Environmental & Social Information • Mar 30, 2023
Environmental & Social Information
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Consolidated non-financial statement 2022 pursuant to Legislative Decree 254/2016
The digital sector is the engine of economic and social growth, but it risks being just a slogan if we do not create the conditions for its development.
The evolution of the competitive scenario has made the rules system obsolete and the uncertainty of the macroeconomic scenario has accentuated the difficulties of our sector. This drives me to be determined in seeking solutions to the key problems of the Group and promoting change. Inaction is not an option!
It is necessary to enable the industry consolidation, incentivize the leap towards new technologies, and introduce new mechanisms for a more equitable redistribution of costs related to the growth of data traffic, such as the "fair share" approach. The renewal of the regulatory framework for telecommunications is a fundamental piece of the puzzle to be put together to achieve a more balanced digital ecosystem.
With the Industrial Plan plan presented in July 2022, we have outlined the path towards the transformation of our Company and the entire sector.
We have chosen to move beyond the vertically integrated model, as it no longer meets the needs of a market as the Italian one. Infrastructure and services are two worlds that can perform better if managed separately, to focus on their respective strengths and potential growth, and to ensure better capital allocation. And I don't believe this necessarily applies to Italy only.
Companies and Public Administration look for digital solutions that help them to transform and offer their customers accessible and to reliable services with a lower environmental impact. Solutions must be simple and secure, which is why we have brought all cloud, IoT, and security activities and services under a single business unit: TIM Enterprise, which uses the largest network of designers, sellers, and customer care in the ICT market.
In 2022, its revenues grew more than those of the market and we expect further growth, thanks to greater efficiency resulting from organizational integration and the increasing customization of our products and services.
With more than 90 million mobile lines and about 16 million fixed lines, our products and services can help promote sustainable lifestyles. Our TIM Green line is useful in concretely stimulating a change in the behavior of our customers because it includes products and accessories with low environmental impact and services to extend the useful life of devices, through regeneration, recycling, and recovery of materials.
Infrastructure requires significant investments to ensure technological evolution, but when the cost of capital increases and the return on investment is uncertain, we must overcome the constraints determined by vertical integration of the business and seek economies of scale through market consolidation. The value of this model is supported by the interest of investors, both national and international, who want to focus on infrastructure business.
However, we have implemented specific actions on all Group infrastructure including data centers, to contain energy, water and cooling consumption, and to reduce CO2 emissions by making increasing use of renewable energy, in terms of efficiency and environmental impact.
The evolution of the technological and economic scenario also requires to operate on our organization. With approximately 50,000 colleagues and an average age of 49 years, we need a deep transformation. First of all, we have decided to protect jobs by continually improving and redeveloping skills. And this is not just a slogan, think about other companies in better financial condition, that plan to substantially reduce their workforce. We have adopted flexible working models and we have made our workplaces increasingly sustainable. Each year, we significantly invest in welfare to support the well-being of our employees and their families through initiatives that promote, for example, work-life balance, family care, education, health, and financial support.
Inclusion and talent enhancement are important ethical values, but also a point of contact with the new generations. We are taking actions to eliminate the gender gap and ensure equal opportunities and professional growth. Gender equality is indeed a resource on which to build a more solid world of work and a more equal society. In 2022, we reached 43% of women on the Group's board of directors and over 28% of women's presence in managerial roles, in addition to carrying out development and empowerment projects. To this is added the 4Weeks4Inclusion initiative, the marathon that we carry out together with our partners to promote the values of inclusion also outside the company.
The projects and actions we have put in place run through our entire business because they intercept what is relevant for the sector and the Group in the medium/long-term and what can determine significant changes both in terms of opportunities and risks. For example, the increasing purchase of renewable energy has partially protected our income statement from sudden increases in fossil fuel prices. Through network and data center efficiency, we have contained the consumption resulting from data growth. With the circular economy we have transformed waste reduction and recovery into an economic resource. Our green data centers allowed us to win the tender for the establishment of the National Strategic Hub will provide cloud services based on our infrastructure to the entire Public Administration.
These facts show that we are moving in the right
direction, carrying out actions that benefit both our Group and the community. We are experiencing that sustainability does not represent a trade-off between the costs to support it and the environmental and social impact. And we are convinced that our change will concretely contribute to the objectives of the 2030 Agenda and the guidelines of the United Nations Global Compact to which we have long adhered.
A year ago, few people believed that we would achieve the ambitious goals we set for ourselves. The first results are now evident to everyone, even though the road is still long. We will continue to walk it with determination and courage, committing ourselves everyday because sustainability for us is a lifestyle. We are part of an ecosystem that goes beyond competition, regulation and profits. Everyone must do their part.
Pietro Labriola Chief Executive Officer
| TIM Group at a glance 5 |
|---|
| Sustainability for TIM 7 |
| ENVIRONMENT 13 | |
|---|---|
| Environmental strategy 14 | |
| Greenhouse gas emissions 16 | |
| Energy efficiency 18 | |
| Electricity 23 | |
| Circular economy and resource efficiency 25 | |
| TIM Green 29 | |
| Sustainable Supply Chain 32 | |
| Employee mobility 36 | |
| Biodiversity 38 |
| SOCIAL 39 | |
|---|---|
| DIGITAL GROWTH 40 | |
| Development of ICT infrastructure 41 | |
| Digital solutions for business growth and sustainability 42 | |
| Digital identity services 44 | |
| Public sector transformation projects 45 | |
| Tools to support digital innovation 48 | |
| TIM PEOPLE 49 | |
| Value of our people 50 | |
| Our training and reskilling programs 51 | |
| People Caring 53 | |
| Smart working 54 | |
| Inclusion 55 | |
| Gender GAP 59 | |
| Health and Safety protection 60 |
| ACTIVITIES IN THE SOCIAL FIELD 61 | |
|---|---|
| Collaboration with Institutions 62 | |
| Solidarity fundraising 63 | |
| Foundations 64 | |
| GOVERNANCE 66 | |
|---|---|
| Corporate Governance Structure 67 | |
| Internal control system 69 | |
| ESG Governance tools 71 | |
| Business Integrity 79 |
| Methodological note 85 | |
|---|---|
| GRI 2 - General Disclosures 87 | |
| GRI 3 - Material Topics 126 | |
| Correlation Material Topics - Enterprise Risk Management 205 | |
| Environment 212 | |
| Human Rights - Discrimination 228 | |
| Employees 231 | |
| Suppliers 257 | |
| Customers 263 | |
| Civil Society 271 | |
| Sector business community 289 | |
| Legislative Decree 254/2016 Connection 290 | |
| GRI Content Index 291 | |
| European Taxonomy 300 | |
| Independent Auditors' Report 320 |
We are the first telecommunications Italian operator and with innovative technologies and services we drive digital transition in Italy(1) and Brazil
(1) In this document, the "Italy" perimeter refers to TIM S.p.A. and companies controlled and fully consolidated by it as of December 31, 2022. This perimeter corresponds to "Domestic BU" indicated in the non-financial report.
We offer individuals and families fixed and mobile telephony services and products for communication and entertainment, we support small and mediumsized enterprises towards digitalization with a portfolio tailored to their needs.
Cloud, IoT and Cybersecurity are at the center of TIM Enterprise's end-to-end solutions for businesses and Public Administration, which realize the country's digital transformation using the largest network of data centers in Italy, the expertise of Group companies such as Noovle, Olivetti and Telsy, and partnerships with leading groups.
We develop fiber fixed network infrastructures which we make available to the entire market, both through a widespread presence throughout the national territory and through Sparkle at the international level. In Brazil, TIM Brasil is one of the main players in the South American communications market and a leader in 4G coverage.
Through Fondazione TIM, we also support projects of high social interest.

KEY 2022 NUMBERS

MAIN BRANDS
In defining the ESG targets of our Plan, we have considered four main areas of intervention that also guide our projects: environmental protection, digital growth of Italy, enhancement of employees skills, and governance strengthening.
As for environmental protection we aim for efficient infrastructure with increasing use of renewable energy, circular models for recycling and recovery of waste, ESG suppliers and a green commercial offer.
For the digital growth of Italy we bring ultra-fast connectivity throughout the territory and offer innovative digital services for individuals, businesses and Public Administrations.
As for the enhancement of TIM people we develop their skills, foster talent growth and reduce the gender gap.
To strengthen Governance we consolidate organizational levers and tools to minimize risks and company costs, integrating ESG into processes and business systems.
In the 2022-2024 Plan, we have set 12 specific and measurable targets, 5 for the Group and 7 for the Italy perimeter, which give substance to our commitments.
In the 2023-2025 Plan, we made some changes to consider the 2022 performance, and we aligned the main targets to 2025 to ensure a more homogeneous reading, net of long-term goals.



(1) Baseline 2019 (2) Weighted average of target 23-25 Italy ≥27% made up of "Italian women managers" and target Brazil ≥ 35% made up of "Brazilian women managers" (3) Average revenue from resale of waste, materials, and goods no longer used per kg of waste produced (4) Target 22-24 excludes revenue from cloud services (5) PEC, SPID, ature (active services) (6) Population involved in the "Sustainability Scenarios" pathway
Scope 1: emissions from production activities (trigeneration, transport, ozone depleting gases, heating and generator sets) Scope 2: emissions from purchased electricity
Scope 3: upstream and downstream emissions occurring in the value chain (cat.1-purchase of goods; cat.2; capital goods; cat 11-use of sold goods)
In Italy, in 2022, we implemented more than 40 projects that allowed us to record progress against Plan targets and achieve important results in the environmental, social, and governance fields. Below are some of the main results.
We have long collaborated with various national and international organizations to promote sustainable development and disseminate universally recognized values. In 2022, we intensified alliances and collaborations in the ESG field to share and adopt the best environmental and social standards.
| From December 2022 |
Eco Rating | We support the initiative of international mobile operators that assess the environmental impact of smartphones to help customers make informed and more sustainable choices and to encourage suppliers to reduce the environmental impact of their devices |
|---|---|---|
| From September 2022 |
European Green Digital Coalition |
We are part of the alliance formed by leading European companies in the ICT sector to promote the role of digitalization in reducing CO2 emissions through innovative technologies with a low environmental impact |
| From September 2022 |
Open-es | In Italy, we are partners of the system alliance that aims to measure the sustainability performance of suppliers, strengthen the qualification process with market ESG standards, and build shared growth paths |
| June 2022 |
SBTi (Science Based Targets initiative) |
We obtain scientific validation of our environmental strategy from the international organization that promotes the definition of measurable goals for reducing the carbon footprint and independently validates them |
| Since 2020 |
ASVIS (Alliance for Sustainable Development) |
We are a sponsor of the Italian alliance created to increase awareness among Italian economic entities and institutions of the importance of the commitments of the 2030 Agenda for sustainable development |
| Since 2010 |
JAC (Joint Audit Cooperation) |
We are founders, together with Orange and Deutsche Telekom, of the international association of telecommunications operators that verifies, evaluates, and develops sustainability in the supply chain of the information and communication technology industry |
| Since 2008 |
GeSI (Global Enabling Sustainability Initiative) |
We are a partner of the International Association for Digital Transformation that provides a unified voice for its ICT members towards Stakeholders, policymakers, and institutional communities in the sector |
| Since 2002 |
Global Compact |
We are members of the Global Compact Network Italy, which promotes a sustainable global economy that respects human and labor rights, environmental protection and fights against corruption |
| Since 1995 |
GSMA (Global System for Mobile Communications Association) |
We are members of the international association that brings together the main mobile telecommunications operators and develops studies on the positive contribution of technology in reducing greenhouse gas emissions and achieving sustainable development goals |
| Since 1992 |
ETNO (European Telecommunications Network Operators' Association) |
We are part of the European Association of Telecommunications Network Operators whose mission is to develop a regulatory environment conducive to the provision of services for citizens and businesses |
| Since 1988 |
ETSI (European Telecommunications Standards Institute) |
We are a member of the leading European telecommunications standardization organization |
| Since 1970 |
ITU (International Telecommunication Union) |
We are a member of the United Nations Agency that aims to coordinate global telecommunications activity |
As TIM Group we have been present, since 2003, in the sustainability indices of the main international rating agencies and, to date, we are included in over 20 ESG indices and ratings, getting notable scores which denote high performance and low levels of risk. Continuous dialogue with rating agencies supports us in analyzing the results achieved and in planning new actions to be implemented in the ESG field.

The performance recorded in 2022 led to significant recognition by ESG rating agencies.
The Group has been included in the indices for Italy since 2003 and for Brazil since 2014. In 2022, we confirmed our position as the only Italian telecommunications Company in the Dow Jones Sustainability Europe Index, and we were also distinguished in the Top 10% of the S&P Global ESG Score in the S&P Global Sustainability Yearbook 2023.
The Group has been included in Moody's ESG Solutions Global Index (formerly Vigeo Eiris) since 2017. In 2022, we ranked first among telecommunications companies with an ESG performance above the sector average, and in the "advanced" category of the overall ranking.

Gender Equality Index
2023.


In Italy, in 2022, TIM was awarded as the best Company for LGBT+ inclusion by the Parks LGBT+ Diversity Index, which identifies the most inclusive Italian companies in this area.
The Group has been in the index since 2020 for Italy and 2021 for Brazil. In 2022, we had a scoring higher than the industry average and all companies included in the index, positioning us among the world leaders for gender diversity and equality in Bloomberg
The Group has been in the index since 2020 for both Italy and Brazil. In 2022, we also confirmed our position among the top 100 companies and the first Company in Italy and South America in the telecommunications sector.
The Group has been participating in the CDP (formerly the Carbon Disclosure Project) questionnaire since 2010. In 2022 we are on the B list for Climate Change for both Italy and Brazil, confirming our environmental commitment in terms of actions, objectives, and governance.
The Group has been included in the rating since 2010 for Italy and since 2022 for Brazil. In Italy, in 2022, TIM is in the top list of companies achieving the "platinum" level for ESG performance in terms of labor, human rights, environment, ethics, and supply chain, while TIM Brazil achieves the "gold" level.

| Environmental strategy 14 | |
|---|---|
| Greenhouse gas emissions 16 | |
| Energy efficiency 18 | |
| Electricity 23 | |
| Circular economy and resource efficiency 25 | |
| TIM Green 29 | |
| Sustainable Supply Chain 32 | |
| Employee mobility 36 | |
| Biodiversity 38 |
We work to achieve "zero-emissions" and maximum efficiency in the use of resources
The ICT sector relies on fixed and mobile network infrastructures and data centers that require significant amounts of energy and, therefore, generate considerable C02 emissions. An environmental issue that, with the increase in energy costs resulting from the recent crisis, also translates into a business issue.
To curb the effects of climate change, as early as 2020 we have started a program to progressively decarbonize the activities of the supply chain, to make the energy consumption of assets more efficient, to increase the use of renewable energy sources, including self-production, and to promote circular models to reduce waste and valorize resources.
From 2022, to accelerate the reduction of greenhouse gas emissions, we have included two new targets in the ESG Plan: a 47% reduction in upstream and downstream emissions occurring in the value chain (Scope 3) by 2030, and Net Zero emissions (Scope 1+2+3) by 2040. Also, in 2022, our climate strategy was validated by the Science Based Targets initiative (SBTi), which has confirmed the coherence of this strategy with the goal of keeping global warming within 1.5°C as established by the Paris Agreement on climate change.
The strategy is complemented by the inclusion of:

(1) The 2019 emissions were re-determined to submit the objectives to the SBTi. The re-determination differs by less than 1% from the 2019 baseline.
(2) The target includes categories 1 (purchased goods and services), 2 (capital goods), and 11 (use of sold products).
To measure our Company's CO2 emissions, we apply the "GHG Protocol", which distinguishes between direct emissions (Scope 1), indirect emissions (Scope 2) and other indirect emissions (Scope 3).

The figures shown have been rounded up; as a result, the amounts may not correspond to the totals reported. (1) They include both diesel emissions for generating sets and natural gas emissions for energy self-production. (2) Scope 3 includes measurement and certification of 3 out of 15 emission categories.



Our Scope 1 emissions are generated by productive activities and regard fossil fuel consumption to power heating and trigeneration plants in the exchanges and Data Centers, generators sets and the company fleet. For Brazil, emissions also concern those arising from natural gas consumption for electricity self-production.
In 2022, we reduced these emissions by 12% compared to 2021 and by 27% compared to 2019 thanks to consumption curbing activities and energy efficiency projects.
Our Scope 2 emissions(1) derive from the purchase of electricity needed to power our infrastructure and offices. In 2022, we reduced these emissions by 16% compared to 2021 and by 47% compared to 2019, thanks to the increasing use of renewable energy sources. In Italy, we will reach 100% renewable energy by 2025, while Brazil has already achieved zero emissions in this area since 2021.
Our Scope 3 emissions are generated upstream and downstream of our production activities and mainly relate to the purchase of goods and services (cat. 1), the purchase of capital goods (cat. 2) and the use of sold products (cat. 11 calculated only for TIM S.p.A). For these three categories, for which we have a target of reducing emissions by 47% by 2030, we record a 13% reduction compared to 2021 and a 8% reduction from 2019. In 2023, the measurement system will be revised to include additional Scope 3 categories.
(1) Emissions were calculated using market based methodology.
(2) The figure differs from that reported in the 2021 Sustainability Report, which also included cat. 6-7.
In 2022, we kept the increase in total consumption of energy from fuels, gas, and electricity under control despite the growth in fixed and mobile voice and data traffic and the activity of data centers.
A milestone that we have achieved thanks to the use of technologies that have allowed better performance with the same amount of energy resources.



633
2,597
1,964
Italy Brazil Group
2020

Italy Brazil Group
Power Usage Efficiency (PUE) relates the energy consumed by IT equipment to the energy consumed by the entire data center. The closer the value is to 1, the more efficient the data center is because it directs energy only to the IT portion. The industry average is 1.55.
18
Our offices, industrial sites and Data Centers have been structurally rethought to divest spaces and technologies that are no longer functional and to reduce maintenance costs and energy consumption.

We manage around 80 office spaces with over 50 people in about 50 Municipalities.
In 2022, the plan for organizing and restructuring the company spaces continued thanks to the consolidation of Smart working and the Desk Sharing work model, which rationalized workstations and the use of locations, reducing management costs and energy consumption.
For the renovation interventions, we chose sustainable materials such as 100% recyclable flooring used for over 100,000 square meters, which can be reused at the end of their life, avoiding waste production. As efficiency measures, we began installing sensors to monitor office temperatures
| THE STRENGHT OF CONNECTIONS | ||
|---|---|---|
| 10 HABITS FOR A SUSTAINABLE OFFICE | ||
| Our behaviors also count toward achieving the 0 emissions goal by 2030! By adopting good office habits all together, in one year we can save up to 540t of CO2 equal to the absorption of about 11,000 trees. Estimated value not countable |
||
| CORRECTLY SEPARATES WASTE Help us to reduce, reuse, and better dispose of what is not needed |
||
| DO NOT PRINT UNLESS NECESSARY Limit paper and toner use as much as possible and use front/back when possible |
||
| ACTIVATE STANDBY WHEN YOU ARE NOT AT YOUR PC Use PC Sleep mode and help us minimize energy consumption |
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| TURN OFF THE LIGHT WHEN YOU DON'T USE IT Whenever you can take advantage of natural light and delay turning on the electric light |
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| SHUT OFF WATER WHEN IT IS NOT NECESSARY Be careful to turn off water taps properly, for example, in bathrooms and break rooms |
||
| REDUCE THE USE OF HAND TOWELS Protect the environment. Hand towels are not intended for recycling |
||
| PREFER THE STAIRS TO THE ELEVATOR Going up the stairs is a good activity that also helps to save energy |
||
| TURN OFF SCREENS IF YOU ARE NOT USING THEM Check that they are turned off at the end of each meeting |
||
| CLOSE WINDOWS IN AIR-CONDITIONED ROOMS Open windows the minimum time necessary for air exchange |
||
| TURN OFF THE HEATING WHEN NOT IN USE Where possible, intervene on the thermostat to turn off the system (e.g., meeting rooms) |
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| BECOME A PROMOTER OF SUSTAINABILITY. |
and more efficient air conditioners. Finally, to promote sustainable office behaviors, we launched a decalogue with the ten good habits for a sustainable office.
ENCOURAGE COLLEAGUES TO HAVE VIRTUOUS BEHAVIORS
We have about 10,500 industrial sites for our fixed and/or mobile network in over 6,900 Municipalities.
In 2022, the energy-saving plan continued, resulting in an overall saving of approximately 100 GWh/year.
Decommissioning activities led to:
The energy efficiency interventions provided for:
• the implementation of a Building Energy Management System (BEMS) for the monitoring of the technological systems of 35 strategic exchanges. A total of 358 probes for monitoring micro-climatic conditions, 126 power meters for energy consumption, and about 150 machines for powering and conditioning rooms were installed;
Thanks to the energy savings produced, about 14,000 Energy Efficiency Certificates have been issued with an economic value of about 3.8 Mln€.

We manage 16 Data Centers in 8 cities that guarantee the maximum levels of operation, security and energy efficiency.
The "Public Cloud" Data Centers built in 2021- 2022 are designed with eco-sustainable criteria, including building materials that are free of pollutants, lighting systems that reduce light pollution, and eco-friendly paints.
In the "Core" Data Centers, interventions continue to optimize room cooling and lighting, to renovate continuity systems (UPS) and conditioning systems, with an average energy saving of about 2.8 GWh/ year.
In addition, interventions were carried out on the IT infrastructure, resulting in an average energy saving of about 13.5 GWh/year.
Overall, more than 100 certifications attest to the efficiency, sustainability, and safety of the sites. These include ISO 50001 for the energy management system, ISO 14001 for the environmental management system, ISO 27001 for information security management, and LEED Gold for the eco-sustainability of building design and construction.

6 Data Center Core that offer cloud and collocation services with the highest performance
where platforms of the most relevant public cloud providers operate

i.e., secure and reliable micro data centers located near customer sites

The interventions on our company vehicle fleet focus on optimizing management costs and reducing fuel consumption.
We manage 12,500 vehicles including 10,000 work vehicles, 2,300 cars for mixeduse, and 200 cars in car sharing.
Work vehicles: are used by technicians for maintenance and fiber installation interventions. In 2022, a project was launched to optimize the vehicle fleet, which will continue in 2023 with the reduction of 1,000 vehicles.
Cars for mixed-use: demand for electric/hybrid cars grew to 22% with a six-monthly renewal of

the Car List to have cars that comply with the latest European emission regulations.
Vehicles in car sharing: replacement plan with Full Electric powered cars continued, involving 13 cities and 25 corporate locations for a total of 50 vehicles.
To encourage the use of electric/hybrid cars, in 2022 we installed 47 electric charging stations in 13 cities and 31 locations, with an increase of 24% compared to 2021.
The electricity that powers our exchanges and data centers is mostly purchased and to a small extent self-produced by trigeneration, generator sets and photovoltaic plants.
We increasingly rely on the use of energy from renewable sources, both purchased and selfproduced, with the goal of achieving 100% green electricity by 2025. In 2022, electricity from renewable sources accounted for 61% of the Group's total electricity. In Italy, the percentage reached 45%, while in Brazil arrived to 98%.


