Compliance
Compliance
Organization, Management and Control Model ex Dlgs 231/2001
Business ethics is a crucial piece in the internal control and risk management system that could compromise the responsible performance of the business. Therefore, LT S.r.l. has adopted the Terna Group Code of Ethics, which identifies and defines the values, principles and rules promoted by the Group companies, which represent an indispensable prerequisite for the correct carrying out of strategic choices and all their activities, with the The aim is to preserve its value and integrity over time.
With resolution of the Board of Directors dated February 24, 2022, LT S.r.l. has also adopted its own organisation, management and control Model (the "231 Model") to guarantee the correctness and transparency of its activities. to guarantee the correctness and transparency of its activities. In this way the Company, in addition to implementing the Legislative Decree of 8 June 2001 n. 231 (the "Decree 231") on the administrative responsibility of entities, protects the corporate reputation and responds to the expectations of stakeholders, in line with all the companies of the Terna Group. The version published here was updated on December 13, 2023.
The Company has also appointed a Supervisory Body ("SB") with autonomous powers of initiative and control, with the task of supervising the functioning and observance of Model 231 and ensuring its updating (pursuant to art. 6 of the Decree 231), as well as adopted the Terna Group's Anti-Corruption Guideline in order to prevent public and private corruption, both in Italy and abroad.
The Company's SB, in monocratic composition, is made up of an external professional:
Lawyer Iole Anna Savini
Model 231 is a dynamic and shared document. Dynamic, because it is sensitive to any regulatory and organizational change. Shared, because its implementation involves the entire company population, both in the phase prior to development, through periodic risk assessment, and in the implementation phase, with training and information. Furthermore, this Model 231 is subjected to continuous monitoring to evaluate its effectiveness and guarantee its updating with respect to internal changes (business or relating to an organizational structure) and external changes (jurisprudence, legislative developments, best practices).
Whistleblowing
In compliance with the provisions of the Legislative Decree. 24/2023 (“Whistleblowing Decree”), the Company has activated the appropriate internal reporting channels, aimed at allowing the people specifically identified by the art. 3, paragraph 3, of the Whistleblowing Decree, the reporting of violations of which they become aware in a public or private working context.
With reference to the provisions relating to the subject of the reports referred to in art. 2, paragraph 1, letter. q) number 3) and art. 3, paragraph 2, letter. b), in particular, behaviors, acts or omissions capable of harming the public interest or the integrity of the public administration or private entity indicated by Legislative Decree no. are the subject of reporting for the Company. 24/2023, art. 2, paragraph 1, letter. a) n. 2, 3, 4, 5 and 6, as well as conduct aimed at concealing violations inherent, among other things, illicit conduct relevant pursuant to Legislative Decree no. 231/2001 or violations of Model 231 (not falling within the previous categories of violations of the national and European provisions indicated in the Whistleblowing Decree).
Reports relating to significant offenses pursuant to Legislative Decree no. 231/2001 or the Company's Model 231 can only be reported through the internal channels activated by the Company in accordance with the provisions of the art. 3, paragraph 2, letter. b) of Legislative Decree no. 24/2023.
Within the IT portal, available at the following link https://whistleblowing.terna.it/Segnalazioni/InvioSegnalazione, there is the internal IT channel shared with the other companies of the Terna Group in accordance with the provisions of the art. 4, paragraph 4, of the Whistleblowing Decree.
Further information is available at https://www.terna.it/it/Governance/etica-impresa/whistleblowing