The safeguard of legality

At Ternai, 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 Ethicsi 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 Compliance Program pursuant to Legislative Decree 231/01 (Model 231), a set of always updated guidelines, procedures, training commitments, and control mechanisms which forms an integrated system for the prevention of specific risks, including the crimes of corruption.  
During the 2008-2010, the Audit Department examined all the corporate departments (100%) and the Company’s subsidiaries several times with regard to the different kinds of risks, including those concerning corruption, and produced audit and risk-assessment reports for corporate processes and departments at risk.  

Monitoringi:
The Security Department’s Fraud Management Unit performs tasks regarding:  

  • the prevention and management of crimes, carried out through the systematic analysis of the preconditions characteristic of incidents of fraud, identifying the critical areas in which the phenomena can be favored and possible causes organizational and operating aspects of processes, the elimination of shortcomings in the control system and ensuring that the prevention systems are not deactivated from within or without;  
  • checking and assessing new parties in transactions with the aim of containing the related risks;
  • in accordance with the Protocols of Understanding signed with them, sending to the prefectures and the financial police data, information, and news on contractors and subcontractors in order to prevent criminal infiltration of construction work on the infrastructure of the National Transmissioni Grid.   

Personnel training: Every year Terna organizes training courses on the Code of Ethics and Model 231. The objective of these courses is to ensure, at all the corporate levels, awareness and the dissemination of the rules of behavior and the procedures established for the prevention of crimes and to inform and train the personnel regarding the areas at risk of crimes and the potential crimes with regard to the activities performed, as well as to present the principles of behavior and implementation of Model 231, with specific regard to the areas and activities identified as at risk.

In March 2011, the Security Department published and distributed to all employees a manual entitled “Legislative Decree n. 231 of June 8, 2001 – Organizational model and procedure management” to further support information and training activities regarding the subject.

The following table shows the data on the employees who attended the courses on Model 231 in 2009 and 2010. (In 2008 the courses were not held.)

COURSES ON MODEL 231

Indicator Unites 2010 2009
Participants in the course      
 Number of participants
Number 1,073 1,053
 -senior executives
Number
26 12
 - other categories Number 1,047 1,041
% coverage       
Out of total
% 30.9 30.6
 -senior executives
% 44.1 18.5
 -other categories
% 30.7 30.8

In 2010, as in the three preceding 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, 2010 no legislation regarding corruption was pending.