Renewable sources Mixed sources

ENERGY(3)
100
100
%
%
RENEWABLE
14 new self-production
TIM Retail Stores Sparkle Plants in Italy
1 in Lombardy 6 in Lazio 3 in Abruzzo 3 in Apulia 1 in Sardinia
Noovle Data Centers Offices
plants
In 2022, renewable energy from Guarantees of Origin(1) (GO) and from Power Purchase Agreements (PPA) covered 45% of TIM's total electricity consumption amounting to approximately 710 GWh(2).
In 2021, we signed a ten-year corporate Power Purchase Agreement (PPA) with ERG for the supply of 340 Gwh/year of renewable energy from wind farms.
In 2021, we also launched a plan to install 14 photovoltaic plants with a capacity of about 0.7 GWp. We also started the restoring of 101 existing small-scale plants in the country with a capacity of about 0.9 GWp. For these plants, self-production will be calculated starting from 2023.
(1) Guarantees of Origin are electronic certificates that attest to the renewable origin of the sources used. (2) The data refers to energy calculated at the PoW (Point of Withdrawal) and corresponds to 757 GWh at the PoI (Point of Injection). (3) An equal quantity of Guarantees of Origin has been allocated for the energy consumed by the indicated perimeters.
The company's environmental impact also depends on responsible use of products and materials, waste reduction, and their transformation into economic resources. To measure our ability to transform waste into value, we have introduced the "Circular Economy Ratio", an index that relates revenues from waste recovery and resale of unused goods and materials to the total waste production(1).
In 2022, the indicator reached a value of 0.3€/kg, an increase of 0.26€/kg compared to 2021, thanks to lower waste production and an increase in the resale of waste and unused goods, which generated 2.4 million euros in revenues (2 million euros more than in 2021).



Our waste production shows a variable trend over time linked to the cyclical nature of some activities such as the decommissioning of network infrastructures and data centers or office reorganization. However, the percentage of products and materials sent for recovery remains high and stable.
Our commitment is to strengthen the control of the production chain. That's why, in 2022, we reviewed the main waste management contracts, requiring our suppliers to have EoW (End of Waste) certification and a report with evidence of the percentage of recycled waste.


The evolution of smart working and desk sharing has made a part of the furnishings and IT equipment no longer essential.
In 2022, we recovered about 5,400 pieces of furniture and company equipment, donating over 1,200 items to non-profit organizations that allowed us, among other things, to set up a nursing school in Dakar, Senegal and provide IT equipment for educational support of lowincome families.

We donated one of our disused pylons to the National Alpine and Speleological Rescue Corps of Belluno for the construction of a radio bridge and a parking area for hikers and specialized personnel. The sale also allowed us to avoid the costs of decommissioning and disposal of the supporting structure which, among other things, would have involved the use of a helicopter for transportation.
In 2022, we started a path of valorization of technological waste through the resale of equipment and materials through specialized brokers. The sale concerned:

(exchanges, base stations) for the recovery of precious metals and other raw materials. Approximately 1,500 tons of material were recovered, with 600,000 euros in revenue.

DISUSED COPPER CABLES generated a total revenue of 1,250,000 euros.

We reduce the consumption of natural resources such as water and materials such as paper and plastic to contain waste and promote sustainable behaviors in the Company.
(m3 )
In 2022, we consumed 1,495,813 m3 of water, 80% of which was allocated for civil use and 20% for industrial use (trigeneration and cooling).


We purchase paper for office and commercial use. On the commercial front, we aim at a progressive digitization of bills, commercial contracts and our archives.
In 2022 we collected about 5 tons of high-quality and mixed paper following the reorganization of our offices, which was then recovered as a secondary raw material. We use paper produced according to the requirements of the Forest Stewardship Council (FSC).

In 2022 the plastic waste generated by our activities amounted to approximately 59 tons. To reduce the environmental impact of plastic, we added Sustainable SIM CARDS to our product range, saving about 8 tons of plastic in 2022.

We installed 25 water dispensers in 9 corporate locations to reduce the use of plastic bottles. Water dispensers will also be gradually installed in the corporate canteens.


To encourage environmentally conscious purchasing choices we have dedicated a section on our commercial website, TIM.it, to the TIM Green products and service range. Sustainability is also relevant for the management of our 216 proprietary stores. Today, our stores manage customers digitally, use recyclable and recycled paper shopping bags, and are powered by 100% renewable energy(1).
(1) Guarantees of Origin have been allocated for the energy consumed by TIM Retail stores.
In 2022, we continue to neutralize the CO2 emissions generated by over 680 million page views on our main commercial and institutional websites in collaboration with Rete Clima, a nonprofit organization.
We have compensated for 554 tCO2 eq, equivalent to approximately 78 trips around the world by car, corresponding to the energy consumption of the servers hosting the websites and the services that make them work.
We offset CO2 emissions with the international project "The Envira Amazonia" REDD+ for the conservation of an area of about 39,000 hectares of Amazon rainforest in Brazil. The project promotes the protection of local flora and fauna biodiversity and supports local communities with social programs for the collection, transportation, and sale of medicinal plants.
The project is certified according to the VCS-Verra standard, validated and verified according to the CCBS-Tke Climate Community and Biodiversity Standards with Triple Gold Level Distinction.

suppliers in 2022
632
19%
We select suppliers by evaluating their commitment to sustainability TIM SUPPLY CHAIN KEY NUMBERS ITALY
TIM Suppliers(1) newly acquired
Transparency, cooperation, free competition, respect for human rights and quality are the values underlying relationships with our suppliers. 5% 4% THE TOP 10 CATEGORIES OF PURCHASED PRODUCTS AND SERVICES
We have also embarked on the path toward a Sustainable Supply Chain with the intention of growing over time the environmental economic and social value of this relationship. 19% 7% 5% 5%

(1) Active suppliers with ordered and expected delivery in 2022.
(2) Orders and contracts.

(1) Active suppliers with ordered and expected delivery in 2022. (2) Orders and contracts.
17% 9%
9%
The sustainability of the supply chain reduces Scope 3 emissions, considering that purchases account for over 80% of the company's total emissions, and improves market performance by stimulating suppliers to seek efficient, innovative, and low-emission impact solutions. We have included ESG control elements in all phases of the purchasing process.

In the management of our suppliers, we identify those at ESG risk based on the geographical areas where they operate (Asia, Central and on the South America, North Africa, Eastern Europe) and potential violations related to the environment, human rights, and labor. These suppliers fill out an ESG questionnaire to access our registry.
In 2022, we became a Value Chain Partner of the Open-es alliance, which, through a platform and an ESG evaluation system based on international standards, will allow us to extend ESG evaluation to all suppliers using shared sustainability criteria.
| Suppliers at ESG risk | 690 | ||||
|---|---|---|---|---|---|
| % on total suppliers Suppliers at ESG risk |
19% 690 |
||||
| 19% % on total suppliers 921 TIM suppliers registered with questionnaire |
|||||
| TIM suppliers registered with questionnaire | 921 |
We have introduced a checklist of 30 parameters (eco-standard guidelines) to include sustainability purchase requests of products and services. In tenders, in addition to technical and price evaluations, we have included a sustainability grid with a weight of up to 10%, which considers the ESG parameters of the product/service included in the purchase request.

7
In contracts, we include standard clauses that require suppliers to comply with the TIM Code of Ethics. In addition, we are starting to include specific ESG clauses for the purchased product/service.
We request EoW (End of Waste) certification, recyclability percentage, and recycling reports
We reserve the right to terminate the contract in case of non-compliance with even one of the environmental protection clauses
We request EoW (End of Waste) certification, recyclability percentage, and recycling reports We reserve the right to terminate the contract in case of non-compliance with even one EXAMPLES OF ESG CONTRACTUAL CLAUSES FOR TECHNOLOGICAL WASTE Contract for Access and Transport Network Works in copper and fiber optic: safety and environmental aspects are taken into account Contracts for fixed and mobile products: are checked to verify the energy consumption parameters EXAMPLES OF ESG ELEMENTS FOR VENDOR RATING We evaluate supplier performance based on audits to verify the technical compliance of technical characteristics of products or service performance. The results are summarized in Vendor Rating indicators that, if negative, result in order modulations or exclusion from tenders.
of the environmental protection clauses
Contract for Access and Transport Network Works in copper and fiber optic: safety and environmental aspects are taken into account
Contracts for fixed and mobile products: are checked to verify the energy consumption parameters
Thanks to the Joint Audit Cooperation (JAC), a voluntary association founded in 2010 by TIM, Orange and DeutscheTelekom(1), we address and monitor the applicability of the principles of Corporate Social Responsibility in the telecommunications supply chain, with a win-win approach for suppliers and operators.

(1) The alliance was subsequently joined by: 2011 Proximus, KPN, Swisscom, Vodafone Group; 2012 Telenor and Telia Company; 2013 Verizon; 2016 AT&T Telefonica; 2018 Mobile Tele System and Telstra; Telstra; 2019 Elisa OYJ; 2021 TDC, MTN British Telecom; 2022 NTT.
(2) It includes Audits 3rdparty, VAP Audits, Workers' Surveys and Remote Audits
(1)
Over 40,000 TIM employees located in over 650 offices in 200 Italian Municipalities generate daily commutes comparable to those of a small Italian city, with consequent impacts in terms of CO2 production.
The obligation since 2021(1) to draw up a Home-Work Commuting Plan (PSCL) has involved administering a questionnaire to employees to collect data on their commuting habits, offering at the same time the opportunity to identify interest in sustainable transportation modes and evaluate initiatives for mobility management. Thanks to the input received from our colleagues in 2021, we have restored shuttle services to corporate locations that are difficult to reach, installed 75 bike and scooter racks in 26 offices and tested a carpooling service.

(1) The activity is provided by the Interministerial Decree No. 179 of May 12, 2021, issued by the Ministry of Ecological Transition in synergy with the Ministry of Infrastructure and Sustainable Mobility, and provides for the drafting of a survey for all companies with more than 100 employees located in Municipalities with more than 50,000 inhabitants.
At the end of 2022, we launched a pilot project for the use of carpooling services in Naples, Rome, Florence and Milan, with the goal of making urban transportation more intelligent and greener.
The service was developed by the startup BringMe, the winner of the TIM Challenge for Circular Economy, with the aim of promoting behaviors based on a circular economy model.
With the "JOJOB Real Time Carpooling" App, users can view people who have a compatible route and book carpool rides, sharing the expenses.
We also associated the service with a cashback campaign that awards credits to the users for each carpool ride taken, which can be used for new trips or to obtain vouchers for shopping or fuel.

In 2022, there were more than 10,600 business trips, representing a 66% decrease compared to the pre-pandemic year of 2019.
The result is the outcome of the new policy on travel, which discourages non essential trips and

In 2022, we launched projects for the preservation of biodiversity in Italy through a partnership with Rete Clima(1).
In the Parco Nord of Milan, 150 new plants and shrubs typical of the Po Valley(2) were planted to contribute to the increase of green areas in the city. The planted trees will absorb around 50 tCO2 eq in their average lifespan of 30 years.
In Città della Pieve-Piegaro in Umbria, we implemented the "Elite Plants" project to preserve forest biodiversity, which allowed us to identify and map rare and valuable plants through GPS and promote their growth through specific management techniques.


(1)
(2) Projects carried out according to the Foresta Italia® Protocol of Rete Clima and with the moral patronage of the Ministry of Ecological Transition and the Ministry of Agriculture, Food and Forest Policies.
(1) Rete Clima, a non-profit organization specialized in promoting sustainability in companies.

| DIGITAL GROWTH | 40 |
|---|---|
| TIM PEOPLE 49 | |
| ACTIVITIES IN THE SOCIAL FIELD 61 |
| Development of ICT infrastructures |
41 |
|---|---|
| Digital solutions for business growth | |
| and sustainability |
42 |
| Digital identity services | 44 |
| Public sector transformation projects |
45 |
| Tools to support digital innovation |
48 |

Digital growth produces benefits for the economy, society and the environment. For this reason, we are focused on building a digitalized and sustainable Italy through innovative infrastructures and digital solutions that make people's lives easier and transform the way that businesses and public administration operate. This vision, which is reflected in our Industrial Plan, contributes to creating a more livable and inclusive society.
THE FIXED ULTRABROADBAND NETWORK

Revenues from digital services and connectivity grew more than the market average
Through TIM Enterprise, we lead companies and Public Administration towards digital transformation, offering services that improve the efficiency, safety and resilience of their business while reducing their environmental impact. A growth opportunity for the economy of Italy as a whole.
• Cloud services: to get the most out of IT while minimizing the environmental impact
With the Cloud, companies and Public Administration get maximum computing power and security, but also lower energy consumption and CO2 emissions, thanks to economies of scale and optimized energy use in our Data Centers.

• Smart Working & Collaboration services: more efficiency for companies and more time for people
Thanks to Smart working, companies reorganize spaces by reducing lighting, heating and air conditioning consumption. It decreases CO2 production related to energy consumption and home-office travel. People have greater flexibility in organizing their time.
• Security services: safety for a solid economy
Companies that invest in the security and resilience of their IT networks protect themselves from potential financial and reputational costs and contribute to the solidity of the national economy.
• IoT services for the Smart City: smart data for a more livable, safe and sustainable city
Digital technology can transform cities into places that are more welcoming and safe for citizens, and simpler and more efficient for administrators. In 2022, through Olivetti, we acquired the Urban intelligence Mindicity platform, which provides digital solutions for Italian municipalities.
• IoT services for Smart Agriculture and Smart Industry: improving productivity and minimizing environmental impact
Data collection from the ground and the air using IoT sensors, enrichment with data from other sources and analysis using Artificial Intelligence, allow you to decide, for example, if and when to irrigate or use pesticides.
The same methodology is applied in industry to control production factors.
• IoT services for E-Health: more accessible treatments for patients and more sustainable costs for the healthcare system
With digital health solutions, medical checkups become simpler and faster for patients and more sustainable for healthcare facilities by reducing time and optimizing the use of space.
We simplify the relationship between citizens and Public Administration
We develop digital identity and validation solutions for people and things, including SPID, PEC and ature.
• ature is the electronic equivalent of the traditional handwritten signature on paper and allows documents to be exchanged online with full legal validity, guaranteeing the integrity, authenticity and non-refusal of the electronic document on which it is affixed.
The services are provided by Trust Technologies, a Group company accredited as a provider of qualified trust services according to European legislation. In 2022, active digital identity services grew by 31% compared to 2021, more than expected by the Plan target (+15% CAGR as of 2024).
| 2022 Closing +31 % active services vs 21 |
Tgt 23-25 +30 % active services by 2025 - CAGR |
||||
|---|---|---|---|---|---|
| over 5 million of SPID Authentications made in one year |
over 1.2 million Digital Identity Users |
per day | more than 2.5 million certified electronic e-mail |
atures affixed per year |
more than 200 million |
We enable more efficient and inclusive management of public services
In 2022, we took part in public tenders funded by the NRRP (National Recovery and Resilience Plan) to complete the fiber coverage of the country by winning:
We were also awarded four lots in the "Connected Schools" tender, two lots of the "Connected Healthcare" tender and, lastly, the tender to create the National Strategic Hub, the Cloud infrastructure of the Public Administration.
(1) Areas in which an operator providing super-fast broadband connectivity services invests or will invest in the next three years.

Project for digitization, innovation and security in Public Administration funded by the National Recovery and Resilience Plan
In June 2022, we were awarded four lots of the "Connected Schools" tender to provide fiber coverage and supply connectivity to approximately 5,900 schools with symmetric speeds of at least 1 Gbps by June 30, 2026.
The call for tenders targeted nearly 10,000 school sites throughout Italy including lower and upper secondary schools and, in "white areas", also primary schools and kindergartens.

| 1. Piedmont | 4. Tuscany | 7. Calabria |
|---|---|---|
| 2. Liguria | 5. Lazio | 8. Sicily |
| 3. Aosta Valley | 6. Campania | 9. Sardinia |
Project for digitization, innovation and security in Public Administration funded by the National Recovery and Resilience Plan
In June 2022, we were awarded two lots of the "Connected Healthcare" tender for fiber coverage and the supply of connectivity to approximately 3,100 diversified healthcare facilities (from outpatient clinics to hospitals) with symmetrical speeds of at least 1 Gbps and up to 10 Gbps.
The work involves the supply and installation of the access network and operation, technical assistance and maintenance services.
Infrastructure work must be completed by June 30, 2026, guaranteeing connectivity services for at least the next five years.
The call for tenders targeted more than 12 thousand public health service facilities nationwide.

| 1. Lombardy | 2. Emilia Romagna |
3. Marche |
|---|---|---|
| ------------- | ---------------------- | ----------- |
Project for digitization, innovation and security in Public Administration funded by the National Recovery and Resilience Plan
In August 2022, through the National Strategic Hub set up with Sogei, Leonardo and Cassa Depositi e Prestiti, we signed the Convention for the design, implementation and management of the Cloud infrastructure that will host the critical and strategic data of Central Public Administrations, Local Health Authorities (ASL) and local Public Administrations. The goal is to have 75% of Italian administrations using Cloud services by 2026. We will provide 4 Data Centers powered by 100% renewable energy, interconnected through the new Virtual Data Center Network (VDCN) and built to the highest security and business continuity standards. In collaboration with Leonardo, we will develop advanced technology solutions for the Public Administration on this IT infrastructure.
We collaborate with Italian museums and archaeological parks to build new models of operational and economic management of cultural heritage by combining different digital tools:

We are collaborating with the Archaeological Park of Pompeii to digitize the artistic and cultural heritage.
In October 2022 with a concert-event dedicated to Pink Floyd, we realized a new way of enjoying the archaeological site, offering spectators an artistic performance that combines the past with the present and an Extended Reality experience thanks to 5G technology.
We pursue technological innovation to increase the value offered to our customers
As at December 31, 2022, our portfolio contains approximately 2,800 patents.
Throughout the year, we deployed our innovation efforts through a multitude of instruments:
international, both in the field of TLC and in sectors converging with ICT, including the automotive industry and Industry 4.0;
With TIM Ventures, we made direct and indirect investments for 11.3 million in startups and SMEs.
| Value of our people 50 | |
|---|---|
| Our training and reskilling programs 51 |
|
| People Caring 53 | |
| Smart working 54 |
|
| Inclusion 55 | |
| Gender GAP 59 | |
| Health and Safety protection 60 |

The ongoing evolution of the technological and economic scenario presents ICT companies with the challenge of managing organizational changes and adapting professional skills.
Our company employs over 40,000 people in Italy, with an average age of 51. To protect the wealth of experience of senior workers, in 2022 we launched the Longevity Program, a comprehensive plan of interventions to enhance their contributions and overcome age-related stereotypes.
At the same time, to foster generational turnover, we signed an Expansion Contract for the two-year period 22-24 which provides for:
• a reduction in working hours for around 30,000 workers, depending on their organizational area for three distinct percentages (10%, 15% and 25%) supplemented by a balancing payment and the provision of training and retraining programs;

We have set up a continuous training plan to improve the skills required by the ICT market which, during 2022, involved all employees in Italy in courses divided into four clusters:
scenarios and top trends such as that related to sustainability scenarios.
Also in Brazil, training activities have involved all employees, totaling about 0.6 million hours (62 hours per capita), with an increase of 24% over 2021 and with priority focus on the development of skills associated with technological and market and on strengthening ESG culture.

In addition to internal training, we are actively committed to reducing the gap between the skills required and those existing in the labor market. For this reason, we are contributing to the work of educational establishments with the experiences and teachings of our professionals on digital innovation topics, promoting the development of digital professions with training programs created with our technology partners, and working with highly specialized skills development centers to create innovative projects.
We are among the founding members in Rome of the Higher Technical Institute "Maria Gaetana Agnesi - Tech & Innovation Academy", a postgraduate high-tech school of excellence that trains Data Analysts and Digital Transformation Specialists.

In collaboration with Google Cloud we have developed a free training program to enhance digital skills and guide Italian developers (freelancers and IT business teams) to the Google Cloud Platform (GCP) certification.

As a partner and associate of some of the National Industry 4.0 Competence Centers, we have supported 6 winning proposals of the MIMI "Houses of Emerging Technologies" call for tenders on topics covering Blockchain and Crypto Asset, Internet of Things (IoT), Artificial Intelligence, 6G, quantum technologies.
The interventions are aimed at municipalities where there is an ultra-broadband network using 5G mobile technology.
The municipalities benefiting from the proposals are Bologna, Naples, Taranto, Genoa, Pesaro and Cagliari.
We create the conditions to increase the well-being of our people
In 2022, we repeated all the main initiatives for the well-being of people and families that we had already implemented in the past.
FOR FAMILY
workers of the Group.
We reimburse expenses incurred for daycare, preschool or baby-sitting services in order to support parenting and the work-life balance of colleagues.
For more than 50 years, we have been offering our employees' minor children a summer stay of fifteen days. An important change was introduced in the TIM Summer 2022 catalog: each stay was inclusivity-oriented, with targeted educational and training initiatives.
For the most deserving children of our employees.
We have disbursed 20 financial assistance packages to employees who found themselves in particularly difficult financial situations.
TIM myHealth
delivers medications to the home.
Enabled for all of the Group's people. Used in 2022 by more than 500 people.
A catalog of materials offering insights into the prevention of certain diseases and proper lifestyles.
A free Healthcare Policy for all our employees that provides comprehensive healthcare for the whole family, offers a telemedicine service, ensures the support of a doctor who is always available online, issues prescriptions and
Movement and physical activity
Since 2019, we provide our employees with a partnership with Gympass at subsidized costs which gives them access to over 2,200 sports centers, helping to reduce sedentariness, the fourth leading mortality risk factor worldwide.
Personal support desk with a package of 8 free online meetings and up to 20 optional meetings at a subsidized rate. 4 webinars to raise energy levels, manage emotions, plan for the future and 2 e-learning paths for the well-being of mind and spirit.
125 psychological support programs completed. 300 training course users.
We implement a work model that integrates productivity, well-being and sustainability
In Italy, we tested Smart Working with 9,000 employees for the first time in 2016, a year before the law that governs its operation came into force.
By 2018 there were already 13,000 workers and by 2019 they had increased to 21,000. During the pandemic emergency, over 30,000 employees were able to work remotely.

(1) For the calculation were used the following data: number of employees (TeleContact Center is out of calculation), number of days the offices were open, number of Smart working days, utility data (electricity, methane gas, diesel, water, cleaning services), and the home-to-work mobility of employees (results of an internal survey). The calculation was carried out by Rete Clima, a non-profit entity specializing in promoting sustainability in companies, through the use of emission factors from the Ecoinvent 3.9 database.
For many years we have paid particular attention to the topics of inclusion and the enhancement of diversity, in the knowledge that these aspects not only represent ethical values, but are also a formidable driver for enhancing the company's performance, as they are closely related to engagement and people's satisfaction.
Every year, we promote numerous events intended to disseminate inclusion issues, with the active contribution of employees. The most successful initiative is 4Week4Inclusion, an inter-company marathon organized by TIM for the third consecutive year.
Hundreds of guests and speakers took turns for four consecutive weeks telling stories of inclusion, best practices, models and tools for valuing all diversity: from disability to intergenerational comparison, valuing women's contributions, sexual orientation and gender identity, ethnicity and religion.
The central theme of this edition was the Gender Gap, with daily events and an entire day dedicated to it (November 25 - International Day for the Elimination of Violence against Women).

We implement actions to effectively guarantee the equality of women in terms of equal opportunities and professional growth. Gender difference is in fact a resource on which to build a more solid world of work and a fairer society. Progetto Donna aims to overcome the gender gap by tackling cultural aspects such as reducing gender bias, promoting shared family and parenting roles, and empowerment.
Gender and sexual harassment and bullying We have an ad hoc policy and legal, psychological and Person of Trust counseling services to support it. Since 2022 we have introduced a training course (on demand) on harassment and bullying.
We engaged the entire corporate population in the Harvard Implicit Test, in partnership with Harvard University, to measure unconscious biases related to gender.
Since 2021, we have introduced the new additional parental leave, which doubles the number of days available for mandatory paternity leave. A Psychological Desk is also available to support parenting, which is free of charge to support new parents in moments of difficulty.
We highlight the value of female leadership with cycles of role modeling meetings to combat gender bias and prejudice.
224 female colleagues under 35 years old involved in networking, mentoring and empowerment meetings to support their personal growth journey and fostering the creation of a network to exchange ideas, experiences and design common paths.
Since 2010, we have been a supporting partner of Valore D, the first business association in Italy - there are currently more than 330 - which since 2009 has been a pioneer in addressing the gender balance issue and the spread of a culture of inclusion to support innovation, progress and the growth of organizations and of our country.
Valore D supports member companies by providing know-how and effective tools for the Diversity, Equity and Inclusion strategy. Valore D also offers the opportunity for intercompany comparison through the exchange of best practices and ongoing dialogue among members, and is a point of contact for institutions.

