231 Organization Model

TIM adopts “231 Organisational Model” pursuant to Legislative Decree 231/2001. The “231 Organisational Model” is a compliance program to prevent crimes ex Legislative Decree 231/2001 that could involve the criminal liability for the Entity, if there are offences committed with the interest or for the benefit of the Company.

The 231 Organizational Model is composed by:

  • Code of Conduct and Ethics of the Telecom Italia Group, which shows the general principles (transparency, fairness, loyalty) that guide the Company in the organization and conduct of its business;
  • “General principles of internal control” tools to provide a guarantee with regard to the objectives of efficiency and operational effectiveness, reliability of financial and management information, compliance with laws and regulations, safeguarding of assets against possible fraud;
  • “Principles of conduct”, which consist of specific rules for relations with third parties and for all fulfillments and activities of a corporate nature;
  • “Internal control Guidelines” that describe at-risk crime business processes, any crimes committed in relation to them, the preventive control activities aimed at avoiding the related risks.

The internal control plans have been formed in accordance with the following primary principles of control systems: (i) the  segregation of duties in undertaking the main activities involved in business processes; (ii) the traceability of decisions, to allow for identification of specific points of responsibility and the motivations for the decisions themselves; and (iii) the  objectification of the decision-making processes, so that decisions are not to be purely subjective considerations, but based on pre-established criteria.

The 231 Organizational Model is a dynamic instrument, which affects the corporate operation, which is constantly checked and updated in the light of feedback and evolution of the regulatory framework.

In July 2018, a revised version of the 231 Organizational Model has been adopted, incorporating additional 231 crimes of racism and xenophobia and new provisions on whistleblowing, that required adjustments to disciplinary system and Principles of Conduct. Like the previous ones, the new version is also consistent with the compliance program requirements relating to international anticorruption laws, FCPA and UK Bribery Act.

The 231 Organizational Model includes a Supervisory Board that verifies the deployment and the respect of the Model and it provides for the updating. Under the provisions of Legislative Decree 231/2001 – art. 6 c.4bis, Supervisory Board functions have been attributed to the Statutory Auditors.

The Supervisory Board reports to the Board of Directors on the examination activities which it has performed and the corresponding outcomes.

Changes to 231 Organizational Model are developed by the Steering Committee 231, ordered by the Supervisory Board and approved by the Board of Directors, in case of significant issues.

TIM Compliance Department supports Supervisory Boards of the companies of TIM Group in their activities, providing specific interventions of compliance, including analysis on the information reports of the companies.

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