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

Code of Conduct & Organization Model

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 4 March 2019, 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 to reflect the Companies’ new organisational realities and several regulatory modifications made to Italian Legislative Decree no. 231/2001.


Reporting of potential violations
In accordance with the Whistleblowing Regulation (Italian Law no. 197/2017, which amended art. 6 of Italian Legislative Decree 231/01), the Wind Tre Group companies have updated the process for receiving and managing reports of behaviour and/or conduct that may constitute a violation (even only potential) of the Code of Conduct, the company’s procedures and rules, and any laws and regulations currently in force.

Regardless of the manner in which the report is submitted (from among the available reporting channels indicated below), 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 (e.g. Business Partners, Suppliers, Customers, collaborators, and other general Stakeholders), 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:
- Reporting - Whistleblowing web platform available by clicking HERE - Helpline: 800 828 457 (toll free from landlines and mobile phones) The “Reporting – Whistleblowing” Web Platform and the Helpline are managed by an external and independent company (Convercent), which is able to guarantee the confidentiality of the reporting party’s identity (as required by art. 2 paragraph 3 of Italian Law no. 197/2017) using computerised methods. -E-mail of Wind Tre Group Compliance Officer: segnalazioniwhistleblowing@windtre.it

Wind Tre Group encourages anyone, whether employees or third parties (e.g. Business Partners, Suppliers, Customers, collaborators, and other general Stakeholders), 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:
- Reporting - Whistleblowing web platform available by clicking HERE
- Helpline: 800 828 457 (toll free from landlines and mobile phones)

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 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 Retail/3Lettronica
Organismo di Vigilanza 231/01 c/o Direzione Audit, Compliance & Risk Management
Largo Metropolitana 5 - 20017 Milano

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

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Privacy Policy
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Wind Tre Code of Conduct
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Wind Tre Italia S.p.A Organizational Model
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Wind Tre S.p.A Organizational Model
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Wind Retail S.r.l. Organizational Model
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3lettronica S.p.A Organizational Model
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Privacy Policy
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Wind Tre Code of Conduct
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Wind Tre Italia S.p.A Organizational Model
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Wind Tre S.p.A Organizational Model
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Wind Retail S.r.l. Organizational Model
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3lettronica S.p.A Organizational Model