Since July 2021, we have partnered with Mulheres Positivas, an ambitious project that, through a digital platform, promotes the employability and empowerment of Brazilian women.
We led the development of the initiative, which in 2022 grew into an intercompany program.


We are among the first Italian companies to provide specific inclusion programs for LGBT people. Based on our extended view of the family, we offer cohabiting partners all the benefits provided for family units, regardless of gender or blood ties. We therefore give homosexual families and their children the opportunity to access company caring services. For colleagues undergoing gender transition, we recognize self-perceived identity before the sentence is passed and prepare the working environment for the colleague's transition.

We are among the founding members of "Parks - Liberi e uguali" [Parks - Free and Equal], a non-profit association that promotes Diversity Management as a source of value and a competitive advantage. Parks supports member companies in building a culture of inclusion through training, organizational consulting, research, event organization and networking activities.
Although in Italy less than 1% of people in the Company belong to an ethnicity and/or religion other than the one prevailing in the country, we keep this aspect in mind in our actions. In 2022, a policy was published that gives people of religions other than Catholicism the opportunity to celebrate the holidays stipulated by their beliefs with ad hoc permits, and to be able to organize times of worship at corporate workplaces.
In Brazil, around 38% of TIM's workforce belong to ethnic minorities. In November 2022, we launched the "Black People Development Program" project to provide development paths for all of TIM's black professionals.
We aim for fair treatment between genders as an element of equity and meritocracy Gender balance is the basis for building a meritocratic organization and is generally recognized as instrumental in achieving business results. The gender gap is represented by the difference between the percentage of women in the Company and the percentage of those women in positions of responsibility. In both Italy and Brazil, we fight this gap with an Industrial Plan target that guides organizational transformations over time and with a short and long-term incentive plan.
In 2022, the pay gap targets set with the variable remuneration system were achieved: zeroed in management and reduction of the gap in middle management.

We apply the highest standards and pursue continuous improvement of our management model
Our Safety Management Model complies with the main recognized standards (UNI ISO 45001) and applies to all processes connected with offices and mixed use buildings.
In addition to the specific policy, which encompasses the safety management principles and guidelines, we have set up a Safety Steering Committee, chaired by the Chief Executive Officer, with the aim of:
In 2022, in addition to the mandatory activities, we carried out information and awareness campaigns aimed at all employees.
Near misses (or "near accidents") are events that did not result in injury to the person only because of favorable conditions and/or chance.


Sample of more than 3,500 on-field technicians and workers in the Real Estate sector
Near-miss reports
Thanks to the reports received, we have identified the highest risk areas on which to intervene with increasingly efficient prevention activities.
| Collaboration with Institutions 62 | |
|---|---|
| Solidarity fundraising 63 | |
| Foundations 64 |


We work together with the Italian Civil Protection Department and all national and local institutions, state administrations, the Armed Forces, private companies, research centers and local communities to protect human lives, settlements, animals, artistic heritage and the environment, both when disasters and emergencies strike and at major events such as concerts. To date, there are 14 emergency vehicles designed and engineered to build mobile exchanges throughout the country. We cooperate with Institutions FOCUS ITALY
We ensure prompt intervention by the Italian Coast Guard through our operational centers in Rome and Palermo, where over 130 people work, which ensure continuity of the maritime and satellite radio network services and therefore thus assisting the navigation.
In April 2022, we participated in a real test evacuation of the population of the island of Vulcano due to volcanic risk by testing for the first time the public warning system providing information to the population, "It-alert" commissioned by the Department of Civil Protection of the Presidency of the Council of Ministers and implemented by TIM together with other telecommunications operators.

For over 20 years, through text messages and land line calls, we have been raising solidarity funds to support humanitarian, scientific, social and environmental protection projects of the Third Sector Entities, as well as those in favor of national and international emergencies sponsored by the Italian Civil Protection Department. We offer the possibility of making donations via SMS for the value of 2 euros and calls from a landline to a dedicated number for the amount of 5 or 10 euros, then paying entirely the donated amounts to the sponsoring bodies.
ITALY

Since 2009, we have promoted the economic and social growth of the country through Fondazione TIM. In 2022, the organization disbursed around 3 million euros in donations and public tenders.
In Brazil, TIM promotes the social inclusion of children and teenagers through education programs in Science, Technology and Innovation (STI).
Since 2013, over 700,000 people have been involved in all 26 Brazilian states and the Federal District. In 2022, the "Exponential Education" initiative was launched with One By One ONG to prepare young people for the labor market.

Since 1998, with the Olivetti Historical Archives Association, we have collaborated with private and public entities to organize exhibitions, conferences, research, and publications.
In addition, we guard and manage a unique documentary heritage, enhanced in an innovative way using a digital approach that reaches new generations and an international target audience.
In 2022, we created the "Olivetti e la cultura nell'impresa responsabile" exhibition, a series of 6 exhibits at the P.A. Garda Museum in Ivrea. The Olivetti Historical Archives Association was among the sponsors of the UNESCO recognition of Ivrea Industrial City of the 20th Century (2018) and Ivrea Italian Book Capital (2022).


| Corporate Governance Structure67 | |
|---|---|
| Internal control system 69 | |
| ESG Governance Tools | 71 |
| Business Integrity | 79 |
Our corporate governance system to minimize business risks and costs

The Board of Directors in its activities is supported by four Internal Committees with advisory, proposalmaking, monitoring and investigative functions: the Control and Risk Committee, the Nomination and Remuneration Committee, the Related Parties Committee and the Sustainability Committee. Each Committee has its own rules of procedure which describe the composition of its members, how they are appointed and how they operate.
The Sustainability Committee, established in 2021, oversees the Group's ESG positioning, targets, processes and initiatives, interacting with:
Moreover, in Italy, the Sustainability Department, in collaboration with other Company Departments, defines the ESG targets for the Industrial Plan, identifies sustainability initiatives to support the Plan, drafts the Non-Financial Reporting and monitors the sustainability ratings in coordination with the CFO.
Within the Group, TIM Brasil also has its own governance structure with four board committees to support the Board of Directors.
Sustainability issues are managed by a Sustainability Department, and at the strategic level by the ESG Committee, which interacts with the Remuneration Committee and the Control and Risk Committee.

The internal control system is structured into three levels, and is applied in the various Group companies taking account of their specific individual operational characteristics.

The system is completed by:
Bribery Management Systems" certification, applies to the members of our corporate bodies, employees and various types of workers, and includes the following instruments:

We implement processes, policies, certifications to manage our business according to sustainability criteria
It is increasingly linked to the impact of business activities on the environment, customer satisfaction, employee engagement, and the reduction of gender pay gap.
The variable remuneration policy is another important lever for achieving ESG targets within the set timeframes(1).
It is based on specific performance targets representing strategic priorities. The scheme includes economic-financial objectives, including a gate target that constitutes the condition of access to the bonus, department objectives and ESG targets. The weight and minimum level of the targets are differentiated by population cluster. Intended for the CEO, General Manager and Key Managers with Strategic Responsibilities.
IL SISTEMA DI REMUNERAZIONE DI TIM
| ITALY | ||
|---|---|---|
| ESG target | Weight | |
|---|---|---|
| 2022 | Customer Satisfaction index | 10% |
| ESG | Employee Engagement - young segment | 6% |
| FOCUS | Gender Pay Gap - Middle managers | 6% |
| Total | 22% | |
Aligns management's interests with those of shareholders through participation in the business risk. The three-year scheme grants stock options against economic-financial targets with a weight of 70% and ESG targets with a total weight of 30%.
Intended for the CEO, Top Management, and a select number of key managers with strategic responsibilities.
| ITALY | ||
|---|---|---|
| ESG target | Weight | |
| 2022-24 | % women in leadership position | 15% |
| ESG FOCUS |
% renewable energy out of the total energy consumed |
15% |
| Total | 30% |
(1) Further information on remuneration can be found in the "Report on Remuneration Policy and Compensation Paid" on the website www.gruppotim.it and the "Management Compensation Policy" at www.tim.com.br
We engage with our stakeholders on the most relevant issues to our business through the consultation, dialogue, information and collaboration activities we organize throughout the year, to better target our operational and strategic activities. A recurring event is the materiality analysis, conducted in preparation for drawing up the non-financial reporting, which, with a specific survey, allows us to discuss the most relevant materiality topics in terms of impact.
We update the list of stakeholders every year following the AA1000SES global standard, the most widely applied in this field. We identify our stakeholders starting with a list generated by an application that leverages semantic analysis and big data, which is then consolidated and weighed in terms of materiality by the company management.
In 2022, we identified eight categories of stakeholders with whom we have constant dialogue and confrontation.


Includes trade union organizations Includes peers, over the top,
Monthly trade union meetings
industry associations
Includes shareholders and banks Includes consumer associations Includes public administrations,
CIVIL SOCIETY
Survey

MEDIA Includes opinion makers
485 Press Releases (300 Italy; 185 TIM Brasil)
national and international institutions
The process is the basis of the Non-Financial Reporting and constitutes input for strategic planning and the management of company risk.
In 2022, following the International Standards of the Global Reporting Initiative, we have adopted the criterion of the relevance of impact according to a "single materiality" approach, i.e. assessing the actual or potential impact that TIM can generate for each topic on society and on the surrounding environment (inside-out approach).
The analysis involved both TIM's stakeholders and top management, who were asked to assess the relevance for TIM of the material topics based on their impacts.
Specifically, at TIM, the materiality analysis involves six steps:

In 2022, 16 material topics were identified. Below is the list of material topics sorted by impact relevance with evidence of the type and intensity of the impact.
Compared to 2021, we did not detect any substantial changes, but we have qualified the topics in more detail according to the relevance of their impact on the outside world, increasing from 12 in 2021 to the current 16.
New material topics are overseen by the Plan targets and ESG projects. Those with mediumhigh impact are overseen in terms of risk by our risk control system (ERM)(1).
| Material topics | Impact level | Type of impact | |||
|---|---|---|---|---|---|
| 1 | Privacy and cybersecurity | POTENTIAL | NEGATIVE | ||
| 2 | Digital inclusion | ACTUAL | POSITIVE | ||
| 3 | Infrastructures and emerging technologies | ACTUAL | POSITIVE | ||
| 4 | Customer interaction and service transparency | ACTUAL | POSITIVE | ||
| 5 | Employee health and safety | ACTUAL | NEGATIVE | ||
| 6 | Development and motivation of TIM employees | ACTUAL | POSITIVE | ||
| 7 | Climate change | ACTUAL | NEGATIVE | ||
| 8 | Energy transition | POTENTIAL | POSITIVE | ||
| 9 | Legal and regulatory context management | POTENTIAL | NEGATIVE | ||
| 10 | Equal pay and opportunity | POTENTIAL | NEGATIVE | ||
| 11 | Community and stakeholder relations | ACTUAL | POSITIVE | ||
| 12 | Resilience to physical, public health and sociopolitical risks | ACTUAL | POSITIVE | ||
| 13 | Sustainable supply chain | ACTUAL | POSITIVE | ||
| 14 | Human rights defense | POTENTIAL | NEGATIVE | ||
| 15 | Cyberbullying, child pornography, online gambling | POTENTIAL | NEGATIVE | ||
| 16 | Circular economy and waste production | POTENTIAL | NEGATIVE | ||
| environment social governance low |
medium high |
(1) See the section on the risk management system.
MARKET INSIGHTS
We oversee quality and customer experience through an extensive listening system that allows us to detect the customer journey at different touch points and to define specific improvement the plans to give value to our customers' feedback. Of particular importance among the surveys of the Italian market is the monitoring of the "Customer Satisfaction Index" based on the American Customer Satisfaction Index (ACSI) standard, which aims to survey the quality perceived by TIM customers and the customers of main competitors.
In 2022, the value of the CSI for the Consumer customer base of the Italy perimeter was 75.01 (vs 74.29 in 2021(1)) compared to a target value of 75.63 confirming a stable performance. Also in the Small and Medium Business segment, CSI improvement targets were set and fully achieved. With reference to the customer satisfaction indicators monitored by TIM Brasil, an improvement in the average Consumer Customer Satisfaction Index was recorded in 2022 with +7.5% vs 2021. The remaining satisfaction indicators were essentially unchanged.
MARKET SURVEY
MORE THAN 5 MLN FEEDBACK COLLECTED IN 2022 IN ITALY AND BRAZIL
(1) Updated data based on revenues for the reporting year.
The certifications we have obtained objectively demonstrate the creation, application and maintenance of a management and organizational system that follows national and international reference standards, providing assurance to our stakeholders while ensuring compliance with standards increasingly demanded in the tenders we participate.
In 2022 we count 9 major certifications with a specific focus on ESG issues.
| TIM S.P.A. DEPARTMENTS |
NOOVLE OLIVETTI | TELSY | TELECOM ITALIA TRUST TECHNOLOGIES |
TIM DIGITAL SERVICES |
SPARKLE | TIM BRASIL |
||
|---|---|---|---|---|---|---|---|---|
| E | ISO 14001: sets the requirements of the Company's environmental management system |
|||||||
| ISO 14064: certifies the quality of the reporting process and monitoring of greenhouse gas emissions of the Company |
||||||||
| ISO 50001: certifies the development of an efficient energy management system |
||||||||
| S | ISO 45001: standard for the occupational health and safety management system |
|||||||
| ISO 30415: certifies the presence and quality of inclusive and sustainable corporate programs in the workplace |
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| G | ISO 22301: certifies the presence of a management system for business continuity under adverse conditions |
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| ISO 9001: specifies the requirements for a quality management system certifying the quality level of the Company's products and services |
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| ISO/IEC 27001: reference standard for the management of information security |
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| ISO 37001: certifies the presence of a management system for preventing bribery |
To direct the correct operation of the business, we establish and constantly update the internal and external policies and organizational procedures that clearly define the rules and norms we intend to refer to. All policies are available on the internal and external channels of the Group companies. Among them we point out the 14 most relevant ESG policies.
| E | Environmental Policy | Group | |||
|---|---|---|---|---|---|
| Climate Change Policy | Brazil | ||||
| Human Rights Policy | |||||
| Health and Safety Policy | Group | ||||
| Human Resources Policy | |||||
| S | Gender Harassment Policy | Italy | |||
| Social Responsibility | Brazil | ||||
| Diversity and Inclusion Policy | |||||
| Information Security and Cybersecurity Governance Policy | |||||
| Whistleblowing Procedure | |||||
| G | Tax Strategy Policy | ||||
| Purchasing Policy for Products and Services | Group | ||||
| Crisis management policy | |||||
| Anti-corruption Policy |
We promote a culture of fairness TIM'S ENTERPRISE RISK MANAGEMENT MODEL and transparency

Our Group adopts an Enterprise Risk Management model (hereinafter ERM) that follows the international reference regulations and standards and integrates with the strategic and operative planning processes. The ERM model is designed to identify the potential events that may affect the business, identify and manage the connected risks within acceptable limits and provide awareness to Top Management.
We conduct a periodic review of the risk scenarios, not only when defining the Industrial Plan, but also upon the occurrence of significant changes in the internal and external context or new risk scenarios.
ERM has identified and mapped the risks of our Group into 12 continuously evolving clusters(1).
The risks included in the ESG area are an integral part of the clusters identified.

(1) For ERM, risk is defined as a possible event that can jeopardize the achievement of the Industrial Plan targets or the proper functioning of business processes and that, if identified and assessed well in advance, can generate value. The level of low, medium, and high ERM risk is based on the impact on Industrial Plan targets and processes as well as the probability of the event occurring (Risk = Impact x Probability). The impact on Plan targets is assessed for current risk as Equity Free Cash Flow at risk.
ESG risks are assessed annually in the materiality analysis, which selects and assesses the impacts and risks connected with material topics.
Also for 2022, the analysis shows that risks linked to the most relevant material topics in terms of impact are mapped and overseen by the ERM model through specific mitigation activities defined by the Risk Owners with the support of the Risk Management Department.
| Material topics | ERM risk level(1) | ERM Risk Area | ERM activities | |||
|---|---|---|---|---|---|---|
| 1 | Privacy and cybersecurity | Privacy / Cyber | ||||
| 2 | Digital inclusion | Technological | ||||
| 3 | Infrastructures and emerging technologies | Technological | Company | |||
| 4 | Customer interaction and service transparency | Market | processes analysis to identify risk factors |
|||
| 5 | Employee health and safety | Health and Safety | and the data needed for | |||
| 6 | Development and motivation of TIM employees | a quantitative assessment of the |
||||
| 7 | Climate change | Climate | risk profile | |||
| 8 | Energy transition | Climate | Support | |||
| 9 | Legal and regulatory context management | Regulatory / Privacy | in the decision-making |
|||
| 10 | Equal pay and opportunity | process of Risk Implementation Owners to define |
||||
| 11 | Community and stakeholder relations | of statistical mitigation mathematical actions |
||||
| 12 | Resilience to physical, public health and sociopolitical risks | Climate / Regulatory(2) | models for risk enhancement |
|||
| 13 | Sustainable supply chain | Supply Chain | ||||
| 14 | Human rights defense | |||||
| 15 | Cyberbullying, child pornography, online gambling | |||||
| 16 | Circular economy and waste production | |||||
| environment social governance low |
medium high |
(1) Inherent ERM risk level assessed gross of mitigation actions already implemented in the Company. (2) For the "Regulatory" risk area, ERM activity is being analyzed.
Among the mapped company risks, "Climate" risk is managed in line with the model proposed by the Task Force on Climate-related Financial Disclosures(1), which recommends disclosure by the company of the metrics and targets used to assess and monitor risks and opportunities linked to the climate, including Scope 1, 2 and, where possible, Scope 3 emissions.
To measure the actual and potential impact of this risk, we use a short, medium and long-term assessment model that provides an economicfinancial risk output.

(1) The Task Force on Climate-related Financial Disclosures (TCFD) is created by the Financial Stability Board (FSB), the international body that monitors and makes recommendations on the global financial system to improve and increase climate-related financial disclosure.
(2) Derive from climate change impacts.
(3) Derive from actions associated with a transition towards a lowcarbon economy, e.g., the introduction of new low-carbon climate or technology policies.
In 2022, we adapted the Group's Organizational Model overseeing personal data protection to the principle of privacy-by-design, which requires the data controller to implement effective technical and organizational measures to protect personal data, such as the introduction of new IT tools, including the one for managing Information Notices and the one for managing the Registers, which enable the integration of managed information.
In the cybersecurity area, we constantly upgrade the protection measures for the public telecommunications network and our network and data center infrastructures, in addition to having a robust IT security incident management process reinforced by operational policies and procedures on crisis management.
The curiosity and lack of experience of young people using chat services, email, instant messaging and more generally the Internet can make web surfing unsafe. Our goal is to protect minors from these virtual places first and foremost through offers dedicated to younger people (TIM Junior) that protect them when surfing from smartphones or PCs, which have features such as parental control, antivirus and anti-malware, protection and privacy.
Our commitment to Human Rights goes beyond "basic" rights and considers the specificity of our business activities, recognizing the right to access information, freedom of expression, protection of online privacy and security, the protection of minors from the risks associated with the use of new technologies.
From this perspective, we have adopted a Policy, reported in our Code of Ethics and in all the most relevant policies, which encompasses TIM's entire value chain, including our people, suppliers, business partners and customers, with particular regard to vulnerable groups.
Regarding our people, in 2021 we introduced a Policy that establishes complete intolerance of gender and sexual harassment and bullying, also promoting activities of awareness and preventive training by introducing psychological legal support tools to possible victims.
We have carried out a free training program "Digital Media Appointment" in collaboration with IDMO (Italian Digital Media Observatory), the European Union's Italian observatory for combating disinformation and disseminating good practices in the use of digital media.
The program designed for middle and high school teachers and students includes: video shorts, virtual and live classrooms, interactive games and a sign language service (Italian Sign Language) to understand the opportunities of the media world, at the same time gaining awareness of the possible risks.

