whistleblower, as indicated in the procedure, and assigns a unique ID code to each allegation entered, which allows the whistleblower to check its processing status.
It’s also possible to send allegations in paper form at the regisered office of TIM:
- attn Head of Internal Audit Department
- Via Gaetano Negri, 1- 20123 Milano - Italy