Code of Conduct &
Organization Model

The tools that define the reliability of the company as an economic entity operating in Italy

The Code of Conduct is an essential element of the Corporate Governance and it is the tool with which Wind Tre Group aim to reinforce its credibility and reputation as an economic entity in the national community in which it works. The document is extremely important for Wind Tre’s employees since it provides the guidelines for the behaviors to adopt in everyday business activities. It is therefore the main tool for the implementation of the company ethics.
In this context, we find the Model of Organization and Management ex Legislative Decree no. 231 of 2001, which introduced the administrative liability of the company in the Italian law as to specific violations committed by employees, in the interest and to the advantage of the companies.

Reporting of potential violations
Wind Tre has implemented a system for reporting and management of conducts that may represent a breach (also potential) of the company Code of Conduct, the procedures and policies and rules, and/or the applicable laws and regulations, even suspected.
All Wind Tre stakeholders (employees, customers, suppliers and partners) can raise their concerns of the above situations or potential breach, through the following channels:
Phone: contact the Wind Tre “Helpline” Speak Up at + 800 1777 9999 (international toll free number, only from fixed line).
The Helpline is totally managed by a third party, and the service is available 24 hours a day, 7 days a week.

Furthermore, the reporting of violations of the principles and provisions of the Organization, Management and Control Model pursuant to Legislative Decree n. 231 of 2001 (“231 Model”) may also be sent through the following channels:
postal address:
          Wind Tre S.p.A. Organismo di Vigilanza 231/01
          Compliance Department          
          Via Cesare Giulio Viola 48
          00148 – Roma
Wind Tre is committed to protect the confidentiality of whistleblower identity, without prejudice to legal obligations, and it does not tolerate any form of retaliation against anyone who reports in good faith.
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Wind Tre Code of Conduct

Wind Tre S.p.A. Organizational Model