84
| Methodological note85 |
|---|
| GRI 2 - General Disclosures 87 |
| GRI 3 - Material Topics126 |
| Correlation Material Topics - Enterprise |
| Risk Management205 |
| Environment212 |
| Human Rights Discrimination 228 |
| Employees 231 |
| Suppliers 257 |
| Customers 263 |
| Civil Society 271 |
| Industry Business Community289 |
| Linkage Legislative Decree 254/2016290 |
| GRI Content Index291 |
| European Taxonomy 300 |
| Independent Auditor's Report320 |
The Consolidated Statement of Non-Financial Nature (hereinafter "Statement") fulfills the obligations under Legislative Decree 254/2016 regarding the disclosure of non-financial information. The Statement presents the data and information that relate to TIM S.p.A. and its subsidiaries and fully consolidated companies as of December 31, 2022 (hereinafter "the TIM Group" or "the Group"), as presented in the Annual Financial Report(1).
Environmental performance data are presented with scope limitations, based on significance criteria(2). More generally, in each chapter and/or paragraph, if necessary, the scope is specified. These limitations are not relevant to the understanding of the company's activities, its performance, results, and the impact produced by the Group.
The Statement is a separate report from the Group Management Report and represents TIM's follow-up to its commitment to communicate its sustainability performance and achievements to its stakeholders,
already started in previous years.
The 2022 Statement, prepared annually on the calendar year, meets the same deadlines as the Group Annual Financial Report and is published on March 30, 2023. For any information regarding the published document, the e-mail box is available: [email protected].
The Statement is prepared according to the Global Reporting Initiative (GRI) Sustainability Reporting Standards (in accordance with).
References to GRI disclosures are given within the text highlighted with the symbol [GRI No. disclosure].
In terms of internal control of the contents presented in the Statement, the Company has set up a system that provides:
• an internal control system, implemented on the digital platform used for data collection, designed to ensure the proper tracking and reporting of nonfinancial information;
(1) For BU Brazil, the KPIs that include OI/Cozani are as follows: GRI 302-1; GRI 302-3; GRI 305-1; GRI 305-2; GRI 305-4.
(2) The reporting boundary of the Non-Financial Statement coincides with the Annual Financial Report, with the exception of environmental data for which, starting from the consolidation boundary of the Domestic BU, as reported in the Financial Report '22, threshold values were applied to the following items of the Domestic BU '21:
turnover (k€): 0.5% of turnover;
number of employees (no.): 0.5% of no.;
expenditure on energy and fluids (k€): 0.1% of expenditure.
The TIM Group companies included in the '22 environmental scope are listed below: TIM S.p.A, Sparkle Group (companies that meet the criteria), Fibercop S.p.A, Noovle S.p.A., Olivetti S.p.A., T elecontact Center S.p.A., Telenergia S.r.l., Telsy S.p.A., TIM Retail S.r.l., TIM Servizi Digitali S.p.A., as well as BU Brazil.
• the signing of a letter of attestation by the top individuals concerning the data constituting the paragraphs of the Statement under their responsibility. Finally, at the end of the Statement there is information regarding the European Taxonomy.
In terms of external audit, the Statement is subject to limited examination ("limited assurance engagement") by EY S.p.A., the Group's auditing firm, whose Report is available at the end of this Report.
Quantitative indicators not referring to any general or topic-specific disclosures of the GRI Standards, shown at the pages indicated in the Content Index, are not subject to limited examination by EY S.p.A.
This document was approved by the Board of Directors of TIM S.p.A. on March 15, 2023.
Disclaimer: This document has been translated into English for the convenience of the readers. In the event of discrepancy, the Italian language version prevails.
[GRI 2-1a] Telecom Italia S.p.A., also referred to as TIM S.p.A.
[GRI 2-1b] The Parent Company is TIM S.p.A., joint-stock company organized under the laws of the Republic of Italy and listed on the Italian stock exchange.
[GRI 2-1c] TIM S.p.A. has its registered office in Milan and branch office and general management in Rome.
[GRI 2-1d] The TIM Group operates mainly in Europe, Brazil and, to a limited extent, Asia as reported in the Annual Financial Report available on the Group website.
[GRI 2-2a] The Sustainability Report presents data and information that relate to the TIM Group.
[GRI 2-2b] In the Sustainability Report 2022, environmental performance data are presented excluding the following TIM Group companies: Olivetti Deutschland GmbH, Noovle International SAGL, Noovle Malta Ltd, Noovle Sicilia S.c.a.r.l., Panama Digital Gateway S.A., Staer Sistemi Srl, Mindcity, Trust Technologies, Telecom Italia San Marino S.p.A., Telefonia Mobile Sammarinese S.p.A.
[GRI 2-2c.i] The Sustainability Report presents the data and information that relate to TIM S.p.A. and its subsidiaries and fully consolidated companies as of December 31, 2022, as presented in the Annual Financial Report. The Consolidated Financial Statements as of December 31, 2022 of the TIM Group have been prepared in compliance with the recognition and measurement criteria of the International Financial Reporting Standards issued by the International Accounting Standards Board and endorsed by the European Union (referred to as "IFRS"), as well as with the laws and regulations in force in Italy.
[GRI 2-2c.ii] The Sustainability Report, like the Consolidated Financial Statements, does not report changes regarding minority interests. April 2022 saw the consolidation of the mobile assets of the Oi Group, into TIM S.A. (Brazil), following the completion of the acquisition for a total consideration of approximately 7 billion reais (1,741 million euros).
[GRI 2-2c.iii] Environmental performance data are presented excluding companies reported in [GRI 2-2b] that do not meet the materiality criteria. The list of material issues of economic, environmental and social impact is derived on the full scope of the TIM Group as reported in the Consolidated Financial Statements.
[GRI 2-3a] The TIM Group's Sustainability Report, prepared on an annual basis, corresponding to the calendar year, respects the same period as the Group's Consolidated Financial Statements.
[GRI 2-3b] The Group Consolidated Annual Report, like the Sustainability Report covers the period from January 1, 2022 to December 31, 2022.
[GRI 2-3c] The TIM Group Sustainability Report is published following its approval by the Board of Directors on 3/15/2023, at the same time as the Consolidated Financial Statements. The punctual date of publication is reported in the Methodological Note of this document.
[GRI 2-3d] The contacts are: Institutional Communication, Sustainability & Sponsorship of TIM S.p.A. Via G. Negri 1 10123 Milan, Italy Tel: +39 06 3688 5092; e-mail address: [email protected],
Web site: www.telecomitalia.com, Brazil: [email protected].
[GRI 2-4a.i] [GRI 2-4a.ii] There were no significant changes in the information reported in the years 2020 and 2021.
April 2022 saw the consolidation of Oi Group's mobile assets into the BU Brazil.
[GRI 2-5a, b] The selection of the auditor Ernst & Young ("EY") took place in 2018, based on the opening of a bidding process, following the applicable regulatory framework and taking into account that TIM S.p.A., as an Entity of Public Interest ("EIP"), is responsible for determining the selection process and preparing the bidding documents containing, among other things, the selection criteria. The Audit and Risk Committee, i.e., the Board of Statutory Auditors of TIM S.p.A. is responsible for the auditor selection procedure and validates the report prepared by TIM S.p.A. on the conclusions of the tender process. The auditor's appointment was endorsed by the TIM S.p.A. Shareholders' Meeting on March 29, 2019.
The current legislation (Legislative Decree 254/2016 transposing EU Directive 2013/34) requires the statutory auditor to verify the preparation of the Non-Financial Statement ("NFS") and the statutory auditor or other person authorized to perform statutory audits to verify the preparation of the Non-Financial Statement ("NFS") and to express his or her opinion about the compliance of the non-financial information with the prescribed methodologies and principles of preparation.
Bearing in mind that the subject of the audit service is the limited examination of the Consolidated Non-financial Statement of the TIM Group, the main audit procedures that the Auditor performs, both at the consolidated level and at the level of individual companies or divisions, are described within the section Responsibilities of the Auditor of the Audit Report.
In terms of the Company's responsibility, TIM S.p.A. proceeds to the preparation of the NFS and defines the design, implementation, and maintenance of an adequate internal control system for the preparation of a NFS that is not marred by significant errors due to fraud or unintentional behavior or events. It also issues, for each year of the audit, a certification letter, signed by the legal representative of TIM S.p.A., on the NFS compliance with the requirements of Articles 3 and 4 of Legislative Decree 254/2016 and the GRI Standards, on the reliability and completeness of the information and data contained therein, and on the truthfulness, completeness, and correctness of the documentation made available to the Auditors for their audits. The work is carried out by the Auditor in accordance with the provisions of the "International Standard on Assurance Engagements ISAE 3000 (Revised) - Assurance Engagements Other than Audits or Reviews of Historical Financial Information" (hereinafter "ISAE 3000 Revised"), issued by the International Auditing and Assurance Standards Board (IAASB) for limited assurance engagements. This principle requires planning and carrying out procedures in order to gain a limited level of confidence that the NFS will not contain significant errors. Therefore, the independent auditors, on the basis of the verification activities carried out and indicated in the Report itself, issue an audit report in which they state whether or not elements have come (or not) to their attention that suggest that the TIM Group NFS has not been prepared, in all significant aspects, in accordance with the requirements of Articles 3 and 4 of Legislative Decree 254/2016 and GRI Standards. This report is included in the Sustainability Report or NFS.
Finally, it should be noted that Legislative Decree 39/2010 in Art. 10 par. 1 "Independence and Objectivity" states that "The statutory auditor and the statutory auditing firm performing the statutory audit of a company must be independent of the company and must not be involved in any way in its decisionmaking process."
In this regard, it is confirmed that the TIM Group's auditing firm, EY, warrants that it is independent in accordance with the ethics and independence principles of the Code of Ethics for Professional Accountants issued by the International Ethics Standards Board for Accountants, which is based on the fundamental principles of integrity, objectivity, professional competence and diligence, confidentiality and professional behavior.
Finally, it should be noted that, based on the Guidelines for the Appointment of the Group's Single Auditor, TIM S.p.A., in order to protect the independence of the Auditors, restricts the appointment of further appointments to the same Single Auditor to services and activities strictly related to the audit of financial statements/reporting packages.
[GRI 2-6a] TIM is the leading ICT group at the forefront of digital technologies in Italy and in Brazil. It develops fixed fiber network infrastructure that it makes available to the entire market, both through a widespread presence throughout the country and through Sparkle internationally. More information is available at the link:https://www.gruppotim.it/en/group/about-us.html
[GRI 2-6b.i] The TIM Group offers individuals and households fixed-line and mobile services and products for communication and entertainment, and accompanies small and medium-sized enterprises toward digitalization with a portfolio tailored to their needs. Cloud, IoT and Cybersecurity are at the heart of TIM Enterprise's end-to-end solutions for businesses and Public Administration, which realize the country's digital transformation by taking advantage of the largest Data Center network in Italy, the expertise of Group companies such as Noovle, Olivetti and Telsy, and partnerships with leading groups.
In Brazil, TIM Brasil is a major player in the South American communications market and a leader in 4G coverage.
Group companies have implemented numerous initiatives to protect minors from content that may harm their mental and physical development (e.g.,
content that is violent, pornographic, racist, offensive to religious feelings, etc.). For BU Domestic, there were no revenues from the sale of adult-only services or gambling-related revenues in the year 2022.
In addition, through Fondazione TIM in Italy and Instituto TIM in Brazil, the Group supports projects of high social interest.
[GRI 2-6b.ii] The TIM Group's purchases take place mainly in the two geographic areas where the Group's main activities are based, Italy and Brazil, and are mostly directed towards the categories of products and services listed below:
The TIM Group, to its suppliers, recorded payments of a commercial nature, excluding payments made to Other Licensed Operators, of approximately 10 bn euros in 2022. In the Domestic BU, there are nearly 2,800 tier 1 suppliers in the supply chain (of which about 2,500 are local) and 1,800 tier 2 suppliers, for a total of about 4,600 suppliers(1).
Regarding Tier 2 suppliers, the value shown refers to the total number of subcontracted suppliers, within BU Domestic, for the Network, IT, TLC and IS perimeters.
(1) Supply chain data in BU Domestic pertains to the following companies: Telecontact Center S.p.A. - Olivetti S.p.A. - TI Sparkle S.p.A. - TI Trust Technologies S.r.l. - TI Ventures S.r.l. - Fibercop S.p.A. - TIM MY BROKER S.r.l. - TIM Servizi Digitali S.p.A. - Telecom Italia S.p.A. - Noovle S.p.A. - TI Sparkle Germany GmbH - TI Sparkle Netherlands BV - TI Sparkle France S.a.s. - TI Sparkle Austria GmbH - TI Sparkle Turkey - TI Sparkle Israel Ltd.
[GRI 2-6b.iii] Domestically, TIM represents the largest network infrastructure in the Country with FTTx network coverage of Real Estate Technical Units exceeding 94%, of which 32% is Fiber to the Home (FTTH). TIM operates its mobile network and it develops wholesale network infrastructure that it makes available to other TLC operators.
Internationally, TIM offers global services to fixed/mobile operators, media and contents, OTTs, ISPs and enterprises through its subsidiary Sparkle, which is present in 32 countries with 164 PoPs and more than 600,000 km of fiber.
By the end of 2022, in the consumer and business market in Italy, TIM is positioned as a "premium brand" in terms of quality and offerings, serving more than 8 million retail users on fixed-line access and reaching more than 30 million mobile lines.
Thanks to Noovle, Olivetti and Telsy factories, TIM Enterprise realizes end-toend solutions for Top customers and Public Administration companies in Italy, providing Connectivity, Cloud, IoT and Cybersecurity services.
TIM Brasil, as of December 2022, reaches a mobile customer base of more than 62 million with 100% coverage in 5,570 cities.
[GRI 2-6c] Polo Strategico Nazionale (www.polostrategiconazionale.it) is the company owned by TIM (45%), Leonardo (25%), CDP (20%) and Sogei (10%) whose mission is to build and manage a technologically innovative and independent cloud infrastructure to ensure security and economic and environmental sustainability in the management of data and applications of the Italian Public Administration.
[GRI 2-6d] TIM, in the domestic market, has decided to move from a vertically integrated operator structure to a new horizontal structure, divided into separate business entities: NetCo, the network that will also include domestic and international wholesale assets and activities; TIM Enterprise, dedicated to the segment of large Italian companies and the Italian Public Administration; and TIM Consumer, serving Italian households, individuals and small and mediumsized enterprises.
Such a strategy would mitigate risks related to regulatory constraints, reduce the level of debt, and optimize the focus on target markets.
In Brazil, as previously reported, there is the purchase of the mobile assets of the Oi S.A. Group.
| 2022 2021 |
2020 | ||||||||
|---|---|---|---|---|---|---|---|---|---|
| Total number of employees by gender and geographical area of the Group |
Men | Women | Total | Men | Women | Total | Men | Women | Total |
| Italy | 26,430 | 14,307 | 40,737 | 27,460 | 14,871 | 42,331 | 27,702 | 14,965 | 42,667 |
| Brazil | 4,644 | 4,751 | 9,395 | 4,629 | 4,696 | 9,325 | 4,736 | 4,673 | 9,409 |
| More | 185 | 60 | 245 | 195 | 62 | 257 | 197 | 60 | 257 |
| Total personnel to payroll | 31,259 | 19,118 | 50,377 | 32,284 | 19,629 | 51,913 | 32,635 | 19,698 | 52,333 |
| Personnel under contract of employment |
9 | 6 | 15 | 9 | 7 | 16 | 9 | 5 | 14 |
| Total personnel | 31,268 | 19,124 | 50,392 | 32,293 | 19,636 | 51,929 | 32,644 | 19,703 | 52,347 |
| 2022 | 2021 | 2020 | ||||
|---|---|---|---|---|---|---|
| Total number of employees by type of employment contract and gender in the Group |
Men | Women | Men | Women | Men | Women |
| Total number of employees | 31,259 | 19,118 | 32,284 | 19,629 | 27,891 | 15,020 |
| of which fixed-term | 111 | 93 | 111 | 87 | 71 | 68 |
| of which permanent | 31,148 | 19,025 | 32,173 | 19,542 | 27,820 | 14,952 |
| of which full time | 30,076 | 13,442 | 31,130 | 13,954 | 27,154 | 10,128 |
| of which part time | 1,183 | 5,676 | 1,154 | 5,675 | 737 | 4,892 |
| 2022 | |||||
|---|---|---|---|---|---|
| Total number of employees by type of employment contract and geographic area of the Group |
Italy | Brazil | Other | ||
| Total number of employees | 40,737 | 9,395 | 245 | ||
| of which fixed-term | 203 | 1 | 0 | ||
| of which permanent | 40,534 | 9,394 | 245 | ||
| of which full time | 35,633 | 7,643 | 242 | ||
| of which part time | 5,104 | 1,752 | 3 |
The new breakdown by geographical area is available from 2022; employees in Italy in 2021 were 42,331 and in 2020 42,667; abroad 9,582 in 2021 and 9,666 in 2020.
[GRI 2-7b.iii] There are no employees with discontinuous employment contracts in the Group.
[GRI 2-7c] For TIM S.p.A., Telsy, Telecontact, TI Sparkle, TI Trust Technologies, Olivetti, Noovle, and Fibercop, the survey was conducted by extrapolating data from the Group's IT systems. Data from other companies in the Group are provided directly by the companies themselves.
Data are expressed in head count. The average annual whole-head count was calculated by applying the arithmetic mean, for each type of staff, to the number of heads present at the end of each month of the year.
[GRI 2-7d] The data shown refer to head count present as of December 31, 2022 in TIM Group companies, broken down by each cluster and type of survey (by gender, contract type, hourly type, and territorial breakdown).
[GRI 2-7e] Compared to December 31, 2021 (51,913 heads), there is an overall decrease of 1,536 heads, of which 5,416 heads left the Group and 3,583 heads entered.
[GRI 2-9a] The TIM Group's governance system is organized according to the traditional model and provides for a governing body (Board of Directors - BoD) which, as a rule, is organized through the establishment of internal committees, either stable or set up for specific operations. There is also a control body (Board of Statutory Auditors).
[GRI 2-9b] The BoD approved the establishment of the following internal committees:
Each committee has its own regulations, approved by the BoD, in which the rules for its composition and appointment, operating rules, duties, powers are defined. Regulations of committees are available on the Group website.
[GRI 2-9c.i] As of December 31, 2022, the BoD consists of 1 executive member (CEO) and 14 non executive members (including the Chairman of the BoD). Please refer to the Group website (www.gruppotim.it) for any updates.
[GRI 2-9c.ii] As of December 31, 2022, the Board of Directors consisted of 15 members, 10 of whom were independent. On January 16, 2023, Arnaud Roy de Puyfontaine resigned as Director of the Company. As of the date of publication of this report, the BoD thus consists of 14 members, 10 of whom are independent. For any updates, please refer to the Group website (www.gruppotim.it).
[GRI 2-9c.iii] On March 31, 2021, the Shareholders' Meeting renewed the administrative body for the three-year period 2021-2023. Detailed information is available on the Group website (www.gruppotim.it).
[GRI 2-9c.iv] According to TIM's Corporate Governance Principles, it is not considered compatible with serving as a Director of TIM to hold directorships or supervisory positions in more than five companies, other than those subject to TIM's management and coordination or controlled by or affiliated with TIM, when they are (i) listed companies included in the FTSE/MIB index, or (ii) companies operating predominantly in the financial sector dealing with the public sector, or (iii) companies that perform banking or insurance activities.
In the case of Executive Directors in companies with the characteristics listed above, the limit is reduced to three of which under (i), (ii) and (iii).
There are no diversified thresholds to account for Directors' participation in board committees. If a Director holds offices in more than one company belonging the same group, only one appointment held within that group shall be taken into account when calculating the number of appointments.
More detailed information is available in the Report on Corporate Governance and Ownership Structure, published on the Group's website.
[GRI 2-9c.v] Article 9.1 of the Bylaws was applied in the appointment of Board members last March 31, 2021, which requires the presence on the BoD of members of the least represented gender in an amount of at least two-fifths of the total. As of December 31, 2022, female representation on the Board is six out of 15 Directors. Please refer to the Group website (www.gruppotim.it) for any updates.
In view of the preparation of the lists, a special guidance document to TIM shareholders on the composition of the BoD has been published (available on the Group's website), which sets as a priority objective the adequate competence and professional path of the members of the administrative body.
[GRI 2-9c.vi] TIM is in favor of diversity in the composition of the BoD, including the overriding goal of adequate competence and professional path of its members. Discrimination on the basis of ethnicity, nationality, country of origin, gender, sexual orientation, religion, political or other views is excluded.
No specific diversity policies have been adopted in relation to the composition of the BoD, the matter being deemed to be devolved to the shareholders, in the exercise of the rights of candidacy attributed to them by law and the Statute, with respect to the lists submitted by them, or to the responsibility of the outgoing Board, in the event of the exercise of the right to submit its own list, with disclosure of the selection process and the criteria by which it was governed.
[GRI 2-9c.vii] Curricula vitae and detailed information on current Directors of the Board are available on the Group website (www.gruppotim.it).
[GRI 2-9c.viii] The only stakeholders represented on the BoD are the shareholders.
[GRI 2-10a] Pursuant to TIM's Statute and Corporate Governance Principles, the BoD is appointed by the Shareholders' Meeting. Appointments are made in accordance with applicable statutory and regulatory provisions on the basis of lists submitted by shareholders or the outgoing BoD. The BoD establishes committees from among its members, composed of non executive Directors, the majority of whom are independent, with advisory and proposal-making functions, determining their powers and responsibilities.
[GRI 2-10b.i] Pursuant to the Statute, only shareholders who alone or together with other shareholders hold a total of shares representing at least 0,5% of the share capital entitled to vote at the Ordinary Shareholders' Meeting, or the lesser amount required by the regulations issued by the National Commission for Companies and the Stock Exchange, are entitled to submit lists.
[GRI 2-10b.ii] Article 9.1 of the Statute was applied for the appointment of the members of the Board last March 31, 2021, which requires the presence on the Board of members of the least represented gender to be at least two-fifths of the total. As of December 31, 2022, female representation on the Board is six out of 15 Directors. Please refer to the Group website (www.gruppotim.it) for any updates.
[GRI 2-10b.iii] Pursuant to the Statute, at least half of the directors drawn from each list must meet the independence requirements of Article 148 of Legislative Decree 58/1998 and/or the Corporate Governance Code of Borsa Italiana.
[GRI 2-10b.iv] The curricula vitae and skills summary (skill matrix) of Board members can be viewed on the Group website (www.gruppotim.it).
[GRI 2-11a] The Chairman of the BoD does not hold executive positions within the organization.
[GRI 2-11b] Not Applicable
[GRI 2-12a] The BoD plays a strategic guidance and oversight role, pursuing the overriding objective of shareholder value creation over a medium- to long-term horizon, while also taking into account the legitimate interests of the remaining stakeholders, with a view to the sustainable success of the Company. The BoD has established the Sustainability Committee with advisory, propositional, monitoring and investigative tasks to support and guide the activities of the board plenum and management, on the environmental, social and governance (ESG) aspects in terms of positioning, objectives, processes, and specific initiatives of the Group. In addition, as per the regulations, with respect to board processes, in addition to operating in direct support and direction of the activities of the board plenum, the Sustainability Committee is promptly involved with reference to the ESG profiles of the activities overseen by the remaining committees.
Specifically, the Committee interacts:
[GRI 2-12b] The BoD, throught the Sustainability Committee, assesses ESG oversight, defines the materiality/impact matrix, monitors ongoing corporate initiatives on the sustainability front, and defines ESG goals (starting with environmental ones, with specific focus on energy), according to overall corporate planning.
[GRI 2-12b.i] The Sustainability Committee, as a result of the reorganization of sustainability activities within the Group that took place during 2022, oversaw the new process for defining material issues of impact that redesigned the Group's stakeholder engagement.
More generally, TIM adopted in December 2020 the Engagement Policy by which the dialogue with the generality of stakeholders (customers, suppliers, Public Administration, employees, business community) was formalized; the Policy is consistent with the recommendations of the Corporate Governance Code of Borsa Italiana.
[GRI 2-12b.ii] [GRI 2-12c] The outcome of the processes are evaluated by the BoD periodically, and at least, for each financial year, when planning and reporting on ESG objectives as well as when preparing the annual NFS (Sustainability Report). The set of principles and rules that guide the execution of activities aimed at the pursuit of corporate objectives, the management of associated risks, and control and monitoring activities are defined within the regulatory tools (Policies, Procedures and Operating Instructions) that the Group adopts and disseminates to the entire organization, considering them fundamental knowledge management tools. In addition, roles and responsibilities related to the planning, execution and control of business activities are assigned to TIM personnel ensuring the necessary information flows, in accordance with defined hierarchical lines, role diversity and corporate mission.
[GRI 2-13a.i] Responsibility relating to the overall governance of the Company and the Group is assigned to the Chief Executive Officer, subject to the prerogatives reserved to the BoD by law, by TIM's Corporate Governance Principles, or by specific Board determinations.
Sustainability matters are handled by the Institutional Communication, Sustainability & Sponsorship Function, which reports directly to the CEO. The oversight of sustainability issues is also present in the mandate of the Functions that have the management of the organization's impacts on the economy, environment and people (Chief Human Resources & Organization Office, Procurement, Chief Network, Operations & Wholesale Office, etc.).
[GRI 2-13a.ii] As part of the Institutional Communication, Sustainability & Sponsorship Function, the new organizational structure 'Sustainability' was established in April 2022, representing a single function dedicated to the guidance, management and monitoring of the Group's sustainability policies and enabling to overview all aspects into which sustainability is declined - sustainability plan, projects and reporting - to be addressed organically, making the relationship between ESG planning and reporting continuous and fluid.
[GRI 2-13b] During 2022, the Sustainability Committee met with the head and the Institutional Communication, Sustainability & Sponsorship team at all meetings, regarding which the Chairman provided specific briefings to the BoD. The latter met with the Sustainability team at the approval of the NFS 2021.
[GRI 2-14a] The BoD annually approves the Sustainability Report based on the Sustainability Reporting Guidelines of the Global Reporting Initiative (GRI), bearing TIM's Consolidated Non-financial Statement, pursuant to Legislative Decree 254/2016.
This approval is preceded by a special investigation by the Audit and Risk Committee-which instructs financial and non-financial reporting for the periodand the Sustainability Committee.
