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.
Identifying, preventing and controlling any risk of corruption
TIM has adopted and developed an Anti-Bribery Management System (also ‘AMS’) in accordance with UNI ISO 37001 and in line with the provisions of the applicable regulations on the prevention of corruption, the 231 Organisational Model and the principles expressed in the Code of Ethics and Conduct. In 2019, TIM was ISO 37001 certified by an accredited body for this type of scheme.
The reference documents for the AMS are the 'Anti-Corruption Management System of TIM' and the 'Anti-Corruption Policy of the TIM Group'.
In particular, the AMS document supports the company in preventing, detecting and responding to corruption-related events, in compliance with the relevant anti-corruption laws and other voluntary commitments applicable to its business activities, and is an integral part of the broader internal control system the company has adopted. The AMS is also the guide used to establish, implement, maintain, review and improve the AMS itself, identifying purpose and scope, roles and responsibilities, reference procedures, risk assessment methodologies, training/communications, reporting and internal auditing in particular. In addition, the AMS identifies operations, projects, activities, relationships and personnel with a more than low corruption risk, for which it provides specific prevention measures.
The Group Anti-Corruption Policy, the most updated version of which is dated 14th February 2022, is the systematic management framework in which the standards and rules of conduct to be adopted in order to prevent corruption within the Group are defined.
The TIM Group has, indeed, always been committed to fighting corruption, in the belief that business must be conducted legally and ethically.
In view of this objective, TIM and the Group’s main subsidiaries have adopted the UNI ISO 37001 "Anti-bribery Management Systems" standard.
According to the Anti-corruption Policy adopted by the Group, it is forbidden to commit an act of corruption, an incitement to act of corruption or in any other way prodromal to the achievement of corruptive agreements.
For example, 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. unofficial payments of modest value, made in order to expedite, favour or ensure routine activities of the Public Officer or Private Subject that has a relationship with the Group.
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;
- purchasing of goods and services;
- consultancy, intermediation, relationships with Business Partners;
- joint-ventures, acquisitions and disposal of assets;
- selection, hiring and management of personnel.
One of the strengths of the Group’s Compliance Programme is training: TIM regularly provides adequate and appropriate training to corporate bodies and employees, not only with reference to the application of the 231 Organisational Model, but also on anti-corruption issues. Specific anti-corruption training is provided as part of the on-boarding training for TIM S.p.A. new recruits. In addition, every two to three months, the Compliance Department sends all the organisation’s top executives and management a review with the main regulatory and case-law news, including on anti-corruption and corporate liability issues. Targeted training campaigns take place on a cyclical basis and are also provided when internal regulatory instruments, such as the 231 Organisational Model, are updated.
The Anti-Corruption Management System document, the Anti-Corruption Policy, the 231 Organisational Model and the Code of Ethics and Conduct are communicated to employees through special communications initiatives and are published on the Intranet portal. The 231 Organisational Model (General Part), the Code of Ethics and Conduct and the Anti-Corruption Policy are communicated to other recipients through publication on the website, while third parties in business relationships with Group companies are required to contractually undertake to comply with the principles set out in these documents.
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, as an advanced member, 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.