Telecom Italia 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 result in administrative responsibility for the Company, if they are committed in interest of or for the benefit of the same.
The 231 Organisational Model is made of:
The internal control plans have been compiled 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 Organisational 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. On 5th March 2013 the Board of Directors adopted a new version of the 231 Organisational Model which was updated with the insertion of the new crimes of private corruption and undue induction to promise or give benefit to a public official. The new version contains the updating of Internal Control Guidelines and the reference to the anticorruption Policy of the Group. The version was previously approved by the Board of Directors of Telecom Italy on January 17, 2013.
The version is also consistent with the compliance program requirements relating to international anticorruption laws, FCPA and UK Bribery Act.
The 231 Organisational 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 changes to 231 Organisational 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.
A dedicated department - Compliance 231 - of Telecom Italia Compliance Function supports the Supervisory Boards of the companies of the Group, handling reports of violations of the Model and providing specific interventions of compliance, including analysis on the information reports of the companies.