Due diligence on the human rights of the TIM Group

[G4-DMA-Reporting due diligence on Human Rights-a] As of 2012, TIM has been involved in the Company Coaching and Capacity Assessment on Business and Human Rights, organised by the Global Compact Network Germany, as part of which the OCAI¹ (Organisational Capacity Assessment Instrument) for Human Rights due diligence in companies was also illustrated (expressly required by the “Guiding Principles”). The OCAI is a self-assessment questionnaire that reflects the content of the “UN Guiding Principles on Business and Human Rights”, consisting of twenty-two questions concerning the main elements of corporate responsibility for Human Rights². In completing the OCAI questionnaire, for each question, the company or department must assess its own position – current and potential – on a spectrum of six levels that range from “non-responsive” to “Human Rights promoter”³.

The goals of the due diligence include:

• the identification and mapping of Human Rights risks resulting from the Company’s operations 4;
• confirmation that each topic is governed by a specific internal regulatory framework (e.g., policy, procedure), has a management system that regularly monitors and traces the performances (if possible through appropriate indicators, such as those concerning health and safety), and that the relative responsibilities have been assigned;
• the definition of a gradual improvement path which, starting with simple respect for the local laws, guides the policies and processes of Human Rights towards sharing with the appropriate stakeholders through appropriate involvement initiatives;
• the highlighting of any gaps or inconsistencies between the company’s various departments and/or between the different companies of the Group;
• the possibility to discuss Human Rights with the other companies.

[G4-HR9]  TIM carried out the first internal due diligence on Human Rights from autumn 2012 to spring 2014, on the basis of the “Guiding Principles”, the use of the OCAI questionnaire, and the involvement of the Group’s two biggest entities in terms of workforce (the percentage of employees covered was 98%) and investments: BU Domestic (excluding Olivetti and TIM Sparkle) and the Brazil BU.

The entire due diligence process has been studied and coordinated by the CSV Department, which invited the Departments and companies of the Group to fill in the self-assessment questionnaire⁵. CSV department examined the questionnaires that had been filled in and conducted the related feedback with the Italian departmentsin order to further examine the contributions provided and define the action plans for the level two and three self- assessments (respectively 3.1% and 8.6% of all the responses⁶.

In fact, if the self-assessment process reveals a potential risk situation with reference to Human Rights, the Department concerned is required to communicate the corresponding action plan to CSV which monitor the progress achieved in the work.

In Italy, at the end of the feedback, the following emerged:

• on a scale of one to six, the average score of all the answers was 4.4;
• the need to prepare the TIM Group’s Human Rights policy (around 2/3 of the insufficient self-assessments regarded this aspect);
• the usefulness of organising internal Human Rights training courses.

The feedback meetings planned in Brazil were postponed until 2017 in view of the preparation and dissemination of the online Human Rights Information and raining course, which is expected to improve knowledge on the subject, with a positive effect on the results of the due diligence itself.

[G4-HR10] [G4-HR11] Even the results of the audit on Human Rights carried out on the Suppliers of the Group are reported in the Sustainability Report and in the Sustainability section on the Group’s website.

¹ Created by Twentyfifty Ltd with funding from the Global Compact Germany Foundation.

² Four questions concern the Human Rights policy that may be in place, four concern the assessment of the actual and potential impacts on Human Rights (deriving from company activities and relations), eleven concern the integration of respect for Human Rights in the company processes and departments, two questions concern tracing the company’s response to the negative impacts it has caused or contributed to cause and the related communication, and finally the reporting mechanism.

³ The two lowest levels identify a reactive approach to Human Rights (“non-responsive” and “reactive” respectively), the third is an active approach (“efficient management”), the three higher levels represent a proactive approach to Human Rights (rising from “proactive experimentation” to “strategic integration” and finally “Human Rights promoter”). The tool does not operate as a compliance expert.

⁴ TIM’s activities include supply chain. Among the groups deemed vulnerable, in addition to children, elderly and disabled people and local communities, TIM has identified indigenous people and the work done by migrants.

⁵ TIM has not considered the question relating to “conflict-affected areas” as the Group does not operate in any such areas

⁶ No level one response was supplied during the first round.