The safeguard of legality and the prevention of corruption

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At Terna, the prevention of corruption is a strategic activity which meshes with the internal control systems. Legality and honesty are two of the general principles on which the Code of Ethics and conducting the Company’s activities are based.

Terna’s strategy in this regard focuses on three major areas:

Risk management: since 2001 Terna has adopted the 231 Organizational Model, an updated set of guidelines, procedures, training commitments, and control mechanisms which forms an integrated system for the prevention of specific risks, including the crimes of corruption.

SO2During the 2009-2011 period, the Audit Department examined all the corporate departments (100%) and the Company’s subsidiaries several times with regard to the different kinds of risks, including those concerning corruption, and produced audit and risk-assessment reports for at risk corporate processes and departments.

Monitoring: the Security Department’s Fraud Management Unit performs tasks regarding:

  • the prevention and management of crimes, carried out through:
    • the systematic analysis of the preconditions characteristic of incidents of fraud, identifying the critical areas in which the phenomena can be favored and possible causes in organizational and operating aspects of processes;
    • defining specific monitoring and control procedures for reducing risks;
    • constant monitoring of the effectiveness of prevention systems adopted;
  • checking and assessing new parties and counterparties with the aim of limiting the risks stemming from transactions with third parties;
  • preliminary validation of the requests for assigning consulting, professional assignments, IT services and assignment procedures to pre-determined contractors;
  • in compliance with the Memorandums of Understanding signed with them, sending to the Public Authorities in charge data, information, and details on contractors and subcontractors in order to prevent criminal infiltration of construction work on the infrastructures of the National Transmission Grid (NTG).

SO3Personnel training: Terna constantly organizes training courses on the Code of Ethics and 231 Model. The objective of HR3these courses is to ensure, at all the corporate levels, awareness and the dissemination of the rules of behavior and the procedures established for the prevention of crimes and to inform and train personnel regarding the areas at risk of crimes and the potential crimes with regard to the activities performed. In 2009, awareness regarding the Code of Ethics was also increased through a dissemination campaign addressed to the first reporting lines and, using the waterfall method, all employees during the establishment of an Ethics Committee aimed at facilitating internal discussion of ethical issues.

In March 2011, the Security Department published and distributed to all employees a manual entitled “Legislative Decree no. 231 of June 8, 2001 - Organizational model and procedure management” to further support information and training activities regarding the subject.

The following table shows the data on the employees who attended the courses on 231 Model in the 2009-2011 three-year period.

COURSES ON 231 MODEL
Indicator 2011 2010 2009
Participants in the course      
Number of participants 97 1,073 1,053
- senior executives 12 26 12
- other categories 85 1,047 1,041
Coverage %
     
Out of total 2.8 30.9 30.6
- senior executives 20.0 44.1 18.5
- other categories 2.5 30.7 30.8

Following the 2009/2010 campaign, during 2011 training on the 231 Model regarded only specific updating requirements. During the year, a working group was formed for defining a new online course and classroom activities.

SO4In 2011, as in the three previous years:

  • there were no cases of litigation regarding corruption;
  • there were no disciplinary penalties for incidents of corruption;
  • there were no ascertained reports of violation of the Code of Ethics with regard to corruption.

As of December 31, 2011 no litigation regarding corruption was pending.