Compliance
Compliance
Business ethics are a crucial element in the internal control and risk management system that could compromise the responsible performance of the business. Therefore, LT S.r.l. 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 execution of strategic choices and all their activities, with the aim of preserving its value and integrity over time.
By resolution of the Board of Directors of February 24, 2022, LT S.r.l. it has also adopted its own organisation, management and control model (the "231 Model") to guarantee the correctness and transparency of its activities. to ensure 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 liability of entities, protects corporate reputation and responds to stakeholder expectations, in line with all Terna Group companies. The version published here was updated on February 28, 2023.
The Company has also appointed a Supervisory Body ("SB") with independent powers of initiative and control, with the task of supervising the functioning and observance of Model 231 and updating it (pursuant to Article 6 of the Decree 231), as well as adopted the Anti-Corruption Guidelines of the Terna Group in order to prevent public and private corruption, both in Italy and abroad.
The Company's OdV, in monocratic composition, is made up of an external professional:
Lawyer Anna Iole Savini
Any violation or suspected violation of Model 231 and/or any other aspect pertaining to its implementation can be reported to the SB at the following addresses:
Supervisory Body pursuant to Legislative Decree 231/01 of LT S.r.l. c/o TERNA S.p.A. – Presidio Model 231 - Viale Egidio Galbani, 70 - 00156 - Rome
Model 231 is a dynamic and shared document. Dynamic, because sensitive to any regulatory and organizational change. Shared, because its creation involves the entire company population, both in the phase preceding its elaboration, through periodic risk assessment, and in the implementation phase, with training and information. Furthermore, this Model 231 is subject to continuous monitoring to assess its effectiveness and ensure that it is updated with respect to internal (business or pertaining to an organizational structure) and external (jurisprudence, legislative evolutions, best practices) changes.
In compliance with the provisions of the Law of 30 November 2017, n. 179, LT S.r.l. uses a whistleblowing IT portal, implemented within the Terna Group and in line with Group policy, as a channel for receiving reports also from external parties. Therefore, anyone can report violations, even potential ones, of the principles contained, inter alia, in the Code of Ethics, in the 231 Model and in the Anti-Corruption Guidelines, via the following link: https://whistleblowing.terna.it/