TIM 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 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.
The aim is to maintain this level.
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 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.
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.
As reported in TIM anticorruption policy, political contributions are not allowed. So, for TIM, political contributions and lobbying expenditures have always been equal to 0 (zero).
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.
One of the strengths of the Group’s Compliance Programme is training: TIM 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 the case of Italian companies, 231 Organisational Model and the anti-corruption policy are communicated to all employees while commercial partners are required to confirm their adherence to the principles contained therein. Note also that the on-boarding training provided to new recruits at TIM S.p.A. included specific anti-corruption sessions.
In 2016, 1,208 employees completed a digital learning model on the handling of inside information at workstations (Market Abuse). The training campaigns are not necessarily annual but dependent on the changes made to the Model or other organisational requirements.
In 2017, the course on the Anti-Corruption and Whistleblowing Policy was delivered, which involved employees of the parent company and main subsidiaries (the last, as at 8 January 2018, had been completed in TIM S.p.A, by 33,335 resources, making for approximately 73% of the target: if we consider the main subsidiaries as well, the number of employees who completed the course is 34,421 resources, equal to approximately 73% of the target), as shown by the tables below:
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In Brazil, communication on anti-corruption matters, with employees and partners, was launched in 2014 and new classroom and online training activities were delivered starting in 2015 (aimed at the departmental focal points, the people who manage relations with public bodies and legal advisors). The last online course on the Anti-Corruption Compliance Program (Organisational Model), provided in 2016, was completed by 94% of employees according to the data recorded in December2017.
TIM is a member of the "231 e Legalità" workgroup, an initiative organised by Confindustria.
In 2015, TIM 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).
The following initiatives are being developed in this area:
- production of a handbook with Confindustria for the small and medium Italian companies, with effective and ready to use suggestions in order to manage the risk of illegal activities, especially of corruptive type;
- preparation of a questionnaire to be given to 100 SMEs to assess the entrepreneurs’ awareness of the risk of corruption crimes and the dissemination of 231 Models
- definition of an online training course focused on legality and anticorruption, an educational initiative for schools Alternating Training projects during school year 2017/2018.
TIM 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 companie
Since 2016 TIM has been participating to the Business Integrity Forum promoted by Transparency Italia for the development in the private sector of activities concerning cultural projects and the spreading of initiatives supporting Integrity Transparency and Anticorruption. In December 2017, the Compliance Department participated in the “Italian Business Integrity Day” promoted by the Anti-Corruption Coordination Department of the Ministry of Foreign Affairs at the OCSE offices in Paris as part of the working group on bribery.