Safeguarding legality and preventing corruption

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For 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 the conduct of the Company’s business are based.

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

Risk Management: in 2001 Terna adopted a 231 Organizational Model (a model pursuant to Legislative Decree 231/01), a set of continually updated guidelines, procedures, training commitments, and control mechanisms which forms an integrated system for the prevention of specific risks, including crimes of corruption. In February 2013, with the involvement of all the affected companies and departments of the Group, an update of the model was begun to take into account the changes introduced by the “anti-corruption” Law, No. 190/2012.

During the 2010-2012 period, the Audit Unit examined all the corporate departments (100%) and the Company’s subsidiaries several times with regard to various kinds of risks, including those concerning corruption, and produced audit and risk-assessment reports for corporate processes and departments at risk.

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

  • preventing and dealing with crimes, carried out by:
    • systematically analysing the pre-conditions characteristic of incidents of fraud, identifying the critical areas in which the phenomena can be facilitated and possible causes in the organizational and operating aspects of processes;
    • defining specific monitoring and control procedures to mitigate risks;
    • continually monitoring the effectiveness of the prevention measures adopted;
  • checking and assessing new subjects and counterparties with the aim of containing the risks deriving from transactions with third parties;
  • ex ante validation of requests for awarding consultancy services, professional appointments, IT services and procedures for awarding contracts to predetermined suppliers;

in accordance with the Protocols of Understanding signed with them, sending data, information, and news on contractors and subcontractors to the institutions responsible, in order to prevent criminal infiltration of construction work on the National Transmission Grid infrastructure.

Personnel training: Terna continually runs training courses on the Code of Ethics and the 231 Organizational Model. The objective of these courses is to ensure awareness and dissemination of the rules of behaviour and the procedures established for the prevention of crimes at all the corporate levels, and to inform and train the personnel regarding the areas at risk for crimes and the potential crimes with regard to the activities performed.

During 2012, the courses on the 231 Model, after the training campaign which during the 2009-2011 three-year period involved 21% of the corporate population and 27% of the senior executives, involved only a small number of colleagues. In fact, the training campaign is currently being revised to take into account the regulatory updates, adjustments to the model and organizational changes which have occurred.

In 2012, 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, 2012, no litigation regarding corruption was pending.