Wind Tre - code-of-conduct-and-om

NEW REGISTERED OFFICE: from 17 June 2024 the registered office of the Wind Tre Group companies is in Milan, in Via Monte Rosa, 91 – 20149 Wind Tre is dedicated to ensuring that its business activities are carried out with integrity, and in a fair and professional manner, while at the same time maintaining high ethical standards and respecting the local and international regulations. In this regard, the Code of Conduct constitutes the main tool for implementing Wind Tre Group’s business ethics, and is used to strengthen its credibility and reputation as an economic entity in the country in which it operates.
The document is also important for everyone who works at Wind Tre Group, as it establishes the behavioural guidelines to be followed on a day-to-day basis while carrying out their work activities.
Within this context, the Organisational and Management Model (“Model 231”) has been drawn up in accordance with the provisions of Italian Legislative Decree No. 231 of 2001, which introduced the concept of administrative corporate liability for certain offences committed by employees, in the interests or to the advantage of the company itself, to the Italian legal system.
With a resolution dated 23 March 2023, the Boards of Directors of the Wind Tre Group Companies (Wind Tre Italia S.P.A. and its subsidiaries: Wind Tre S.p.A, Wind Retail S.r.l, and 3Lettronica S.p.A) , adopted their new Model 231 documents, which have been updated with reference to the recent regulatory modifications made to Italian Legislative Decree no. 231/2001.

Reporting of potential violations
The Wind Tre Group Companies (Wind Tre Italia S.p.A, Wind Tre S.p.A, 3Lettronica S.p.A and Wind Tre Retail Srl) have established a process for handling whistleblower reports (the Whistleblowing process) in accordance with the regulatory provisions enshrined in Legislative Decree no. 24/2023 regarding the protection of individuals who report violations of European Union law and national legislation.

In particular, Wind Tre Group has prepared 2 Whistleblowing Policies:
- The Whistleblowing Policy for the Wind Tre Companies, to be understood as Wind Tre Italia S.p.A, Wind Tre S.p.A, and 3Lettronica S.p.A;
- The Whistleblowing Policy of Wind Tre Retail Srl

Wind Tre Group promotes a corporate culture of fighting crime through the active and responsible participation of all of its employees and, more generally, all third parties that work with the Group.

What can be reported?
- violations, even potential ones, relating to the types of offences falling within the scope of Legislative Decree no. 24/2023, including but not limited to offences pursuant to Legislative Decree 231/01 and violations of Organizational Models; offences affecting areas protected by the EU (such as prevention of money laundering, product safety and compliance, etc.), violations of antitrust regulations, etc.
- other violations relating to other types of crimes not falling within the scope of Legislative Decree no. 24/2023, for which the provisions of the Decree itself do not apply, such as: violations of the SA8000 Standard, violations of other regulations, such as violation of the rules protecting the insurance industry (IVASS Regulations), violations of the Code of Conduct and other internal policies and procedures, cases of corporate fraud, etc.

Regardless of the manner in which the report is submitted, Wind Tre Group will guarantee the confidentiality and (if requested) anonymity of the reporting party, and will handle all the information relating to the case with the utmost confidentiality, and in accordance with the current laws.

Wind Tre Group will not tolerate retaliation, threats, or acts of discrimination against anyone who submits a report in good faith.

Wind Tre Group encourages anyone, whether employees or third parties, to report any potentially illegal behaviour (as specified above) in good faith, and without fear of retaliation, even anonymously, using one or more of the following reporting channels:

- For the W3 Companies (Wind Tre Italia S.p.A, Wind Tre S.p.A, 3Lettronica S.p.A):
1) the online platform accessible via this link
2) e-mail, at the address: segnalazioniwhistleblowing@windtre.it
3) verbal reports can be made to the Director of the Audit, 231 Compliance & Risk Management Department

- For Wind Tre Retail:
1) the online platform accessible via this link
2) e-mail, at the address: segnalazioniwhistleblowingwindtreretail@windtre.it
3) verbal reports can be made to the dedicated Figure specifically appointed by Wind Tre Retail to manage whistleblower Reports pursuant to Legislative Decree no. 24/2023. To set up a meeting with the dedicated Figure, write to the following e-mail address: segnalazioniwhistleblowingwindtreretail@windtre.it.

It should be noted that the above channels do not handle customer complaints, such as complaints concerning service quality, prices, etc.

Wind Tre Group encourages anyone, whether employees or third parties, to report any potentially illegal behaviour (as specified above) in good faith, and without fear of retaliation, even anonymously, using one or more of the following reporting channels:

- For the W3 Companies (Wind Tre Italia S.p.A, Wind Tre S.p.A, 3Lettronica S.p.A):
1) the online platform accessible via this link
2) e-mail, at the address: segnalazioniwhistleblowing@windtre.it
3) verbal reports can be made to the Director of the Audit, 231 Compliance & Risk Management Department

- For Wind Tre Retail:
1) the online platform accessible via this link
2) e-mail, at the address: segnalazioniwhistleblowingwindtreretail@windtre.it
3) verbal reports can be made to the dedicated Figure specifically appointed by Wind Tre Retail to manage whistleblower Reports pursuant to Legislative Decree no. 24/2023

It should be noted that the above channels do not handle customer complaints, such as complaints concerning service quality, prices, etc.

Any reports of violations or fraudulent circumvention of the principles and requirements of the Organisation, Management and Control Model pursuant to Italian Legislative Decree no. 231/2001 (“Model 231”) can also be submitted via the Supervisory Bodies’ dedicated channels listed below:
E-mail:
organismodivigilanzaW3@windtre.it (Wind Tre SpA)
organismodivigilanzaWR@windtre.it (Wind Tre Retail Srl)
organismodivigilanzaW3Italia@windtre.it (Wind Tre Italia SpA)
organismodivigilanza3Lettronica@windtre.it (3Lettronica Industriale SpA)

Postal address:
Wind Tre Italia S.p.A/ Wind Tre S.p.A/ Wind Tre Retail/3Lettronica
Organismo di Vigilanza 231/01 c/o Direzione Audit, Compliance 231 & Risk Management
Via Monte Rosa 91 - 20149 Milano

It should be noted that the channels cited above do not handle customer complaints, including complaints regarding service quality, prices, etc.

Company

Press & Events

Sustainability

Governance

Code of Conduct & Organization Model

Company

Press & Events

Sustainability

Governance

code-of-conduct-and-om // <![CDATA[ _spBodyOnLoadFunctionNames.push("setupPageDescriptionCallout"); // ]]>

Code of Conduct & Organization Model

code-of-conduct-and-om