For 2022 reporting, the process, carried out under the supervision of the endoconsiliar committees, led to the definition of a new NFS structure that better correlates sustainability projects with the Group's ESG Plan.
At its meeting on October 14, 2022, the Audit and Risk Committee approved the 2022 materiality/impact matrix, the basis for 2022 reporting.
[GRI 2-14b] Not Applicable
[GRI 2-15a] As per the Company's Corporate Governance Principles, the members of the corporate bodies take their decisions independently, in the interest of the issuer and the generality of shareholders, giving timely disclosure of any extrasocial interest they may have with respect to the transactions submitted to their examination for deliberative, propositional, investigative, advisory or control purposes. The Rules of the Board of Directors, published on the Group's website, regulate how to handle situations in which a Director has an interest, on his own behalf or on behalf of third parties, in a given transaction, in terms of information segregation, abstention from taking part in the board discussion and voting on the same. In compliance with the Consob Related Parties Regulations, the Company has, in addition, adopted a procedure for conducting transactions with related parties, which can be consulted on the Group website.
[GRI 2-15b] Disclosure of related party transactions in the reporting period is included in the Annual Financial Report, under Related Party Transactions.
[GRI 2-16a] The Board of Statutory Auditors and the Audit and Risk Committee of TIM S.p.A. are periodically informed about the whistleblowing activity carried out through a summary report. Each semester, the Supervisory Board of TIM S.p.A. prepares a report, sent to the Company's Top Management and Control Bodies, summarizing the activities carried out, as well as a summary report of the reports received and the main initiatives taken.
[GRI 2-16b] In 2022, 100 reports were received in Italy and 1,291 in Brazil. As for Italy, the 100 complaints, including 24 anonymous and 76 non-anonymous, are grouped as follows:
Information on historical data is available at the following link:
https://www.gruppotim.it/en/group/governance/governance-tools/whistleblowing.html. In addition to the above numbers (i.e., whistleblowing numbers), during FY2022, the Board of Statutory Auditors received 15 reports directly, mostly complaining about technical inefficiencies and deficiencies of a commercial and administrative nature, as well as 4 complaints under Article 2408 of the Civil Code. On all such reports and complaints, the Board of Statutory Auditors carried out, with the support of the relevant offices of the Company, the appropriate investigations.
In the case of Brazil, of the 1.291 reports, 635 were anonymous and 656 were nonanonymous, classified as follows:
[GRI 2-17a] The Institutional Communication, Sustainability & Sponsorship Function constantly updates the Sustainability Committee on sustainable development issues, which reports to the board plenum.
[GRI 2-18a] The Board assesses annually, through formalized procedures, its effectiveness and the contribution of individual Directors including with regard to ESG issues. The results of this assessment are reported in the Annual Report on Corporate Governance and Ownership published on the Company's website (www.gruppotim.it).
(2) Of which 559 were "managerial" (processes that can be improved, etc.) and 247 from TIM S.A. (employees in crisis situations).
[GRI 2-18b] For the annual self-assessment of the Board and its Committees, the Society uses an independent external advisor.
[GRI 2-18c] Based on the evidence, the BoD identifies specific follow-up initiatives. As an example, a specific induction session on corporate governance issues was organized.
[GRI 2-19a] The policy on Directors' remuneration is defined in line with legal regulations and statutory provisions under which:
Shareholders' Meeting on compensation plans based on the award of financial instruments to directors and employees and for preparing the Remuneration Report.
[GRI 2-19a.i] Except for the CEO, directors receive only fixed compensation. More details at the following link:
https://www.gruppotim.it/en/group/governance/remuneration/policy.html.
Details of the components of fixed and variable remuneration (including any equity component), benefits and termination treatment awarded to the CEO and key management personnel are detailed in the Remuneration Report (for key management personnel the figure is in aggregate form) and available, in summary form, at the following link:
https://www.gruppotim.it/en/group/governance/remuneration/policy.html.
[GRI 2-19a.ii] For key management personnel, the awarding of bonuses untied by performance conditions is excluded. TIM exceptionally reserves the right to pay lump sums at the hiring stage in order to encourage the acquisition of resources possessing specific skills deemed essential for the achievement of strategic business objectives and who have accrued the right to specific deferred compensation from the Companies of origin.
[GRI 2-19a.iii] There are no notice/termination treatments for Board members. This is without prejudice to what may be provided in relation to the office of General Manager, held by the Chief Executive Officer.
The notice period for senior executives is set in the national collective bargaining agreement and differentiated according to seniority; it can be up to a maximum of 12 months.
Severance payments for senior executives are determined by law and the national collective bargaining agreement, with a maximum of 24 months' additional monthly payments.
Any mitigation clauses are included in the termination agreements.
As per policy, for Executive Directors, in the event of termination without just cause, an indemnity equal to the remuneration due for the office is paid until the natural expiration of the term of office, with a maximum of 24 monthly payments (calculated as the sum of the fixed and MBO component). With respect to the termination of the employment contract, the severance payment established by law and the national collective bargaining agreement is provided, with recognition of additional monthly payments in the maximum number of 24 (calculated on the fixed component). In the event of termination of the employment relationship of executives with strategic responsibilities, in the absence of just cause for dismissal, it will be the responsibility of the CEO to identify the resources that - due to the relevance and strategic nature of the role held - may be recipients of severance pay, to which a non-competition agreement may be associated, depending on the relevance and strategic nature of the role held, for a maximum period of one year calculated on the fixed remuneration.
[GRI 2-19a.iv] In the three years following the payment of the variable compensation component award, the clawback clause of the disbursed amounts may be activated, as per policy.
[GRI 2-19a.v] Details of the components of fixed and variable remuneration (including any equity component), benefits and termination treatment awarded to the CEO and key management personnel are detailed in the Remuneration Report (for key management personnel the figure is in aggregate form) and available, in summary form, at the following link:
https://www.gruppotim.it/en/group/governance/remuneration/policy.html.
[GRI 2-19b] The goals assigned to the CEO, for 2022, are economic-financial and ESG. Details are available at the link:
https://www.gruppotim.it/en/group/governance/remuneration/policy.html.
The TIM Group's remuneration policy is aimed at supporting the achievement of the guidelines set out in the Company's Strategic Plan by adopting an appropriate balance of performance parameters of the short-term and long-term incentive systems for the achievement of strategic objectives.
The short-term and long-term incentive systems include both economic-financial targets derived from the three-year Business Plan for the period, targets linked to share performance, and ESG targets.
With regard to the MBO system, for 2022, the ESG target was confirmed with a weight of 22%, both for the CEO, for key executives and for all incentivized personnel, highlighting the centrality of the two essential stakeholders for the Company, external customers (with Customer Satisfaction goals) and employees (with Employee Engagement and Gender Pay Gap goals).
Like the long-term incentive plans launched in 2020 and 2021, the 2022-2024 stock option plan also combines macroeconomic and equity targets with two growth targets on the gender gap and renewable energy consumed, with a combined weight of 30%.
[GRI 2-19a.iii] There are no notice/termination treatments for the BoD (this is without prejudice, of course, to what may be provided in relation to the position of General Manager, held by the CEO).
[GRI 2-20a.i] The Remuneration Policy is approved by the Board, upon the proposal of the Nomination and Remuneration Committee, which is composed exclusively by independent directors, and is submitted to the Shareholders' Meeting, which is called upon to express a binding vote on the matter.
[GRI 2-20a.ii] TIM values dialogue with its shareholders and institutional investors on compensation issues, aware of the importance of shareholder involvement in both the definition and verification of the implementation of the Policy for the Remuneration of Directors and Executives with strategic responsibilities.
Of particular importance is the analysis on assembly voting. Dialogue with its shareholders and institutional investors is conducted through various communication tools and channels, including meetings, conference calls, and the concluding shareholders' meeting event supported by the provision of detailed and complete information.
[GRI 2-20a.iii] In order to carry out its functions, the Committee (whose meetings are attended by the Chairman of the Board of Statutory Auditors or, in the event of his inability, another Statutory Auditor designated by him) avails itself of the collaboration of the competent structures of the Company (mainly Chief Human Resources & Organization Office, Chief Financial Office) and may avail itself of the support of external consultants independent of the members of theBoD and of the Top Management. Details of activities, broken down by quarters are available at the following link:
https://www.gruppotim.it/en/group/governance/remuneration/policy.html.
[GRI 2-20b] The summary report of Shareholders' Meeting voting on agenda items, including Remuneration Policy, can be found on the Group website. In particular, the findings of the last Shareholders' Meeting - on remuneration policies and proposals - are available at the following link:
https://www.gruppotim.it/en/investors/shares/agm/assembly-7-04-22.html.
| [GRI 2-23a.i] | [GRI 2-23a.ii] | [GRI 2-23a.iii] | [GRI 2-23a.iv] | [GRI 2-23b.i] | [GRI 2-23b.ii] | |
|---|---|---|---|---|---|---|
| The intergovernmental reference instruments |
Due diligence | Application of the precautionary principle |
Respect for Human Rights |
Internationally recognized human rights |
Stakeholders to whom TIM pays special attention |
|
| Code of Ethics and conduct of the Group |
Global Compact: TIM has joined the Global Compact sponsored by the Organization for the United Nations. |
Based on risk assessment, the Company provides specific due diligence processes with respect to commitments made. |
Application of the precautionary principle not explicitly stated. |
Yes. | TIM S.p.A. has adhered to the Global Compact promoted by the United Nations Organization on human rights, labor standards, environmental protection and anti corruption, and ensures full implementation of this institutional commitment through the implementation of timely initiatives on environmental and social issues. |
The Group's Code of Ethics and Conduct addresses the following stakeholders: People, Third Parties, Customers, Suppliers, Business Community, Institutions and Regulatory Bodies, Financial Community and Civil Society. |
| [GRI 2-23a.i] | [GRI 2-23a.ii] | [GRI 2-23a.iii] | [GRI 2-23a.iv] | [GRI 2-23b.i] | [GRI 2-23b.ii] | |
|---|---|---|---|---|---|---|
| The intergovernmental reference instruments |
Due diligence | Application of the precautionary principle |
Respect for Human Rights |
Internationally recognized human rights |
Stakeholders to whom TIM pays special attention |
|
| Policy Respecting Human Rights in the TIM Group |
- UN Universal Declaration of Human Rights, 1948; - UN International Covenant on Civil and Political Rights, 1976; - UN International Covenant on Economic, Social and Cultural Rights, 1976; - UN Human Rights Council, Guiding Principles on Business and Human Rights: Implementing the United Nations "Protect, Respect and Remedy" Framework, A/HRC/17/31, 2011; - UN Global Compact, 1999; - International Labor Organization, Declaration on Fundamental Principles and Rights at Work, 1998; - International Labor Organization Tripartite Declaration of Principles concerning Multinational Enterprises and Social policy; - European Commission, ICT Sector Guide on Implementing the UN Guiding Principles on Business and Human Rights; 2013; - OECD, Guidelines for Multinational Enterprises, 2011. |
TIM carried out due diligence on Human Rights using the OCAI (Organisational Capacity Assessment Instrument) tool created by Twentyfifty Ltd. with funding from the Global Compact Network Germany Foundation. |
Application of the precautionary principle not explicitly stated. |
Yes, basically all of them (with high attention to those impacted by virtue of TIM's core business, i.e., the protection of privacy of customers and employees, the right to freedom of expression especially online freedom of expression-the rights potentially violated by value added services including services with adult-only content and gambling). |
All internationally recognized Human Rights. |
All stakeholders, including vulnerable groups (e.g., minors, elderly, disabled, supplier workers, etc.). |
| [GRI 2-23a.i] | [GRI 2-23a.ii] | [GRI 2-23a.iii] | [GRI 2-23a.iv] | [GRI 2-23b.i] | [GRI 2-23b.ii] | |
|---|---|---|---|---|---|---|
| The intergovernmental reference instruments |
Due diligence | Application of the precautionary principle |
Respect for Human Rights |
Internationally recognized human rights |
Stakeholders to whom TIM pays special attention |
|
| Anti-Corruption Policy |
National and international regulations such as FCPA and UK Bribery Act. |
Yes, TIM S.p.A. carries out due diligence activities on third parties, and during 2022, no red flags attributable to bribery hypotheses were revealed. |
Application of the precautionary principle not explicitly stated. |
The Anti-Corruption Policy does not deal with issues related to Human Rights, which are dealt with in the separate Policy "Respecting Human Rights in the TIM Group." |
The Anti-Corruption Policy does not deal with issues related to Human Rights, which are dealt with in the separate Policy "Respecting Human Rights in the TIM Group." |
The Anti-Corruption Policy does not deal with issues related to Human Rights, which are dealt with in the separate Policy "Respecting Human Rights in the TIM Group." |
| Fiscal Strategy | OECD "Co-operative Compliance - A Framework; From Enhanced Relationship to Co-operative Compliance"; OECD GUIDELINES "Building better tax control framework. |
Not applicable. | Not applicable. | Not applicable. | Not applicable. | Not applicable. |
| Whistleblowing procedure |
- Legislative Decree No. 231/01 "Regulations on the administrative liability of legal persons, companies and associations, including those without legal personality, pursuant to Article 11 of Law No. 300 of September 29, 2000" - Regulation (EU) No. 2016/679 on the protection of personal data (c.d. GDPR) - Legislative Decree 196/03 and subsequent amendments and additions, as well as related legislative provisions - Law No. 179 of November 30, 2017 "Provisions for the protection of the authors of reports of crimes or irregularities of which they have become aware in the context of a public or private employment relationship." |
The procedure does not include due diligence processes by external agencies. |
Not applicable. | The whistleblowing procedure governs the process of receiving and handling reports also inherent in the failure to respect human rights. |
The procedure covers the following types of human rights as defined in the Group Human Rights Policy: human rights in general non-discrimination * labor issues. |
The whistleblowing procedure applies to all stakeholders. |
| [GRI 2-23a.i] | [GRI 2-23a.ii] | [GRI 2-23a.iii] | [GRI 2-23a.iv] | [GRI 2-23b.i] | [GRI 2-23b.ii] | |
|---|---|---|---|---|---|---|
| The intergovernmental reference instruments |
Due diligence | Application of the precautionary principle |
Respect for Human Rights |
Internationally recognized human rights |
Stakeholders to whom TIM pays special attention |
|
| Policy Human Resources, Organization & Real Estate TIM Group |
The Group's commitment to the respect and protection of Human Rights and labor standards is reaffirmed in the Code of Ethics, the Human Rights Respect Policy and the Group Organizational Model, which are inspired by the ten Principles of the UN Global Compact on Human Rights, Labor Standards, Environmental Protection and Anti-Corruption. |
Yes, the commitments include due diligence because all activities that may adversely affect compliance with Human Rights are subject to periodic internal due diligence, carried out on the basis of the Guiding Principles on Business and Human Rights, approved by the UN Human Rights Council in June 2011. |
Should the self assessment process reveal a situation of potential risk with reference to the Human Rights issue, the function concerned is required to communicate the relevant action plan for the purpose of monitoring its progress. |
The TIM Group is committed to being a proactive leader in Human Rights related initiatives and networks at both local and international levels, both sectoral and cross-sectoral. |
The TIM Group applies the "Code of Ethics and Conduct of the TIM Group," the policy "Respecting Human Rights in the TIM Group," the policy "Managing Incidents of Gender, Sexual and Bullying Harassment," and the operating procedure "Adaptation of Workstations and Work Environments for Persons with Disabilities or Chronic Illnesses - Disabling," and also adheres to the United Nations Global Compact. |
The Group's commitment to Human Rights is stated in the Code of Ethics and Conduct and in all relevant policies, such as those concerning Human Resources, Sustainability in the TIM Group, suppliers, and customers, particularly the most vulnerable (e.g., minors and the disabled). |
| [GRI 2-23a.i] | [GRI 2-23a.ii] | [GRI 2-23a.iii] | [GRI 2-23a.iv] | [GRI 2-23b.i] | [GRI 2-23b.ii] | |
|---|---|---|---|---|---|---|
| The intergovernmental reference instruments |
Due diligence | Application of the precautionary principle |
Respect for Human Rights |
Internationally recognized human rights |
Stakeholders to whom TIM pays special attention |
|
| Products and services purchasing policy |
Internal references such as: Code of Ethics and Conduct, in the 231 Organizational Model, TIM's Anti-Corruption Management System, the Group Anti-Corruption Policy and the Policy "Respecting Human Rights in the TIM Group." |
Application of sustainability principles in supplier selection and monitoring processes. The level of compliance with the principles is assessed and measured in the supplier evaluation/ control processes and in the selection of services/products, with specific operational methods for each acquisition/supplier category. Also in cooperation and through agreements with partners or other telecom operators, such as under the Joint Audit Cooperation - JAC initiative (http:// jac-initiative.com) of which TIM is a founding member. |
Application of the precautionary principle not explicitly stated. |
Yes. | The purchasing process aims to ensure, throughout the supply chain, constant compliance with TIM Group's values of ethicality and sustainability, requiring similar formal commitment from suppliers and promoting, through them, respect for legality, human and personal rights, environmental sustainability and occupational health/ safety and the provisions of TIM's Anti-Corruption Management System. To this end, contracts must always provide that TIM and the TIM Group Companies reserve the right to carry out verification and audit activities on suppliers and the services they are responsible for, in compliance with the regulatory and procedural framework in force. |
The Code of Ethics and Conduct, Organizational Model 231, TIM's Anti Corruption Management System, Group Anti Corruption Policy, and the Policy "Respecting Human Rights in the TIM Group" set out the basic principles underlying the TIM Group's commitment to respecting the environment, protecting human rights and labor standards, and fighting corruption. |
| [GRI 2-23c] | [GRI 2-23d] | [GRI 2-23e] | [GRI 2-23f] | |
|---|---|---|---|---|
| Link | Approval or last update | Extension of commitment | Communication of commitment | |
| Telecom Italia Group Code of Ethics and Conduct |
code-ethics.html | BoD - October 3, 2013. It should be noted that the Company is in the process of adopting a new version of the Code of Ethics and Conduct, which is soon to be approved by the Board of Directors. |
Commitments cover all TIM Group activities for which the Code of Ethics and Conduct is directly applicable. |
Commitments are communicated to all stakeholders through: the institutional website, the corporate intranet, as well as the appropriate inclusion of contractual clauses regarding the acknowledgment and/or compliance with the Group Code of Ethics and Conduct. |
| Policy Respecting Human Rights in the TIM Group |
policy-diritti-umani.pdf | Chairman of the Board, September 29, 2015. |
TIM Group activities and related value chain. |
The policy-drafted in Italian, English and Portuguese-was communicated to the Group's people, suppliers and partners through the TIM website, and was discussed within the German and Italian networks of the UN Global Compact. |
| Anti-Corruption Policy |
anti-corruption-system.html | The latest version of the Anti Corruption Policy was approved by the Board of Directors of TIM S.p.A. on February 14, 2022. |
The Anti-Corruption Policy applies to TIM S.p.A. and members of corporate bodies, employees and collaborators in various capacities of the Company. The Policy applies to TIM Group Subsidiaries and TIM Foundation: domestic and foreign listed companies and companies certified under UNI EN ISO 37001 may implement this Policy by establishing their own policies in compliance with the principles stated in the Policy. In relation to joint ventures and Subsidiaries, TIM will use its influence, to the extent reasonable under the circumstances, to ensure that these companies and entities comply with the standards and rules of conduct set out in the Anti-corruption Policy. The Policy is intended to be known by: - TIM's employees, management and members of corporate bodies - Subsidiaries and/or Subsidiaries - Third Parties - Certification Bodies. |
Commitments are communicated through: the institutional website, the corporate intranet, as well as the appropriate inclusion of contractual clauses regarding acknowledgment and/or compliance with the Group Anti Corruption Policy. In addition, TIM S.p.A. publishes on the Group Supplier Portal the Code of Ethics and Conduct, the Anti-Corruption Policy and the Anti-Corruption Manifesto. |
| [GRI 2-23c] | [GRI 2-23d] | [GRI 2-23e] | [GRI 2-23f] | |
|---|---|---|---|---|
| Link | Approval or last update | Extension of commitment | Communication of commitment | |
| Fiscal strategy | Not applicable. | BoD December 15, 2022. | TIM Group. | It is made public on the Group's website. |
| Whistleblowing procedure |
Whistleblowing-Procedure.pdf | The current whistleblowing procedure (currently under review) was approved by the TIM Board of Directors on November 10, 2020. |
The procedure applies to any business relationship. |
When a new version is issued, notice is given, including by e-mail, to employees. |
| Policy Human Resources, Organization & Real Estate TIM Group |
Policy-Human-Resources-ENG.pdf | The policy Policy HRO - TIM Group was approved by the Head of HRO Function in April 2021. |
All TIM Group people and "workers" in its value chain. |
The policy under review has been communicated to Group people, suppliers and partners, and has been discussed in the German and Italian UN Global Compact Networks and is on the institutional website. |
| Products and services purchasing policy |
Suppliers-policy-2019.pdf | The following first management carryovers: Procurement, Human Resources, Compliance and Legal Departments. |
Group companies and TIM Foundation. |
Addressees of the Policy are TIM S.p.A., the TIM Foundation and TIM Group Companies. |
| [GRI 2-24a.i] | [GRI 2-24a.ii] | [GRI 2-24a.iii] | [GRI 2-24a.iv] | |
|---|---|---|---|---|
| Responsibility for the implementation of commitments |
Integration of commitments into organizational strategies, policies, and operating procedures |
Implementation of commitments with and through business relationships |
Training | |
| Group Code of Ethics and Conduct |
TIM S.p.A. and the companies of the TIM Group have an efficient and effective internal control and risk management system, in which the correct definition of tasks and responsibilities, the separation of roles with a consistent approach to operational delegations, the traceability of acts and transactions, the reliability of financial information, as well as compliance with laws, regulations and internal procedures are particularly important. |
Policies, procedures, regulations and internal instructions, adopted at the company level and defined according to a specific procedural system structure, are aimed at ensuring that the values of the Code of Ethics and Conduct are reflected in the behavior of Group Companies and all its recipients. To this end, penalty systems for possible violations of the aforementioned Code shall be provided for and applied where appropriate and subject to compliance with the regulations in force. |
TIM S.p.A. inserts a special clause dedicated to taking vision/ observance of the Group's Code of Ethics and Conduct in stipulated contracts and carries out due diligence activities on Third Parties. |
A specific section devoted to the Code of Ethics and Conduct was included in the training course on Organizational Model 231. As of December 31, 2022, this course has been completed by 29,343 employees of TIM S.p.A. and domestic subsidiaries and is being completed by the remaining employees (on target). In addition, planning has begun for specific training on the new Code of Ethics and Conduct (in the process of being approved) to take place in 2023. |
| Policy Respecting Human Rights in the TIM Group |
The Human Resources & Organization Function is responsible for compliance with this document as it relates to the involvement of TIM people, the Procurement Function is responsible for compliance with it as it relates to the involvement of TIM suppliers, the Compliance Function oversees the risk of non-compliance with relevant regulations, and the Sustainability Function is responsible for updating the policy, involving stakeholders. |
All TIM Group functions are encouraged to explicitly refer to this policy (and Human Rights) in their operating policies and procedures and management systems (e.g., with respect to the environment, health and safety, and nondiscrimination). |
The TIM Group supports and encourages its partners to approve: - UN International Charter of Human Rights; - the Declaration on Fundamental Principles and Rights at Work, issued by the ILO; - the Guiding Principles on Business and Human Rights approved by the UN Human Rights Council; - the Guidelines for Multinational Enterprises, issued by the OECD; - the ISO 26000 Guidelines. |
Online (In)training course on Human Rights and more. |
| [GRI 2-24a.i] | [GRI 2-24a.ii] | [GRI 2-24a.iii] | [GRI 2-24a.iv] | |
|---|---|---|---|---|
| Responsibility for the implementation of commitments |
Integration of commitments into organizational strategies, policies, and operating procedures |
Implementation of commitments with and through business relationships |
Training | |
| Anti-corruption Policy |
The BoD has identified the Compliance Department as the Compliance Function for the prevention of corruption, which is responsible for implementing and monitoring the Anti-Corruption Management System within the corporate organization and, more generally, for ensuring that the Anti-Corruption Management System complies with the requirements of the ISO 37001:2016 Standard. In particular, the Compliance Function supports the 231 Steering Committee and TIM Management in the implementation of the Anti-Corruption Management System. In addition to the aforementioned Compliance Function, TIM S.p.A., in order to ensure the effectiveness of its activities in preventing and combating Bribery, has assigned the leadership of its Anti-corruption Management System to the following corporate entities: 1) the Board of Directors and the Audit and Risk Committee play the role of the Governing Body according to ISO 37001 2) the 231 Steering Committee plays the role of Senior Management according to ISO 37001 and has overall responsibility for the operation of the Anti-Corruption Management System, ensuring the definition of initiatives for the effective adoption of the Anti-Corruption Management System by the relevant business functions. 3) Management ensures that the requirements of the Anti-Corruption Management System are implemented and complied with in the areas of responsibility. |
The Anti-Corruption Management System includes an organic set of objectives with three levels: 1) Strategic Objectives: these are the general objectives of the Anti Corruption Management System, referable to the Code of Ethics and Conduct and declined in the Anti-Corruption Policy, the pursuit of which is the responsibility of the corporate bodies, all TIM personnel and Third Parties in business relations with the Company. 2) Organizational objectives: these objectives, identified in the Anti-Corruption Policy in relation to the processes at risk, consist of the implementation of all the organizational measures provided therein 3) Operational objectives and planning: these are the objectives reflected in the Anti Corruption Management System Plan prepared by the Compliance Department, which considers the balance of the activity carried out during the year and plans the activities to be carried out in the following year. |
