Prevention of corruption

At Terna, 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 activities are based.

Terna’s strategy covers three major areas::

Risk management: in 2001, Terna adopted the 231 Organisational Model, a set of 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 period 2006-2009, the Audit Department examined 100% of Terna’s departments and those of its subsidiaries with regard to all the corporate risks, including those regarding corruption, and produced risk assessment reports on the corporate activities, positions, and departments at risk of illegality and corruption. A process is now in progress for the new subsidiaries, SunTergrid and TELAT..

Monitoringi: in cooperation with the Audit Department, the Fraud Management Unit of the Security Department coordinates actions to prevent illegal events through the continual monitoring of Terna’s risk factors and its degree of exposure to the risk of crimes, the elaboration of financial analyses of the new parties – customers, suppliers, partners – with which the Company is preparing to have business relations, and assistance to the different corporate departments with the required audits.

Personnel training: every year since 2005, Terna has organised training courses on the Code of Ethics and 231 Organisational Model. The purpose of these courses is to ensure, at all corporate levels, awareness of the rules of conduct and the procedures established for the prevention of crimes and to train and inform employees on the areas at risk of crimes and the potential crimes associated with the activities carried out, as well as to explain the principles of conduct and of implementation of the Model, with specific regard to the areas of risk and the activities identified beforehand.

Courses on the Code of Ethics and 231 Organisational Model (1)

Participants in the course
  senior executives
  other categories
% coverage of total31%57%
% senior executives
% other categories

(1) No courses were held in 2008.

As in the two previous years,in 2009:

  • no cases of litigation regarding corruption ended;
  • there were no disciplinary penalties for incidents of corruption;
  • there were no verified reports of violation of the Code of Ethics regarding corruption.
  • As of December 31, 2009, no litigation was pending regarding corruption..