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.
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:
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.