TIM publishes the Group's Code of Ethics and Conduct, Anti-Corruption Policy and Anti-Corruption Manifesto on the Group's supplier portal and includes a special "anti-corruption clause" in the contracts it enters into, under which it requires compliance with both anti corruption regulations (including U.S.- FCPA - and British - Bribery Act - regulations) and adopted Anti-Corruption Policies. Finally, the Company carries out due diligence activities on Third Parties. |
Anticorruption training is provided through an e-learning course open on the internal training platform "TIM Academy" and accessible to all employees of TIM S.p.A. and the Group's domestic subsidiaries. In addition, specific training on the subject is provided in the webinar track dedicated to new hires. As of December 31, 2022, e-learning training on the 231 Organizational Model has beencompleted by 29,343 employees of TIM S.p.A. and domestic subsidiaries and is being completed by the remaining employees (in target). |
| [GRI 2-24a.i] | [GRI 2-24a.ii] | [GRI 2-24a.iii] | [GRI 2-24a.iv] | |
|---|---|---|---|---|
| Responsibility for the implementation of commitments |
Integration of commitments into organizational strategies, policies, and operating procedures |
Implementation of commitments with and through business relationships |
Training | |
| Fiscal strategy | The TIM Group has adopted a tax risk management and control system that provides for a governance model designed to ensure that: i. top management is informed of the tax impacts related to all strategic and operational business operations, planned and to be implemented, in order to ensure the consistency of business decisions with the defined tax strategy; ii. the Tax Function is involved in the performance of ordinary and extraordinary business activities, in order to ensure a prior assessment of the tax implications of the aforementioned activities, to ensure the proper management of the tax variable. |
To ensure effective tax risk management, the TIM Group has equipped itself with a system for the detection, measurement, management and control of tax risk (Tax Control Framework), governed by a specific Tax Policy, which provides: 1. a clear assignment of roles and responsibilities; 2. effective procedures for the detection, measurement, management and control of tax risks; 3. effective internal procedures aimed at ensuring, at all levels of the company, compliance with tax obligations; 4. effective procedures to remedy any deficiencies found in the functioning of the system and to activate the necessary corrective actions; and 5. reporting to the management bodies, through the provision of a report, at least annually, on the activities carried out. |
The TIM Group does not implement operations that primarily pursue a tax advantage and do not respond to business logic, i.e., operations carried out "artificially" for the sole purpose of reducing taxation. In addition, TIM, as part of its business activities, has adopted procedures for qualifying its counterparties (customers and suppliers), including for the purpose of preventing the commission of tax offenses. |
The TIM Group trains and supports all personnel involved in the management of tax-relevant activities, not limiting itself to resources specifically dedicated to tax matters, in order to ensure that all employees have the right skills and experience to fulfill their responsibilities. In order to achieve the above goal, TIM also invests in the professional growth of staff through specific voluntary online training plans. |
| [GRI 2-24a.i] | [GRI 2-24a.ii] | [GRI 2-24a.iii] | [GRI 2-24a.iv] | |
|---|---|---|---|---|
| Responsibility for the implementation of commitments |
Integration of commitments into organizational strategies, policies, and operating procedures |
Implementation of commitments with and through business relationships |
Training | |
| Audit - Policy Commitments |
The whistleblowing procedure governs the process of receiving, analyzing and managing reports concerning the TIM Group, the ownership of which is attributed to the Supervisory Bodies of each of the Group companies, without prejudice to the responsibilities and prerogatives of the Boards of Statutory Auditors for reports addressed to them. The handling of reports is carried out with the support of TIM's Audit Department. Commitments defined as a result of in-depth investigations of reports are attributed to the heads of the relevant functions, whose objectives include meeting agreed deadlines for resolving critical issues. |
The whistleblowing procedure cuts across all organizational strategies, policies, and operating procedures. |
The whistleblowing procedure cuts across all business relationships. |
As part of the periodic training refreshments conducted on the subject of Organizational Model 231, there is a reference to the whistleblowing procedure. In addition, a specific video pill was published on the corporate intranet in 2022, and all Group employees were informed about it via e-mail. |
| [GRI 2-24a.i] | [GRI 2-24a.ii] | [GRI 2-24a.iii] | [GRI 2-24a.iv] | |
|---|---|---|---|---|
| Responsibility for the implementation of commitments |
Integration of commitments into organizational strategies, policies, and operating procedures |
Implementation of commitments with and through business relationships |
Training | |
| Policy Human Resources, Organization & Real Estate TIM Group |
Although responsibility for the policy resides with the HRO Director, who reports directly to the CEO, managers are responsible for building and sustaining an environment in which People can best express their human and professional qualities to ensure the success of the Group. |
TIM promotes work-life balance by bringing agile working as an integral part of the new organizational model. Group Companies ensure full compliance with the legislative provisions on occupational diseases, health and safety in the workplace aimed at preventing possible accidents and damage to health in any way related to the performance of work. TIM assesses risks to worker safety and health with a view to their progressive minimization by adopting the principles, standards and solutions that constitute "best practices." Awareness and involvement on health and safety policies and objectives and related to internal control systems, as well as training and information on the risks and control measures taken, are considered key tools for achieving the expected results. |
TIM maintains open and transparent relations with labor unions and employee representatives, believing that only through continuous and constructive discussion can we arrive at the best balanced solutions with respect to the expectations of all stakeholders. The Group Companies widely recognize the role of workers' union representatives, who are not subject to any form of discrimination, and also guarantee paid leave and necessary means of communication with workers in the workplace to carry out their union activities. The signed union agreements provide for joint review sessions on the contents defined in the understandings. In addition, consistent with the system of industrial relations, special joint bodies are established to discuss the state of the art of the programs defined in the relevant agreements. |
The Group encourages all its stakeholders to provide feedback on the policy in order to improve it. Following the publication of the Policy, an online course was created for the entire corporate population, which has been available since the end of 2015. The course, which was updated in fall 2018, was included in the TIM Academy e-learning platform for Group employees. |
| [GRI 2-24a.i] | [GRI 2-24a.ii] | [GRI 2-24a.iii] | [GRI 2-24a.iv] | |
|---|---|---|---|---|
| Responsibility for the implementation of commitments |
Integration of commitments into organizational strategies, policies, and operating procedures |
Implementation of commitments with and through business relationships |
Training | |
| Products and services purchasing policy |
Recipients are TIM S.p.A., the TIM Foundation and TIM Group Companies. Specifically, within TIM S.p.A. the Functions concerned are: Procurement Function, User Functions, Chief Financial Office and Legal & Tax. |
What is set out in the Policy applies to all Group Companies and is directly applicable to purchases made by the Procurement Function for itself and for Italian and foreign Group companies that have given the latter a suitable purchasing mandate. For Group Companies that have not mandated TIM to purchase or have mandated it partially, this document is a "framework" and it is therefore the responsibility of the Companies to have their own specific policy for deploying this document. |
TIM ensures, throughout the supply chain, constant compliance with the Group's values of ethicality and sustainability, requiring similar formal commitment from suppliers and promoting, through them (and any subcontractors), respect for legality, human and personal rights, environmental sustainability and occupational health/safety and the provisions of TIM's Anti-Corruption Management System. To this end, contracts must always provide that TIM and the TIM Group Companies reserve the right to carry out verification and audit activities on suppliers and the services they are responsible for, in compliance with the regulatory and procedural framework in force. |
Where appropriate, and without prejudice to the independent responsibility of the supplier/partner, TIM may allow them access to specific training activities, with a view to a relationship of mutual cooperation Specifically, under the initiative called JAC, there is the JAC Academy project, which through a "supplier development program" contributes to the training of suppliers on ESG issues, and provides tools for tier 2 and 3 involvement and evaluation. In addition to the training initiative provided by the JAC Academy, there is the approach provided by the Open-es platform, which supports and guides providers in defining a plan to grow their ESG performance. |
[GRI 2-25a, b, c, d, e] TIM S.p.A. and/or TIM Group provide reporting channels other than the whistleblowing channel, such as the following:
(i.) in health, safety and environment:
(a) internal reporting channel, accessible to every facility manager of the Company, regarding the Health, Safety and Environment component in implementation of the Regulation "Employer's delegations of authority in the field of occupational safety and health and environmental protection checks on the work of delegates" code 2019-00035;
(ii.) in the area of security:
(iii.) in customer care:
[GRI 2-26a.i] The procedures for requesting clarification are provided in the whistleblowing procedure(3).
[GRI 2-26a.ii] Methods of requesting clarification are provided within the Reporting Portal (available at https://portalesegnalazioni.telecomitalia.it/).
In Brazil, TIM S.A. makes available the "whistleblowing channel," in two languages (Portuguese and English), accessible via the Internet or through the company's intranet (tim.com.br and ri.tim.com.br > ESG > Governança > Canal de Denúncias), or at the number (0800 900 8007), available 24/7. The full policy is available at the link: site.tim.com.br/sp/canal-de-denuncias.
(3) Page 3 of the whistleblowing procedure (regarding its "purpose and scope") states the following: "The Procedure applies to TIM and the TIM Entities, which ensure its correct and constant application, as well as its maximum dissemination internally, while respecting the obligations of confidentiality and the prerogatives of autonomy and independence of each Company.
The Procedure also serves as a reference for TIM subsidiaries other than TIM Entities, which may implement it, subject to regulatory adaptation to specific and/or local processes and organizational arrangements." In addition, on page 4 of the procedure in question (concerning the "Glossary"), the following is stated: "TIM Entities: means the domestic subsidiaries of the TIM Group, the TIM Foundation, Telecom Italia San Marino S.p.A. and Telefonia Mobile Sammarinese S.p.A, to which the Procedure applies directly."
| TIM S.p.A. | 2022 |
|---|---|
| Cases in which TIM has incurred a monetary penalty | 3 |
| Cases in which TIM received a non-monetary penalty | 0 |
| Total number of cases of noncompliance with laws and regulations | 3 |
| Non-compliance with laws and regulations | |
| BU Brazil | 2022 |
| Cases in which TIM has incurred a monetary penalty | 93 |
|---|---|
| Cases in which TIM received a non-monetary penalty | 13 |
| Total number of cases of noncompliance with laws and regulations | 106 |
| TIM S.p.A. | 2022 | 2021 | 2020 |
|---|---|---|---|
| Total number of fines paid for cases of noncompliance with laws and/or regulations |
3 | 3 | 9 |
| Monetary value of fines paid in Euro | 1,794,000 | 1,715,333 | 242,102,263 |
| BU Brazil | 2022 |
|---|---|
| Total number of fines paid for cases of noncompliance with laws and/ or regulations |
6 |
| Monetary value of fines paid in Reais | 820,000 |
In Brazil, in 2022, TIM S.A. recorded 106 significant cases of non-compliance with laws and regulations, with a total amount of 820 thousand Reais:
TIM, in Brazil, considers cases as significant based on the impact on business and fines exceeding 500 thousand Reais.
[GRI 2-27c] For TIM S.p.A., the total number and monetary value of fines by the AGCM(4) for non-compliance with laws and regulations regarding the provision and use of products and services in Italy with reference to unfair trade practice proceedings:
(4) Competition and Market Authority.
| TIM S.p.A. | 2022 | 2021 | 2020 |
|---|---|---|---|
| number of fines | 1 | 0 | 3 |
| total value in Euro | 1,000,000 | 0 | 7,100,000 |
Number and total monetary value of fines by AGCM for non-compliance with laws and regulations regarding the provision and use of products and services in Italy with reference to Antitrust proceedings:
| TIM S.p.A. | 2022 | 2021 | 2020 |
|---|---|---|---|
| number of fines | 0 | 0 | 2 |
| total value in Euro | 0 | 0 | 230,498,263 |
Number and total monetary value of fines by AGCOM(5) per le Garanzie nelle Comunicazioni for non-compliance with laws and regulations concerning the provision and use of products and services in Italy with reference to consumer protection proceedings:
| TIM S.p.A. | 2022 | 2021 | 2020 |
|---|---|---|---|
| number of fines | 2 | 3 | 4 |
| total value in Euro | 794,000 | 1,715,333 | 4,504,000 |
For 2022, a description is given below for each proceeding according to the year in which it related final deliberation:
In 2022, the following proceedings appear to be in progress:
(5) Communications Guarantee Authority.
• for consumer protection at AGCOM there are no pending cases reported.
In addition, with reference to the A514 antitrust proceeding at AGCM that concluded in 2020, with a sanction on TIM of approximately 116 million of Euro, it should be noted that TIM appealed the final measure before the Lazio Regional Administrative Court, contesting both the lawfulness of the conduct challenged by AGCM and, in any case, the quantification of the sanction imposed. In ruling 1963/22 dated February 28, 2022, the appeal was dismissed by the Regional Administrative Court. TIM has, however, appealed to the Council of State whose hearing is scheduled for May 25, 2023. With reference to the I850 antitrust investigative proceeding at AGCM concluded in 2022 with the assumption of commitments by TIM, it should be noted that Open Fiber in April 2022 challenged before the Lazio Regional Administrative Court, after requesting the adoption of precautionary measures, the final measure of AGCM that made mandatory the commitments proposed by TIM, which according to the plaintiff would not be suitable to remove the anticompetitive profiles. As a result of the precautionary hearing on June 1, 2022, the TAR rejected Open Fiber's request and set the merits for January 25, 2023; following that hearing, a decision is pending.
During 2022, the Garante per la protezione dei dati personali did not conduct any inspection activities at TIM S.p.A., nor did it adopt any sanction measures considered "material " (i.e., exceeding one million Euro). In the past 3 years, the Garante per la protezione dei dati personali has adopted only one prescriptive and sanctioning "material" measure against TIM S.p.A: Measure 7/2020 of January 15, 2020. This Measure mainly concerned activities related to telemarketing to consumer customers; additional issues considered were the management of certain applications, the TIM Party program, data breaches, and data retention of OLO (Other Licensed Operators) customers. The total amount of the penalty was 27,8 million Euro, of which TIM S.p.A. paid 13,9 million Euro, having settled the dispute without recourse under current Italian law by paying, within the 30-day period, the amount equal to half of the penalty imposed. In addition, in compliance with the Garante's order, TIM S.p.A. has implemented the requirements of the order, especially with regard to the improvement of telemarketing processes and the system of internal controls, in compliance with the deadlines set by the Privacy Guarantor.
For the sake of completeness, it is represented that in the years 2022, 2021 and 2020 there were other sanctioning measures towards TIM S.p.A. of "not material" amounts.
Over the past three years, the Data Protection Supervisor has not adopted any sanctions against the other BU Domestic companies on which the information collection process was carried out.
[GRI 2-27c] The measure taken by the Data Protection Authority toward TIM S.p.A. in 2020 is considered "material" (i.e., amounting to more than one million euros); in the years 2021 and 2020 there were other measures of several tens of thousands of Euro.
In the three-year period 2020-2022, no tax penalties related to BU Domestic were paid in excess of 100,000 Euro.
[GRI 2-27d] For completeness of information, all proceedings concluded before the AGCM and AGCOM have been reported.
[GRI 2-27a] [GRI 2-27b] In BU Brazil, there were no complaints regarding privacy breaches and/or loss of customer data during 2022, according to local regulations.
In Brazil, the Data Protection Officer (DPO) has not become aware of any specific complaints related to privacy breaches and/or loss of customer data. In 2022 TIM S.A. received more than 600 inquiries from customers regarding holder rights. Among the requests for privacy rights received so far, the most frequent include:
[GRI 2-28a] ETSI (European Telecommunications Standards Institute): the main European standardization organization for telecommunications.
GSMA (Global System for Mobile Communications Association): of which TIM S.A. is also a member, an international association that brings together the major mobile phone operators and develops studies on the positive contribution of technology in reducing greenhouse gas emissions and achieving sustainable development goals.
Open-es: a system alliance that aims to survey the sustainability performance of its suppliers, strengthen the qualification process with market ESG standards, and build shared paths to growth.
JAC (Joint Audit Cooperation): TIM is among the founders of the international association of telecom operators that audits, evaluates and develops the implementation of sustainability in the supply chain of the information communication technology industry.
Ecorating: a consortium of international TLC operators that assesses the environmental impact of smartphones to help customers make sustainable choices and encourage suppliers to reduce the environmental impact of their devices.
Parks Free and Equal: an association that brings together employers to develop Diversity & Inclusion strategies and practices with a prevalent focus on the area related to sexual orientation and gender identity.
Valore D: an association of companies in Italy that has pioneered issues of gender equity and a culture of inclusion since 2009.
In addition, in Brazil, TIM S.A. has roles in the governance of: ABR-www.abrtelecom.com.br Conexis-www.conexis.org.br Telebrasil-www.telebrasil.org.br ConectarAgro-www.conectaragro.com.br
[GRI 2-29a.i] In 2022 the Domestic BU identified eight main categories of stakeholders with each of which different modes of engagement were employed:
BU Domestic reviews the stakeholder list annually to keep up with organizational and market changes. In identifying and engaging stakeholders, TIM follows the AA1000SES global standard, the most widely applied standard in this area.
[GRI 2-29a.ii] As a Company that is strongly integrated in the territory and in the social and economic-productive fabric, the Domestic BU considers it essential to have a constant relationship with its stakeholders, that is, with all the people and organizations that are involved in various ways in the Company's activities. Through consultation, dialogue, information, and partnership activities, TIM has a way to keep its understanding of their expectations up-to-date and at the same time have a forward-looking view of possible scenario developments.
[GRI 2-29a.iii] The engagement standard used (AA1000SES), with a view to continuous improvement, involves a circular model that starts with defining the goals of engagement and arrives with translating what emerges from discussions with stakeholders into actions. Below are the main ways of involvement in BU domestic:
On the customer side, TIM confirms its strategy strongly oriented toward digitization and innovation, offering its digital caring channels dedicated to existing customers and prospects who receive personalized and fast responses.
In 2022 TIM handled about 276 thousand caring conversations between the public page and private messages on facebook and twitter, about 221 thousand alerts in the MyTIM private area, and handled about 4,2 million instant messaging conversations of which 83% were through the chatbot Angie and 17% with phone operator. In addition, through the whatsapp channel (human and bot) 390 thousand conversations were handled. In addition to the whatsapp channel, in 2022 deaf customers were also able to make use of the Pedius service, which allows access to TIM call centers, adding to the usual channels. The service, TIM S.p.A. has adopted a model of presiding over and improving quality and customer experience (customer experience) with principals dedicated to the definition and evolution of customer journeys, to define improvement plans and give value to its customers.
Of particular importance among the surveys is the monitoring of the Customer Satisfaction Index (CSI)-based on the American Customer Satisfaction Index (ACSI) standard-which aims to survey the perceived quality of TIM customers and the customers of major competitors. Monitoring of the CSI has achieved certification of compliance with UNI 11098:2003 and is included in the managerial (Management By Objectives) and collective incentive system.
The indicator for 2022, for consumer customers is 75.02, up from 74.29 in 2021(6).
See GRI Scope 3 of this report for issues related to Relations with Consumer Associations.
In Brazil, TIM S.A. orients its engagement and relationship actions with its key audiences based on the engagement policy, which provides a set of principles that seek to enhance dialogue and transparent communication in order to
which was launched in 2014, aims to ensure that inbound contact is accessible to hearing-impaired customers through an application that allows them to make normal phone calls using speech recognition and text-to-speech technologies.
(6) Figure updated based on base year revenues.
build quality, solid and ethical relationships. In constructing its ESG agenda and materiality matrix, TIM S.A. follows these guidelines to dialogue with its stakeholders. The annual process of preparing the materiality matrix includes consultation with the Company's external and internal stakeholders: this process enables the periodic review of TIM's ESG strategies in Brazil, for the continuous improvement of the Company's practices and commitments.
In 2022 TIM S.A. revised the materiality matrix in light of new trends that consider financial and social-environmental impacts (so-called dual materiality), in line with the Global Reporting Initiative's Universal Standards. With the support of a consulting firm specializing in this activity, the construction of the new matrix consisted of five stages:
After defining the areas and identifying the stakeholders, the twenty themes were reported, six on the environmental axis, six on the social axis, and eight on governance.
In setting priorities, TIM S.A. has divided 3 areas:
All the results obtained were analyzed and the information gathered was validated with the Company's top management. At the end of the process, eight material themes were identified for the TIM S.A.
[GRI 2-30] All, then 100%, of TIM Group workers are covered by collective bargaining agreements.
All workers are covered by collective bargaining agreements between the employer and labor organizations: all staff are guaranteed the opportunity to participate in Trade Union meetings, in terms of hours of paid leave and company space or computer tools that enable them to be held, as well as to participate freely in consultations to elect union representatives. In none of the Group's operations is the right to Trade Union participation at risk or challenged. The framework, among other things, specifies how the rights are to be enjoyed and establishes the supervisory bodies for their enforcement.
[GRI 2-30a] 100% TIM Group.
[GRI 2-30b] The relevant collective bargaining agreement applies to all employees.
GRI 3-1 | Process to determine material topics
GRI 3-2 | List of material topics
GRI 3-3 | Management of material topics
[GRI 3-1a.i] During 2022, in accordance with the latest provisions of the Global Reporting Initiative's international standards, TIM adopted the impact relevance criterion by assessing the actual or potential impact that the Group can generate for each topic on society and the surrounding environment.
The topics were preliminarily selected through an analytics platform that, in real time, collects and analyzes a substantial number of documentary sources from the industry and every organization relevant to our business and monitors major social media, ensuring a solid and up-to-date information base. An initial risk analysis was also carried out at this stage to ensure that no topics considered relevant by the risk management system in relation to ESG topics were missed. For each theme, thus mapped, the impacts (negative or positive, actual or potential) that the Group may have on the economy, the surrounding environment, and people were identified by analyzing the Group's activities, its business relationships, and the possible effects generated or induced directly or indirectly.
Top management identified key stakeholders to initiate the general engagement activity used to assess impacts associated with potentially relevant topics.
Based on the Accountability AA100SES standard, top managers made a qualitative assessment of the relevance of the relationship with each stakeholder category in terms of "dependence," "influence," and "urgency" with a scale of values between 0 (not relevant) and 5 (extremely relevant).
[GRI 3-1a.ii] The analysis was conducted with the direct involvement of both stakeholders and TIM's top management, who were asked to assess the relevance to TIM of material issues based on impact.
External and internal stakeholders were engaged in order to ask them to give an impact assessment for each topic, using a qualitative measurement criterion with a scale of values between 0 (not impactful) and 5 (extremely impactful) to then qualify the topics, according to their relevance, into topics for which a position of excellence is required, topics for which targeted action is required on aspects that are peculiar and of interest to TIM, and topics to be observed constantly to assess possible evolutions.
Material topics were consolidated based on the appropriately weighted findings of document analysis, survey results, and listening to stakeholders through media channels. Finally, the material topics were also validated downstream of a sensitivity analysis that tested whether and how the materiality of the topics varied as the weights assigned to the sources used changed. Finally, it was verified that the identified material topics included the medium/high level risks overseen in risk management. The synthesis of the corporate vision and external stakeholders returned a list of topics in order of impact relevance.
[GRI 3-1b] A significant sample of representatives of all stakeholder categories and Group Top Management was involved in a survey designed to identify and measure the impacts associated with each topic. Responses from external stakeholders are appropriately weighted according to the category relevance expressed by Top Management.
The process was carried out in constant interaction with the corporate risk management function and the use of a constantly updated information base both in relation to documentary sources and in relation to the media as a source of listening to stakeholders.
[GRI 3-2a] The 2022 materiality analysis resulted in the identification of 16 material topics. Below is the list of material issues sorted by impact relevance with evidence of the type and intensity of impact.
| Material Topics 2022 | Impact level | Type of impact |
|---|---|---|
| Privacy and cybersecurity | - Potential | |
| Digital inclusion | + Actual | |
| Infrastructures and emerging technologies | + Actual | |
| Customer interaction and service transparency | + Actual | |
| Employee health and safety | - Actual | |
| Development and motivation of TIM employees | + Actual | |
| Climate change | - Actual | |
| Energy transition | + Potential | |
| Legal and regulatory context management | - Potential | |
| Equal pay and opportunity | - Potential | |
| Community and stakeholder relations | + Actual | |
| Resilience to physical, public health, and sociopolitical risks | + Actual | |
| Sustainable supply chain | + Actual | |
| Human rights defense | - Potential | |
| Cyberbullying, child pornography, online gambling | - Potential | |
| Circular economy and waste production | - Potential | |

