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231 Organizational 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. 

Following the entry into force of the Decree, TIM promptly adopted 231 Organisation Model to prevent criminal and administrative offences that can potentially be committed in the course of its business activities. The 231 Organisation Model is a dynamic system, that has impact on the business operation of the company and requires continuous monitoring and updating to take into account feedbacks in its application, as well as developments in the relevant regulatory framework.

The Supervisory Board has the task to ensure that the 231 Organisation Model is updated by submitting to the Board of Directors amendments and integrations needed to adapt to changes in law and in the organization or to outcomes of the actual implementation of the 231 Organisation Model. In carrying out such activities, the Supervisory Board avails itself of the 231 Steering Committee, a collective body composed of top managers. The 231 Steering Committee is coordinated by the Compliance Department and in performing its tasks is supported by all interested departments.

The current version (v. 7.0) of the 231 Organisation Model of TIM s.p.a. has been adopted on April 1, 2020, by resolution of the Board of Directors of the company. The new version, that is a significant improvement over the previous releases aligned with best practices and sector guidelines, has the objective to strengthen the internal risk management and control system, a matter in which the company has always been engaged.  

The 231 Organisation Model is structured according to a ‘cross compliance’ approach that takes into account the specific standard of control developed by the company, specifically: the Anti-corruption Management System, Internal Control System for Financial Reporting, Tax Control Framework, Safety Management System and Environmental Management System.

Below is a brief description of the major innovations.

  • New design of MO 231 and subdivision into:
    • General Section, describing the characteristics of the Organisation Model; 
    • Special Section, describing Sensitive Processes/Activities, associated 231 offences and control measures; 
    • Annexes: Code of Ethics and Conduct; Offences/Processes/Function/Procedures Correlation Matrix, Technical-regulatory annex. 
  • Role of the Supervisory Board assigned to a collective body (totally 4 members) composed by external and internal members. Composition of the current Supervisory Board: Giuseppe Pignatone (Chairman), Carlo Piergallini, Anna Doro (member of the Board of Statutory Auditors) and Gianfranco Cariola (director of Internal Audit).
  • Reduction and rationalization of Sensitive Processes (15) and identification, with respect to each process, of:
    • Sensitive Activities, that are potentially exposed to the risk of commission of 231 offences;
    • definition of control standards and rules of conduct; 
    • definition of specific correlation matrix: i) sensitive activity/category of offence; ii) sensitive activity/specific control standard.
  • Review of information flows through definition of qualitative/quantitative KRI/red flag. List and modality to send information flows/red flag are established in specific Guidelines.

With reference to the Special Section of the 231 Organisation Model, the standards of control to prevent 231 offences associated with Sensitive Processes/Activities are defined based on the following three general principles:

  • formal separation of duties for the different phases of the process; 
  • tracing of each phases of the process, i.e. their continuous visibility (for example, through supporting documentation) in order to help to trace back responsibilities and grounds for decisions;
  • objectiveness of decision-making processes to ensure that decisions are taken disregarding merely subjective evalutations but on the basis of objective criteria.

TIM 231 Organisation Model represents the reference standard for definition of the distinct 231 Organisation Models to be adopted by the companies of TIM Group.