SUSTAINABILITY
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Codes, Charters and Values

Telecom Italia Media has set up an Internal Control System comprised of procedures, layouts and checks aimed at ensuring ethically impeccable behavior towards all stakeholders.

 

  • CODE OF ETHICS

The Code of Ethics summarizes the principles and values to be complied with by all corporate bodies, management, employees, outside consultants and third parties engaging in business dealings with the Company, and constitutes the basis of the Organizational Model and the Group's structured Internal Control System.

 

  • ORGANIZATIONAL MODEL 231

As part of its overall Internal Control System, the Group has implemented an Organizational Model Pursuant to Legislative Decree No. 231 of June 8 aimed at preventing certain offenses, such as bribery, solicitation of bribery and corporate offenses.

The OM 231, introduced in 2003, has been revised, internally and externally, to incorporate all of the Control Schemes associated with "231 offenses", which have been added to the Model over time, up to the most recent version, 6.4.8, adopted in 2010.

In support of the adoption of the Organizational Model, in accordance with the methods applied by Telecom Italia, the Group provides all of its employees with training modules, activities and projects on 231 issues according to the following scheme:

1. targeted training, aimed specifically at updating and honing skills pertinent to the Model possessed by persons in positions at the company with the greatest involvement in terms of both the responsibilities set out in the Organizational Model 231 and from the standpoint of direct dealings with government entities; and

2. general training aimed at very broad segments of the company population, typically without distinction.

 

  • INVESTOR-PROTECTION LAW (262/05 — Provisions on the protection of investors and the regulation of financial markets)

The primary goal of the certification process is to achieve compliance with Law No. 262/05 (the "Investment Act") and, for all Telecom Italia Group companies, US SOX legislation (Sarbanes-Oxley Act of 2002). Achieving the objectives laid down in Law 262/05 and SOX allows the Group to guarantee the reliability of company information, both internally (in relation to management) and externally (in relation to investors). At the same time, the need to comply with the dictates of the new legislation in question represented an opportunity to achieve improvement of the internal control system. In detail, the following benefits have been obtained in recent years: training and development of personnel, improved efficiency of administrative processes, elimination of useless/redundant activities and greater efficiency of accounting and governance procedures.

 

  • CORPORATE GOVERNANCE CODE OF LISTED COMPANIES

The previous Preda Code has been replaced by the Corporate Governance Code, which focuses on the "institutional and governance" structure of Group companies. It regulates the composition of the Board of Directors and committees and the adoption of oversight measures.

 

  • AGCOM

The Company's Intranet site features a link to the AGCOM website so as to allow for immediate, easy consultation of all sector-specific regulations and resolutions. For an update on AGCOM's activities that have an impact on the Company, refer to the Telecom Italia Media Group's Report on Operations, specifically the section concerning the Regulatory Framework.

 

  • ADVERTISING SELF-DISCIPLINARY AGREEMENT

The Advertising Self-Regulatory Code by the Advertising Self-regulatory Institute (IAP) was first issued in 1966 and is now in its 51st edition (effective as of January 10, 2011). The Code is aimed to enforcing the principle that while commercial communications play a particularly useful role in the economic process, it must meet certain public service requirements, especially in light of its influence on consumers. The Code defines the activities that fail to meet the aforesaid requirements, albeit without conflicting with the applicable laws, and lays down the rules and regulations with which all forms of advertising must comply, as far as customs and communications activities are concerned. The Agreement is binding for users, agencies, advertising and marketing consultants, managers of advertising vehicles of all kinds and all those who have accepted it directly or through an association. Telecom Italia Media is a party to the Agreement through the association FRT.

 

  • SELF-REGULATORY AGREEMENT ON MINORS AND THE MEDIA

The website www.la7.it presents the general principles of the Self-Regulatory Agreement on Minors and the Media, along with rules of conduct, application criteria and enforcement methods. The Code, signed by TI Media along with the major public and private broadcasting companies in 2002 in the form of a private agreement, was ratified into statute by system law 112/04, in turn incorporated into the Consolidated Act, Legislative Decree No. 177/05, as amended by Legislative Decree No. 44/10. The enactment of these statutes has made the Agreement binding for all broadcasters, regardless of whether they are parties thereto or the type of platform employed (analog, satellite, digital terrestrial, IPTV). Implementation of the Agreement has been entrusted to a committee of 15 standing members, representing, in equal measure, the television broadcasters that are parties to the Agreement, institutions and users (the latter by indication of the National Council of Users within the Communication Supervisory Authority).

 

  • SELF-REGULATORY CODE ON SPORTS AND THE MEDIA

The Code on Sports and the Media, aimed at the self-regulation of information regarding sports, was signed on July 2007 by the major public and private broadcasting companies and all broadcasters' associations, the Journalists' Association, the Italian Press Federation, Italian Athletic Press Union and the Italian Newspaper Publishers' Federation. The parties to the Code undertake to spread the positive values of sport, condemn violence relating to athletic events, especially football, in the public opinion and not to transmit messages that may incite or legitimize acts of violence.

 

  • VOLUNTARY SELF-REGULATION OF REPORTING ON ONGOING LEGAL PROCEEDINGS IN THE BROADCAST MEDIA

In accordance with the provisions of the Self-Regulatory Code governing reporting on ongoing legal proceedings in the broadcast media, signed on May 21, 2009 by Telecom Italia Media and the representatives of RAI, Mediaset, the associations of local broadcasters FRT and Aeranti Corallo, the National Press Federation and the National Order of Journalists, a committee was formed on December 17, 2009 to investigate possible violations of the Code and implement any corrective measures.

The Code's objective is to temper the right to information concerning legal proceedings with the respect for inviolable personal rights through the observance of the principles of objectivity, thoroughness and impartiality.

 

  • SELF-REGULATION PRINCIPLES AND PROCEDURES FOR PRODUCT PLACEMENT

In November 2010, pursuant to Art. 40-bis, paragraph 5, of Legislative Decree No. 177/05, Telecom Italia Media S.p.A. and MTV Italia S.r.l., along with their respective advertising agencies, Cairo Communication S.p.A. and MTV Pubblicità S.r.l., adopted documents that lay out the general principles and methods of implementation to be observed by the companies and their respective agencies when placing products in programming produced or commissioned by the above companies in accordance with the cited legislation.

 

  • PRIVACY

The website www.La7.it also features the full text of the Privacy Policy regulating the disclosure of operating procedures through which Telecom Italia Media protects the privacy of customers/users who consult the website www.La7.it, owned and operated directly by Telecom Italia Media. The site also links to a list of the company's privacy managers as required under current regulations.

 

  • PROTECTION OF PERSONAL DATA

As required under rule 26 of Annex B (Technical Regulations on Minimum Security Measures) to the Code governing the Protection of Personal Data (Legislative Decree No. 196/2010), Telecom Italia Media S.p.A. has prepared its Document on Security (DPS) for 2009. This document describes the technical and organizational measures adopted for the protection of the common, sensitive and legal personal data subjected to computerized processing. The document also makes provision for a training program aimed at familiarizing employees involved in data processing, with the security measures devised to protect against identified risks.

Last update: 22/09/2011, 16:30