[GRI 3-2b] In 2022 there were no substantial changes from the previous year although the update of the GRI Standards, which requires the analysis of topics in relation to their relevance of impact to the outside world, required a more detailed qualification of the topics, raising them from 12 in 2021 to 16 now. By way of example, we cite the 2021 topic "Work and human capital", which in 2022 was declined into "Employee health and safety" and "Development and motivation of TIM employees"; likewise, "Circular economy and waste production" was spun off from the topic "Climate change", which in 2021 connoted with broader meaning. Finally, the topic "Resilience to physical, public health and sociopolitical risks" is mentioned, which is not present in 2021 because it is considered cross-cutting on various topics, especially in relation to Covid-19 management.
[GRI 3-3a] Describe the actual and potential, negative and positive impacts on the economy, environment, and people, including impacts on their human rights
The disruption or vulnerability of TIM's information systems and networks due to security breaches, which could disrupt core activities or lead to the accidental or illegal access, destruction, alteration, or disclosure of protected data, can generate a negative impact on people's privacy and the cybersecurity of data and information.
[GRI 3-3b] Report whether the organization is involved with the negative impacts through its activities or as a result of its business relationships, and describe the activities or business relationships
The Organization could be involved in the negative impacts through its core activities.
Privacy compliance, cybersecurity protection, and related potential negative impacts are a priority for TIM.
Regarding the issue of privacy in particular, TIM has had an articulated Operating Model since 2003 to safeguard the correct application of data protection regulations at the Group level. With these intentions, the company functions are committed to ensuring the proper processing of the personal data of data subjects, including customers and employees, in the performance of business activities, in line with the provisions of the General Data Protection Regulation (GDPR) in Italy, and the General Data Protection Law (LGPD in the Portuguese acronym), as far as BU Brazil is concerned.
The transposition of legal provisions and guidance from the Privacy Guarantor is ensured by the Privacy Function through the constant study and interpretation of regulations and the subsequent updating of Group regulations and policies and procedures on specific areas. Particularly significant among these is the "System of rules for the enforcement of personal data protection legislation in the TIM Group" (System of Rules), which defines the provisions and operational guidelines for each fulfillment of interest.
In the area of information security, the Cyber Security Function ensures the security monitoring of the public telecommunication network, data centers and network, and manages ICT security incidents in conjunction with the relevant functions. With these aims in mind, the TIM Group has equipped itself with a comprehensive body of regulations consisting of Procedures and Policies on cybersecurity governance, monitoring, cybersecurity incident management and crisis management.
In addition, in order to go beyond the normal transposition of regulations in the management of privacy and information security topics and generate value in this regard, some functions and/or companies in the Group with a significant impact on stakeholders have achieved and/or confirmed certifications in line with the main ISO standards on the subject (ISO/IEC 20000-1, ISO/IEC 27001, ISO 27035).
As a function of the material theme Privacy and cybersecurity, TIM has committed to carrying out multiple actions inherent in preventing and mitigating the negative impacts associated with it. In this regard, BU Domestic has taken the following actions:
• adaptation of the Privacy Operating Model in line with the principle of privacyby-design, which involved updating the Registers of processing activities, creating a heat map based on the calculation of privacy risk associated with each processing operation, and introducing new IT tools, including the one for managing the Notifications and the one for managing the aforementioned Registers, which enable the integration of the information managed;
With reference to the Brazil BU, in order to support the Group's action on privacy and cybersecurity, in full compliance with the General Data Protection Law (LGPD) and the Sarbanes-Oxley Act, TIM has initiated a series of strategic initiatives:
conducting the necessary measures for compliance with the new law and management of data subjects' requests for rights;
Downstream of the materiality analysis, it was found that the main impact related to the material topic is of the potential negative type. For this reason, disclosure was provided solely with respect to the management of this type of impact. However, it should be specified that the TIM Group, in order to ensure transparency and fairness in business management to its stakeholders, has established a solid internal control system, consisting of rules, tools, activities, procedures and organizational structures. In this regard, as part of its risk management system, the Group has adopted an Enterprise Risk Management model capable of identifying potential events that may affect its business activities, including the plurality of ESG risks, enabling it to create the conditions useful for planning and implementing initiatives aimed at dealing with actual negative spillovers or bring about positive economic, social and environmental impacts.
In order to keep track of the effectiveness of actions taken to prevent and mitigate potential negative impacts, the Group has developed a set of processes in line with the relevant major ISO standards (ISO/IEC 20000-1, ISO/IEC 27001, ISO 27035). With reference to privacy, BU Domestic identifies a control system based on three different levels:
In addition, following the review of telemarketing processes that took place during 2020 and 2021, the internal controls performed on these processes were strengthened and expanded, consistent with the requirements of the Privacy Guarantor.
With respect to IT security, in Italy, the Cyber Security Function conducts security monitoring of the public telecommunications network, data centers and network, the process of which is part of a broader macro-process of "security event" management and takes into account the principles contained in the company's policies on information security, Business Continuity Management, Crisis Management and personal data breaches.
As for BU Brazil, in order to assess the effectiveness of its actions, through the Cyber Security Operations Center (CSOC) it conducts constant monitoring with reference to a number of necessary aspects such as those related to data loss prevention (DLP), multi-factor authentication (MFA), identity management and content filtering.
TIM aims to spread knowledge about privacy compliance, promote compliance, and increase awareness and attention of personnel in charge of processing personal data. This is the background against which the relevant training activities are framed. In particular, with reference to the Domestic BU, training sessions were organized in 2022 by the Privacy Function on the subject of processing requests related to access to traffic data stored for criminal purposes (following the regulatory change in late 2021 of article 132 of the Privacy Code) and commercial contacting, i.e., related to the subject of contacts for commercial purposes. With respect to BU Brazil, on the other hand, a training offering has been defined on the contents of the LGPD and the reference measures to be taken in the areas of privacy and cybersecurity. In addition, in order to track the effectiveness of its actions, the Domestic BU
voluntarily monitors a number of specific indicators in this regard from year to year, outlined below:
Finally, for the Brazil BU, indicators are also monitored regarding the requests received regarding the processing of data subjects' data and the number of legal actions conducted by clients during the year.
During 2022, fulfilling its training activities, the Domestic BU implemented training initiatives on privacy and cybersecurity issues, impacting 801 people for a total of 10,424 hours delivered, respectively, with respect to privacy-related notions, and 32,770 people for a total of 125,260 hours of training delivered, with respect to cybersecurity issues.
The training activities held by the Domestic BU in relation to issues related to commercial contactability covered more specifically the general requirements of the GDPR and the rules and instructions defined by TIM in accordance with the current regulations on commercial contactability, the processing of customer/ prospect requests(1) related to the exercise of privacy rights and the detection and management of data breaches.
Regarding training initiatives conducted by the Brazil BU, 100% of employees (in 2022 amounting to 9,395) were involved in order to raise their awareness with respect to data protection and cybersecurity issues.
In relation to the annual monitoring of the indicators adopted by the Domestic BU, the effectiveness of the actions taken is demonstrated, for example, in the effective management of cybersecurity incidents involving the Domestic BU's TIM systems. In this regard, 3 incidents generated low impact, only 1 incident generated medium/high impact; all other incidents were contained/mitigated by the countermeasures in place.
Compared to the monitoring conducted by BU Brazil, 2022 shows a decrease of more than 14% (vs 2021) with reference to requests received related to the processing of data subjects' data.
Finally, further evidence of the effectiveness of the initiatives undertaken by the Group in this regard lies in the fact that some Functions and/or Companies of the Group with a significant impact on stakeholders have obtained certifications in line with the main ISO standards on the subject (ISO/IEC 20000-1, ISO/IEC 27001, ISO 27035).
TIM's efforts during 2022 on the ongoing application of the principles and policies governing the identified topic, and the related impact, has resulted in continuous improvement of the Group's privacy and information security management system.
(1) A prospect is a person who falls within the company's target audience of potential customers; in essence, he or she is a "candidate" who may possibly or likely turn into a customer.
In this regard, the monitoring activities conducted by the Group during 2022 made it possible to capture any critical aspects while enabling the Company to carry out assessments and actions with positive impact on its processes. In fact, the countermeasures put in place in order to prevent or mitigate any negative impacts related to the topic, allowed during 2022 to contain/mitigate 99.9% of cybersecurity incidents involving TIM systems in the Domestic BU.
The materiality analysis conducted in 2022 highlighted the extreme importance of this topic, consequently guiding the Group toward carrying out initiatives and identifying necessary safeguards for policy implementation with a higher degree of commitment and accountability.
With this in mind, during FY2022 the Domestic BU took part in several additional discussions with its stakeholders aimed at implementing privacy and information and network security policies, while also activating virtuous channels for cybersecurity research and innovation. With reference to the engagement activities instrumental to research in the field of e-security, the following are relevant, for example:
(CVD) to share information on new vulnerabilities and threats to mobile networks;
[GRI 3-3a] Describe the actual and potential, negative and positive impacts on the economy, environment, and people, including impacts on their human rights TIM can generate impacts by contributing to the development and deployment of useful technologies to bridge the digital divide, facilitating or providing digital hardware, software, content and service solutions to communities and individuals who lack them, and supporting the development of skills needed for effective use of technologies.
[GRI 3-3b] Report whether the organization is involved with the negative impacts through its activities or as a result of its business relationships, and describe the activities or business relationships
Downstream of the materiality analysis, it was found that the main impact related to the material topic is of the actual positive type. For this reason, disclosure was provided solely with respect to the management of this type of impact. However, it should be specified that the TIM Group, in order to ensure transparency and fairness in business management to its stakeholders, has established a solid internal control system, consisting of rules, tools, activities, procedures and organizational structures. In this regard, as part of its risk management system, the Group has adopted an Enterprise Risk Management model capable of identifying potential events that may affect its business activities, including the plurality of ESG risks, enabling it to create the prerequisites for planning and implementing initiatives to manage potential and actual negative economic, social and environmental impacts.
The Group's strategy is embodied in multiple actions and commitments aimed at spreading an inclusive digital culture that can enable innovation and socioeconomic development of communities. In particular, the Group's activities in the ICT sector, thanks to its coverage with broadband and its mobile network, offer the potential to ensure everyone's participation in digital evolutions, guaranteeing the overcoming of the digital divide through the definition of technological solutions and thematic initiatives that contribute to the determination of a future that takes into account everyone's capabilities. With these aims in mind, the Domestic BU supported and endorsed the European Commission's proposal to adopt the Pathway to the digital decade, which can set concrete goals and targets for digital transformation in Europe to 2030, empowering businesses and citizens for a people-centered, sustainable and more prosperous digital future. In addition, the Group is a member of the Telecom Infra Project (TIP), whose international initiative aims to develop innovative and sustainable solutions to expand telecommunications infrastructure around the world. As part of the same project, TIM has contributed to the development of open telecommunications solutions such as OOPT (Open Optical Packet Transport), DCSG (Disaggregated Cell Site Gateway), OpenRAN (Open Radio Access Network) and more recently TSS (Total Site Solution) and Open Field Program for 5G.
In continuation of previous years, BU Domestic is an active member of the Digital Skills and Jobs Coalition, a platform launched by the European Commission for the exchange of best practices in the field of digital skills, with the participation of multiple stakeholders at the European level.
Finally, in Italy TIM is committed to promoting digital culture in the country through specific practices that can train and/or increase the digital skills (upskilling and reskilling) of students, teachers and workers, with the aim of ensuring greater social inclusion and gender equality. Efforts to promote knowledge acquisition and exchange with universities are also carried out by the Group in Brazil through its open innovation program.
[GRI 3-3d] Describe actions taken to manage the topic and related impacts, including:
[GRI 3-3d.i, d.ii] actions to prevent or mitigate potential negative impacts; / actions to address actual negative impacts, including actions to provide for or cooperate in their remediation;
(See point b)
The Group is constantly engaged in defining actions to highlight, affirm and foster its commitment to digital inclusion, with the aim of managing the actual positive impacts associated with the topic of digital inclusion.
The following are the main actions carried out for this purpose:
In relation to commitments and actions aimed at managing the actual positive impacts associated with the topic, the TIM Group constantly monitors their effectiveness throughout the year by adopting specific processes that take into consideration the recorded performance on digital inclusion.
In relation to the Domestic BU, all projects and actions undertaken are subject to a monitoring system capable of measuring in qualitative and quantitative terms the feedback obtained. For example, with reference to the initiatives conducted with students, the monitoring process adopted by TIM in Italy takes the form of a system defined on the basis of the findings of entrance tests, learning tests and motivational interviews, aimed at measuring how much the training has contributed to closing the skills gap in the digital sphere.
In addition, for the different outreach and training initiatives, the Domestic BU tracks the effectiveness of the actions by measuring participation in the projects implemented and identifying the perceived quality of the users of the projects. In fact, to measure the latter, at the end of each action, BU Domestic first defined and then administered a satisfaction questionnaire.
Finally, in both the Italian and Brazilian territories, the Group conducts annual monitoring processes aimed at analyzing and verifying the degree of coverage of its network, with the aim of progressively expanding it in line with the objectives assumed in this regard as part of its 2023-2025 Business Plan.
The TIM Group has defined specific goals and indicators for monitoring them, which can quantify the effectiveness of the commitments and actions implemented associated with the active management of actual positive impacts on digital inclusion.
In particular, the Group has set ambitious goals inherent in the development of its ultra-broadband network on FTTH (Fiber To The Home) architecture-monitored on an ongoing basis, with the aim of bringing high-speed connectivity services
over fiber to most of the territories in which it operates, contributing to geographic digital inclusion:
In addition, with reference to the implemented projects aimed at the community of high school students and teachers, as well as the community of university students, the Domestic BU monitors the indicators of participation, which capable of determining the rate of increase/decrease of participation in the relevant initiatives, and of passing the learning tests, as well as the number of contacts and the results of the satisfaction questionnaires.
Finally, the Domestic BU has defined additional indicators capable of detecting, monitoring and ascertaining the results and progress achieved with respect to the initiatives activated as part of the cultural and musical events in which TIM took part and with respect to the initiatives implemented in collaboration with schools, monitoring, respectively, for example, the number of events manned and the indicators related to the involvement of schools in the Italian territory.
The effectiveness of the actions implemented by the TIM Group on digital inclusion is demonstrated, first and foremost, through the progress achieved against its digital inclusion targets:
• with reference to the Domestic BU, FTTH coverage of 32% of the country's housing units was achieved in 2022.
• regarding BU Brazil, FTTH coverage >4 (homes passed) was achieved in 2022. With reference to the additional main indicators monitored, with respect to the indicators of participation and passing the learning tests, BU Domestic noted on the one hand a 2% year-on-year increase in participation in the projects implemented for the community of high school students and teachers and for the community of college students, and on the other hand it noted the efficiency of the same initiatives by noting a passing rate of more than 50% of the learning tests.
In contrast, with regard to the indicators monitored by TIM in Italy to measure the level of satisfaction with projects and the number of contacts from companies to university student users, in 2022 the Company found respectively on a scale of 1 to 5 a score of ≥ 3 in the questionnaires disbursed, as well as a 2% year-on-year increase in students contacted by companies operating in the market.
The initiatives carried out by the Group and the important results achieved during the year, contribute to the digital growth of the territories and at the same time increase TIM's awareness of the crucial role assumed by the Organization in the pursuit of national and supranational goals of digital inclusion.
In fact, through its business, the Group contributes to the digital inclusion and growth of the territories in which it operates, learning useful insights from the performance of daily activities and engaging in a path of continuous improvement for the deployment of ultrafast connectivity, accessible and secure digital services for daily life and business, the strengthening of citizens' digital skills and the development of their technical and professional skills. In this light, the realization that one's digital expertise is an essential tool for the personal, social and professional development of the citizens and workers living in the communities where TIM is present underscores the importance attached to the topic and the commitment shown on these aspects, and qualifies as the most important lesson learned from the operational practices conducted. In this sense, only through a widespread and shared culture on digital skills, supported by the Group's actions, can the current and future challenges of sustainable development and, in particular, of breaking down social and geographic digital barriers be addressed.
The TIM Group carries on an ongoing dialogue with different stakeholders in order to develop virtuous initiatives aimed at positively impacting the spread of digital skills and overcoming all forms of social and geographical barriers in this regard. Such confrontation is crucial for the Group to pursue its goals, and identify instances of them.
With this in mind, during the year the Domestic BU carried out a continuous engagement capable of conveying the improvement of the effectiveness of its implemented initiatives, some of which by nature arise from the interaction with external partners; in fact, precisely through such engagement in the constant confrontation between the parties, TIM was able to initiate, develop and actively contribute to the implementation of the planned digital inclusion projects, ensuring positive spillovers associated with the theme.
TIM can generate impacts through the development of digital technologies such as robotics, IoT and artificial intelligence, thanks in part to the enablement of innovative infrastructure such as fiber and 5G, which transform business operations and contribute to the redefinition of the services market and the growth of innovation.
Downstream of the materiality analysis, it was found that the main impact related to the material topic is of the actual positive type. For this reason, disclosure was provided solely with respect to the management of this type of impact. However, it should be specified that the TIM Group, in order to ensure transparency and fairness in business management to its stakeholders, has established a solid internal control system, consisting of rules, tools, activities, procedures and organizational structures. In this regard, as part of its risk management system, the Group has adopted an Enterprise Risk Management model capable of identifying potential events that may affect its business activities, including the plurality of ESG risks, enabling it to create the prerequisites for planning and implementing initiatives to manage potential and actual negative economic, social and environmental impacts.
The TIM Group attaches strategic importance to the issue of investments aimed at upgrading infrastructure and adopting cutting-edge technologies in line with industry trends. Research and development of innovative infrastructure and emerging technologies, processes and business models is a key factor in keeping pace with the profound transformations of ICT, as well as a necessary and driving asset for the customers with whom the Group works, contributing to overcoming the socio-cultural barriers that limit the possibility of participating in the information society and enjoying its benefits.
The Group's technological evolution is based on the TIM Technology Plan, part of the Industrial Plan; in particular, the Technology Plan identifies the technology strategy in terms of guidelines, specific technologies, and adoption roadmaps over a multi-year period. The three-year technology plan is the reference document for the Group and also includes the technology development plans of subsidiaries. Qualitative and/or quantitative objectives are declined on an annual basis and defined in such a way as to be objectively measurable in compliance with the standards of the quality (ISO 9001), environmental (ISO 14001) and innovation operational processes; in general, TIM's processes are based on the eTom reference standard of the Telemanagement Forum(2).
In 2022, the Domestic BU continued to strengthen an innovation model that leverages the ecosystem concept, which is key to nurturing a virtuous circle for scouting, incubating, and planning innovative initiatives. This is realized, on the one hand, through labs as multi-site centers that are virtually open and connected in a single digital environment and, on the other hand, through collaboration with a number of Universities of excellence.
With this in mind, during the year the Domestic BU undertook specific engagements with the aim of giving relevance to the identified impact topic and, implicitly, to support innovation and in creating a synergy geared toward the company's digital transformation, which attests to TIM as a partner of reference in Italy.
[GRI 3-3d.i, d.ii] actions to prevent or mitigate potential negative impacts; / actions to address actual negative impacts, including actions to provide for or cooperate in their remediation; (See point b)
With reference to the efforts deployed in Italy by TIM according to topics related to infrastructure and emerging technologies, the Domestic BU has carried out multiple actions with the aim of attesting, fostering and managing the actual related positive impacts.
In particular, the Domestic BU introduced two new projects during 2022:
(2) The Business Process Framework (eTOM) can be considered an operating model framework for telecommunications service providers; the model describes the required business processes, defines key elements and how they should interact. eTOM is a standard maintained by the TM Forum, an association for service providers and their suppliers in the telecommunications and entertainment industries.
In relation to the "Progetto Polveri Sottili", TIM conducted the following actions in 2022:
On the other hand, with reference to the first platform in Italy enabling smart mobility on TIM's Edge Cloud 5G technology, the Company has committed to carry out relevant actions in order to ensure the implementation and management of its associated actual positive impacts. Details of the main actions carried out are given below:
• defining the platform aimed at managing smarter mobility through the use of Artificial Intelligence (AI). Through these mechanisms, the platform developed by BU Domestic will influence and optimize vehicle routes and mobility in general, decreasing time and improving traffic patterns with positive impacts from a sustainability perspective;
In defining the processes used in order to monitor the effectiveness of the actions referable to the "Progetto Polveri Sottili", TIM identified a joint process between ARPA (Regional Agency for Environmental Protection of Piedmont) and the Polytechnic University of Turin (POLITO) with a view to comparing the data collected by POLITO's sensor system with those collected by ARPA's fixed stations.
The process of monitoring the effectiveness of actions related to the smart mobility enabling platform, launched in 2022 by TIM and Google Cloud, on the other hand, is inherent within the system itself and in the actions conducted by the Domestic BU, aimed at highlighting the positive impact generated by the project. In this regard, the monitoring process through which to verify the effectiveness of the implementation of the first Edge Computing solution lies in the development of the platform itself. In fact, the latter will allow MASA and the University of Modena and Reggio Emilia to test new solutions for self-driving and assisted cars as well as advanced cloud mobility applications, which require dynamic and ultrasecure communication between vehicles and road infrastructure and integration with smart city systems.
In relation to the actions taken in 2022 by TIM in Italy in order to generate positive impacts in terms of infrastructure and emerging technologies, the Company has pursued specific annual goals in the implementation of its projects, monitoring the progress achieved.
In particular, as part of the effort to identify innovative technological solutions for the management of environmental aspects, 2022 saw the birth of the "Progetto Polveri Sottili" - scheduling its full implementation in 2023, for which, as it is still in an experimental phase, the Domestic BU sought to pursue the Proof of Concept (PoC) goal, which is to validate the Blockchain-based E2E technology solution. Since this is, therefore, a solution aimed at the dissemination and data analysis of environmental pollution by measuring the concentration of fine particulate matter in the air, the type of sensors proposed by the Polytechnic and the overall system chain were subject to monitoring and validation, aiming to make the solution easily replicable especially in urban settings.
With respect to smart mobility technology solutions, in 2022 the Domestic BU
has set a target to build a platform enabling smart mobility on TIM's Edge Cloud 5G technology, with the aim of making it, according to its own development, a scalable and replicable solution to make its large-scale deployment manageable and ensure the sustainability of the Egde Computing platform.
The progress made in 2022 by the Domestic BU against its goals and targets, respectively, for the two different projects pursued during the fiscal year highlighted the capacity and importance attached to the material topic by TIM. The effectiveness of the actions taken by the Domestic BU to manage the positive impacts generated and its objectives, in this case the "Progetto Polveri Sottili", is demonstrated by the maturity achieved with respect to the development of the defined system, which has the capacity to enable new city mobility management policies, through the post-processing processes of the collected data related to the concentration of fine particles in the air. Specifically, both the methodological approach and the E2E technology solution were validated in 2022.
With reference to smart mobility solutions, in 2022 in Italy TIM in partnership with Google Cloud launched the platform for smart mobility enablement on Edge Cloud 5G technology, achieving its goal of making the platform a solution, in technological terms, scalable and replicable. In fact, the expertise employed in the design of Edge's infrastructure allowed the technology to be deployed according to these ambitions.
