[G4-DMA Human Rights Grievance Mechanisms] The Group’s Code of Ethics and Conduct requires employees, collaborators, consultants, as well as third parties who have business relations with the Group and all the stakeholders affected by the Human Rights Policy - in respect of activities and services of interest to the Group - to promptly inform the Head of the TIM Audit Department, either directly or via their line manager, of any violations or collusion to violate:
- legal or regulatory requirements,
- provisions of the Code of Ethics,
- policy and internal procedure,
- and any irregularities and/or negligence.
The handling of reports, including those for which the Head of the Audit Department is responsible (known as “whistleblowing”), is a requirement of the Sarbanes-Oxley Act and of the “UN Guiding Principles on Business and Human Rights”.
The Internal Control reporting procedure (see the TIM Group chapter, The Corporate Governance system paragraph) requires the Head of the Audit Department, who answers directly to the Board of Directors, independently of the senior executives:
- to ensure that reports are received, logged and analysed;
- based on the results of the preliminary analysis, to launch a structured audit activity (if required);
- to communicate the results of the analyses to the relevant departments so that they may take the appropriate corrective actions (if required). The non-compliance is only closed once the Audit Department has verified the effectiveness of the corrective actions implemented by the relevant departments;
- to ensure the traceability and retention of the documentation regarding the reports received and their analysis;
- to update the reporting procedure and disseminate it in agreement with the Human Resources & Organisational Development department.
The procedure is available both on the company intranet and at www.telecomitalia. comwebsite. Employees were made aware of this in a letter from the CEO and a news item published on the company intranet.
During 2016, a total of 219 reports were received in Italy and 518 in Brazil. In the case of Italy, of the 219 reports, 73 were anonymous and 146 non-anonymous, classified as follows:
- 110 in the context of the whistleblowing procedure;
- 89 not covered by the procedure and sent to the relevant departments for the respective checks, informing the Audit Department of the result, including:
- 50 customer complaints (poor service);
- 39 other;
- 20 “irrelevant” ones in terms of the purpose of the procedure.
In the case of Brazil, of the 518 reports, 220 were anonymous and 298 non-anonymous, classified as follows:
- 264 of a “business” nature (processes that could be improved, etc.);
- 10 of a “personal” nature (employees in difficult situations, etc.);
- 214 customer complaints (poor service);
- 30 “irrelevant” ones in terms of the purpose of the procedure.
[G4-HR12] The Human Rights-related reports received through the main tool provided by the Company for all stakeholders to report any kind of regulatory irregularity or breach of the Code of Ethics, the Human Rights Policy and the “UN Guiding Principles” i.e. the whistleblowing procedure are given below. Note that the concept of Human Right used to complete the tables is the same as the one used for the due diligence described above. The tables therefore only show the complaints not included in the specif ic paragraphs (e.g., TIM people, requests for information sent to the Agency by the Data Protection Authority, suppliers’ employees).
Reports received and handled in Italy regarding Human Rights
|Total number of reports regarding Human Rights received through the main reporting mechanisms||0||0||4||2||7||3|
|Handled during the reporting period||0||0||4||2||7||3|
|Resolved during the reporting period||0||0||4||2||7||3|
|Total number of reports received prior to the survey period which were resolved during the reference period||0||0||0||0||1||1|
Reports received and handled in Brazil regarding Human Rights
|Total number of reports regarding Human Rights received through the main reporting mechanisms||8||4||0||0||5||2|
|Handled during the reporting period||8||4||0||0||5||2|
|Resolved during the reporting period||8||4||0||0||4||2|
|Total number of reports received prior to the survey period which were resolved during the reference period||0||0||1||0||0||0|
[G4-HR3],[G4-HR8] Over the past 3 years, 2 cases have been reported in the Group, 1 of which was investigated and resolved, relating to discrimination or violations of the rights of indigenous people1.
1 [G4-DMA Indigenous Rights] The only geographical area with indigenous people in which TIM operates is Brazil. However, telecommunications activities do not have negative impacts on these people. Finally, during 2016, one case
was investigated and resolved regarding ethnic discrimination.