The projects identified and the progress achieved with respect to them have enabled the Group to strengthen its awareness of the importance, for realities such as TIM's, of envisaging continued investment in smart, high-innovation solutions, with a view to looking forward.
With reference to 2022, while on the one hand the Domestic BU was able to follow up on its commitment to updating and gaining experience in the field inherent to environmental monitoring by adopting innovative technologies, such as Blockchain, for the certification of collected data ("Progetto Polveri Sottili"), on the other hand it was able to define a solution capable of enabling the creation of an ecosystem of actors and partners for the realization of Edge Cloud-enabled automotive applications and use cases (smart mobility platform).
In fact, it is understood that for TIM, the continuous updating of the solutions developed and the deployment of considerable effort in these areas, turns out to be a necessary condition in order to proactively manage the actual positive impacts associated with the topic itself.
The development of the actions taken during 2022 in the area of infrastructure
and emerging technologies by the Group showed the important role of continuous discussion with stakeholders in achieving the set goals.
In fact, through constant discussion with them, TIM in Italy has been able to follow up on its own initiatives and at the same time has been able to develop important synergies; suffice it to think of the remarkable progress and goals that the Domestic BU has achieved and targeted both in the "Progetto Polveri Sottili" and in the development of the smart mobility platform. All made possible thanks to the continuous discussion with stakeholders and the development of collaborations between TIM, Turin Polytechnic, LINKS Foundation, CSI, UNITO, 5T, Arpa and the City of Turin in the context of the "Progetto Polveri Sottili", as well as the cooperations between the Domestic BU and MASA, with particular reference to the University of Modena and Reggio Emilia, regarding the deployment of smart mobility solutions on Edge Cloud 5G infrastructure.
[GRI 3-3a] Describe the actual and potential, negative and positive impacts on the economy, environment, and people, including impacts on their human rights
The way TIM relates to and communicates with its customers - in terms of listening to their needs, offering quality services, resolving disputes, and providing clear and transparent information during commercial transactions - as well as the way it promotes the most sustainable patterns of consumption and access to products and services without discrimination can have an impact on their level of satisfaction.
Downstream of the materiality analysis, it was found that the main impact related to the material topic is of the actual positive type. For this reason, disclosure was provided solely with respect to the management of this type of impact. However, it should be specified that the TIM Group, in order to ensure transparency and fairness in business management to its stakeholders, has established a solid internal control system, consisting of rules, tools, activities, procedures and organizational structures. In this regard, as part of its risk management system, the Group has adopted an Enterprise Risk Management model capable of identifying potential events that may affect its business activities, including the plurality of ESG risks, enabling it to create the conditions useful for planning and implementing initiatives aimed at managing potential and actual negative economic, social and environmental impacts.
In the current business environment and consistent with corporate strategy, the entire Organization is focused on improving the customer experience, increasingly a central lever to compete and gain market leadership.
In Italy, TIM is constantly committed both to improving quality and regulatory
compliance standards with regard to all contractual materials and advertising communication of the services offered to consumers, and to adopting a model of presiding over and improving quality and customer experience with specific garrisons dedicated to the definition and evolution of customer journeys in the logic of "quality by design", providing for the effective management of disputes as well. Transparency, simplicity and respect for the customer are foundational elements in delivering an excellent customer experience.
In addition, in order to better focus on customer needs, within the Group it defines technology and skills practices formed for homogeneous business strands: cloud (Noovle), IoT/digital Identity (Olivetti-Trust Tecnologies), Cybersecurity (Telsy). In doing so, TIM Enterprise ensures uniformity of access and delivery of service quality to all wallet customers by offering the ability to negotiate and customize solutions and contract standards. At the same time, in Italy TIM is also committed to guaranteeing specific Service Levels defined at the contractual level as well as providing monitoring and support services.
Finally, in relation to this topic, in order to ensure effective management of related impacts, some functions and/or companies in the Group with a significant impact on stakeholders have achieved and/or confirmed certifications in line with the main relevant ISO standards such as ISO 9001 and ISO 22301, as well as ISO 14001, ISO/IEC 20000-1, and ISO/IEC 27001.
[GRI 3-3d] Describe actions taken to manage the topic and related impacts, including:
[GRI 3-3d.i, d.ii] actions to prevent or mitigate potential negative impacts; / actions to address actual negative impacts, including actions to provide for or cooperate in their remediation;
(See point b)
[GRI 3-3d.iii] actions to manage actual and potential positive impacts
In Italy, TIM has implemented a series of interventions aimed at managing actual positive impacts, targeting both Small Business and Consumer customers. The main actions in the area are given below:
adoption of new operational controls, a new testing process to become more stable, the introduction of new features, and a new approach to increase the app's popularity on app stores;
In addition, the Domestic BU has put in place a number of additional actions with a positive impact on customers, the main ones of which are listed below:
Finally, with the aim of responding to the increasing sensitivity of certain customer segments, in 2022 the Domestic BU also confirmed its focus on promoting more sustainable consumption models; in fact, TIM pursued the sale of remanufactured smartphones, exclusively Class A+, minimizing accessories and packaging materials and introducing the use of recycled plastics. At the same time, the Domestic BU completed the switch off of the 3G network, allowing it to focus its investments on 4G and 5G technologies, which are more energy efficient and perform better in terms of the quality of services offered to its customers.
In order to keep track of the effectiveness of the actions taken to positively impact its customers, the Domestic BU has developed a set of processes in line with the main relevant ISO standards (ISO 9001, ISO/IEC 20000-1, ISO 22301), as has the Brazil BU (ISO 9001).
In particular, in Italy TIM is able to deliver high levels of service by having structured internal process controls and adopting solutions that have undergone a multitude of certifications:
In addition, in order to monitor the effective implementation of the planned interventions during 2022, in Italy TIM has drafted and shared a customer experience improvement plan dedicated to Small customers with a focus on the segments to be garrisoned.
The Domestic BU, in line with previous exercises, has developed an extensive listening system capable of surveying the customer experience at different "moments of truth" of customer journeys and at different touch points. Among the processes, of particular importance is the one related to the monitoring of the Customer Satisfaction Index (CSI) - based on the American Customer Satisfaction Index (ACSI) standard - which aims to detect the quality perceived by TIM customers and customers of major competitors in different customer journeys and touch points. CSI's monitoring has achieved certification of compliance with the UNI 11098:2003 standard.
With respect to the processes adopted in order to ensure customer listening, which is instrumental in monitoring the effectiveness of the actions taken, the Brazil BU conducts two types of customer satisfaction surveys:
survey because customers who contact TIM's call center evaluate immediately after "contact", via IVR (Interactive Voice Response) or SMS.
To measure the effectiveness and progress of the actions taken, the TIM Group has defined specific indicators. Specifically, BU Domestic adopted the Customer Satisfaction Index, an indicator used in the managerial (Management By Objectives) and collective incentive system, setting a target for 2022 on the IVQ exit value of 75,63.
In addition, in relation to its services, the Company in Italy has adopted KPIs of infrastructure availability and service request support as well as standard indicators, monitored on a customer basis. In this regard, both the main KPI aimed at assessing infrastructure energy efficiency, Power Usage Effectiveness (PUE), was adopted, setting progressive containment targets, and a set of additional KPIs, of which the main ones are represented below:
• repetitiveness, that is, the number of occurrences of the same malfunction on the same SAP during the observation period.
In line with previous years and referring to litigation management activities, in Italy TIM has adopted specific indicators that decry the degree of transparency with which the Domestic BU communicates the channel for filing complaints to its customers.
As for BU Brazil, the Company monitors a number of effectiveness indicators, such as the average consumer customer satisfaction index, the average mobile consumer customer satisfaction index, the average mobile business customer satisfaction index, and the number of complaints received, in addition to the customer conversion rate.
In 2022, the Domestic BU highlighted the effectiveness of its actions taken, highlighting on the Small customer segment an improvement in the CSI, as well as the following findings within the customer experience KPIs:
The CSI value for the year 2022 achieved by the Domestic BU for Consumer customers is 75.01 (vs 74.29 in 2021 - updated figure based on the base year's revenues); by doing so, the Company was able to maintain a stable performance in the current fiscal year. CSI improvement targets were also set for 2022 on the Small and Medium Business segment, which were fully achieved.
With reference to customer satisfaction indicators monitored by the Brazil BU, an improvement in the average consumer customer satisfaction index was noted in 2022. The remaining monitored satisfaction indicators remained largely unchanged. Compared with the customer conversion rate under the activation portal, in 2022 (January to October) this increased by 400%.
In relation, however, to actions taken to improve the energy efficiency of Data Centers within its services, TIM in Italy recorded an average PUE of 1.54, noting levels of absolute excellence in relation to current market standards.
With regard to litigation management activities with Consumer Associations and the Authority, the Domestic BU improved during 2022 the transparency with which it communicates the channel for filing complaints to customers. In 2022 in Italy TIM showed 10,455 Claims and Joint Conciliation cases with a percentage of positive agreements for the customer of 97.4% (vs 96.9% of Joint Conciliation applications discussed in 2021) and 39,168 cases at Co.Re.Com with a percentage of positive agreements for the customer of 89.3% (vs 88.7% in 2021).
On these issues, in Brazil, according to official SINDEC data, TIM S.A. emerges as the economic group with the lowest number of complaints in PROCONS (which are part of SINDEC), maintaining the fifth position in the complaints ranking for the third consecutive year. In this regard, 2022 saw a major decrease of about 34% (January-November 2022 data) in the number of complaints received (vs 2021).
Realizing that an excellent customer experience increases loyalty, enhances the perceived value of the brand, attracts new customers and is increasingly a central lever to compete and gain market leadership, TIM during the year has continuously carried out initiatives and actions that will allow the Group to ensure a path of continuous improvement with respect to customer experience indicators.
In fact, as a function of its profound commitment aimed at enhancing the customer experience, the Domestic BU has strengthened the omnichannel logic by including in the "offer profile" (Pdo) of Consumer customers the paragraph "Channels and modes of communication to the customer." At the same time, consistent with the above, on the processes most significant to the Small customer experience, TIM has established cross-functional working groups in Italy with the goal of ensuring the best E2E quality, service level trends, and sharing of continuous improvement initiatives and best practices. At the same time, the insights that emerged in carrying out the activities led the Brazil BU to carry out improvement interventions with respect to its digital channels (e.g., website and dedicated apps), with the aim of initiating the development of a new version of the My TIM App, with new technologies, functions and features to improve the customer experience.
With regard to the issue in question, during the year the Group initiated various projects and initiatives in order to follow up on an ongoing discussion with its stakeholders, as it is aware of the importance assumed by these moments in the monitoring and management of the positive impacts associated with the issue itself. In this regard, in Italy, the Operator Listening Project has enabled active involvement by caring operators in identifying possible actions to improve customer satisfaction and the daily activities of operators. In addition, to support the creation or modification of offers/processes, the Domestic BU made use of the "the Lighthouse" community for the Consumer segment, which features internal experimenters who are engaged to live the customer experience at all stages of the customer journey.
In addition, the Domestic BU, in response to the needs of its stakeholders (customers, institutions, investors, etc.), has been equipped with certifications and attestations that aim to keep operational processes under control and guarantee the services provided. In this way, TIM Enterprise - operating under the Domestic BU - is able to assure its stakeholders that the stated goals of ICT infrastructure resilience, availability and efficiency are real and verifiable. These needs are made explicit by stakeholders through various ways, such as, for example, in the context of calls for tenders.
Finally, on the issue of joint conciliation, a topic for which TIM chaired an event at CNEL in 2022 sponsored by Consumer's Forum, was released a new interface platform with Consumer Associations, the MIRART AC, a platform that facilitated the relationship and simplified the management of the process through the possibility of monitoring with more transparency the data of the worked and the received.
TIM can generate an impact on its employees' health and safety (occupational accidents and illnesses), well-being, and work-life balance.
The Organization may generate negative impacts in the performance of typical general & administration activities of its resources.
[GRI 3-3c] Describe its policies or commitments regarding the material topic
The TIM Group has always been committed to ensuring a healthy and safe working environment through full compliance with relevant legislative provisions and by considering the safety and health of employees in the performance of their duties and activities a priority. In fact, the Group ensures full alignment with regulatory references on occupational diseases and occupational health and safety, with the aim of preventing possible accidents and damage to health in any way related to the performance of work.
The Domestic BU analyzes and evaluates risks to workers' safety and health with a view to their progressive reduction, adopting the principles, standards and solutions that constitute national and international best practices, and implementing appropriate prevention measures and verifying their adequacy and effectiveness.
In addition, in order to further strengthen internal management and control methodologies, and to complement the normal implementation of regulations in the management of occupational health and safety, an ISO 45001-compliant management system was implemented within the Domestic BU having all processes related to office and mixed-use real estate assets as its perimeter. In Brazil, TIM is in the process of aligning its internal processes and regulations with the legislative changes that have taken place, while at the same time placing itself at the forefront, through participation in committees led by its union with other telecommunications companies, in reviewing laws that impact its industry,
such as in the area of sizing of technical health and safety teams.
[GRI 3-3d] Describe actions taken to manage the topic and related impacts, including:
Downstream of the materiality analysis, it was found that the main impact related to the material topic is of the actual negative type. For this reason, disclosure was provided solely with respect to the management of this type of impact. However, it should be specified that the TIM Group, in order to ensure transparency and fairness in business management to its stakeholders, has established a solid internal control system, consisting of rules, tools, activities, procedures and organizational structures. In this regard, as part of its risk management system, the Group has adopted an Enterprise Risk Management model capable of identifying potential events that may affect its business activities, including the plurality of ESG risks, enabling it to create the preconditions for planning and implementing initiatives to deal with potential negative spillovers or result in positive economic, social and environmental impacts.
As part of its activities, the TIM Group implements multiple actions to address negative impacts. In particular, the Company, inspired by the principles underlying the proper application of employee health, safety and welfare, has carried out and carries out numerous actions on a daily basis, the main ones of which are listed below:
performance and objectives to ensure a transparent dialogue aimed at promoting a culture of safety inside and outside the Organization.
Within the Domestic BU, the achievement of ISO 45001 certification and the establishment of the Safety Steering Committee is emphasized, with a view to directing and making corporate action on occupational safety and health issues more incisive. In particular, the Steering Committee Safety, chaired by the Chief Executive Officer, was established with the aim of intensifying the commitment on the subject and further structuring the Governance of the Organization on health and safety issues, as well as fostering the integration between the different business departments and execution.
With reference to BU Brazil, a new edition of the Bem+Estar Marathon and SIPAT, the Company's main annual health, safety and environment event, was held in 2022. In fact, in order to help provide a solution for negative impacts through fostering greater awareness of health and safety issues, TIM made a commitment during the period to follow up on this event, which in 2022 observed 12 conferences held online and spread over 2 weeks, with more than 4,000 participants. Topics such as mental health, happiness, longevity, healthy eating, physical activity, mindfulness, motivation, HIV/AIDS, and safety in the hybrid work model were addressed.
[GRI 3-3d.iii] actions to manage actual and potential positive impacts (See point d.i)
[GRI 3-3e] Report the following information about tracking the effectiveness of the actions taken:
In order to monitor and track the effectiveness of its actions, the TIM Group adopts monitoring processes in accordance with relevant standards, principles and good practices, based on systems for measuring recorded performance with reference to occupational health and safety. In this sense, in continuity with the previous year, in 2022 TIM in Italy conducted its monitoring in line with the provisions of ISO 45001, having as its perimeter all processes related to office and mixed-use real estate assets. Continuous monitoring of indicators related to the company's health and safety performance enables the Domestic BU to plan activities, resources and goals in order to provide for progressive elimination or minimization of risk elements and triggers.
The TIM Group adopts specific indicators useful for periodically monitoring progress against its initiatives implemented on the issue. In this regard, among the most significant performance indicators for measuring the effectiveness of the actions taken, TIM considers, for example, the number of accidents (excluding commuting) and the number of accidents per 100 workers.
In addition, in order to encourage the development of its employees' knowledge about the risk of occupational accidents and the negative impacts associated with the topic, TIM in Italy monitors the number of hours of training provided on health and safety, as well as the percentage of such training out of total hours.
Finally, in relation to monitoring the effectiveness of its actions aimed at providing useful solutions for improving working conditions and work-life balance, the Group monitors the turnover rate as an indicator capable of quantifying the degree of resilience of its initiatives aimed at ensuring the livability of the working environment.
The effectiveness of the actions implemented by the Group in activities aimed at managing phenomena related to employee health and safety is evidenced by the following main results achieved:
With regard, on the other hand, to the indicators related to health and safety
knowledge development, the Group observed a total number of hours provided to employees of 133,516, also associated with an improvement in the percentage of total hours, at 5% (vs 3% in 2021).
Finally, as further proof of the effectiveness of the activities implemented by TIM in Italy in order to conduct virtuous management of the issue, within the Domestic BU, management system certification in line with ISO 45001 was obtained.
Over the years, the TIM Group has been committed to, and has been at the forefront of, ensuring the continuous updating of its body of legislation, and thus of its defined internal health and safety policies and procedures, in order to incorporate regulatory developments and ensure a healthy and safe workplace for its employees.
With this in mind, observing the insights emerging from the performance of activities and from the evidence of the analysis of accident phenomena, the Domestic BU over time has taken steps to update its management system, as well as has managed to follow up, by virtue of this, on particular experiments in this area, de facto introducing elements of Digital Safety in line with the activity carried out within its core business.
So, the awareness gained from its own actions and the day-by-day monitoring of the goodness of the progress made, have enabled the TIM Group to further understand the importance of its role in defining a healthy and safe working environment; in fact, it is thanks to the adoption of such a commitment to the topic, declined in terms of policies and operating procedures, that the Company will be able to ensure the constant improvement of health and safety practices in the workplace, as well as to manage in the best way possible the impacts that occur.
Constant discussion with the Group's stakeholders has enabled the pursuit of relevant actions useful in addressing actual negative impacts and providing solutions in the areas of employee health, safety and welfare.
In Italy, in fact, discussions with key stakeholders led to the establishment of the Steering Committee Safety making corporate action on H&S topics more pronounced; this strengthening of commitment will ensure the definition of strategic H&S policies and targets, ensuring their monitoring and control, the determination of transversal and vertical Action Plans and finally the promotion of a corporate safety culture.
In Brazil, on the other hand, through constant discussion with stakeholders and participation in committees led by its industry union, as part of the alignment of business processes and internal regulations with legislative changes, TIM has managed to record substantial progress in revising and adapting internal regulatory documents.
[GRI 3-3a] Describe the actual and potential, negative and positive impacts on the economy, environment, and people, including impacts on their human rights
TIM - through recruitment, retention and engagement policies and practices can generate impacts on the development of the professional and personal skills and career growth of its people.
Downstream of the materiality analysis, it was found that the main impact related to the material topic is of the actual positive type. For this reason, disclosure was provided solely with respect to the management of this type of impact. However, it should be specified that the TIM Group, in order to ensure transparency and fairness in business management to its stakeholders, has established a solid internal control system, consisting of rules, tools, activities, procedures and organizational structures. In this regard, as part of its risk management system, the Group has adopted an Enterprise Risk Management model capable of identifying potential events that may affect its business activities, including the plurality of ESG risks, enabling it to create the prerequisites for planning and implementing initiatives to manage potential and actual negative economic, social and environmental impacts.
[GRI 3-3c] Describe its policies or commitments regarding the material topic The TIM Group aims to be an increasingly inclusive company, capable of taking care
of its People and improving the overall quality of living and working. Satisfaction and engagement are central pillars in the development of the strategy toward People. Demonstrating this commitment, the Group-wide Human Resources, Organization & Real Estate Policy was introduced, which governs all aspects affecting Human Resources, including engagement, development and training. In carrying out its activities, TIM places People at the center through defined paths designed on individuals for career management, the potential of which is useful to meet specific needs depending on roles, organizational positions and skills required in the long term.
Training, through targeted and diversified pathways, supports people in processes to consolidate skills for specific job profiles, soft skills independent of job role, and pathways aimed at upgrading or retraining. The training offer, accessible to the entire corporate population, intends to safeguard People's lifelong learning by encouraging self-training and empowerment on personal learning process useful for safeguarding their employability.
In this regard, over the years the Domestic BU has ensured the pursuit of its goals through policy and practice efforts and by committing to the introduction, within its Sustainability Plan, of the TIM People Plan. Specifically, the "TOGETHER" Plan encompasses all initiatives for people in the Domestic BU aimed at enhancing personal and organizational well-being to work and live better in the company. Starting in 2019, in fact, TIM has launched a major internal listening activity to get a snapshot of various aspects of the bond between the company and its people in order to, among other things, better impact the development of its employees and enhance their capabilities.
[GRI 3-3d] Describe actions taken to manage the topic and related impacts, including:
[GRI 3-3d.i, d.ii] actions to prevent or mitigate potential negative impacts; / actions to address actual negative impacts, including actions to provide for or cooperate in their remediation; (See point b)
During 2022, the TIM Group identified specific actions to manage the actual positive impacts associated with the topic of employees development and motivation.
The following are the main actions carried out for this purpose in Italy:
With reference to BU Brazil, some examples of actions implemented by TIM in order to manage its positive impact on the issue are represented below:
[GRI 3-3e] Report the following information about tracking the effectiveness of the actions taken:
In order to evaluate and monitor the effectiveness of the actions taken in the area of employees development and motivation, the TIM Group has equipped itself with specific processes capable of quantifying the goodness of the initiatives and verifying the achievement of pre-established objectives and targets, through the use of performance indicators.
Through monitoring on an annual basis, the TIM Group adopts the Climate Survey as its main tool to get a holistic view, by business function and socio-demographic cluster, of employee engagement and satisfaction.
At the Domestic BU level, the effectiveness of actions put in place with respect to Welfare services is also monitored through Welfare Survey, which is also useful in identifying any gaps.
With reference to monitoring the effectiveness of the Domestic BU's efforts in relation to the performance development of its resources, TIM has adopted several additional processes, which are outlined below:
to be analyzed prospectively and independently of the role held, so as to ensure more effective organizational planning and enhance individual characteristics;
In line with the 2023-2025 Business Plan, the enhancement of people and their development in terms of professional and personal skills is a priority for the TIM Group. With this in mind, the Group identifies objectives and reference targets, as well as related performance indicators to understand the effectiveness of the activities implemented.
Specifically, under the same Plan, the Group has defined two strategic goals and targets impacting the Domestic BU:
In order to keep track of the effectiveness of actions aimed at developing employees' skills, the Group voluntarily monitors a number of indicators, the main ones of which are given below:
Finally, the Domestic BU monitors the number of certifications related to both technological and methodological issues achieved by staff, attesting to the growth of employees' specialized skills.
The effectiveness of the actions put in place by the Group, with reference to the development and motivation of its employees, is demonstrated by the following results achieved in 2022:
• Positive turnover rate in 2022 of 6% for men and 8% for women;
In the highly evolving environment that has characterized the past few years, the evidence that has emerged in the course of conducting business activities has led the TIM Group to orient its outlook toward an increasingly systemic vision, attaching strategic importance to the needs of the new generations.
As a player operating in the ICT sector, the Group has become increasingly aware of how technological innovation cannot be a stand-alone variable, but must be integrated into the sphere of knowledge and tools available to the corporate population in order to respond to the social and environmental challenges faced by TIM.
With this in mind, the Group invests in its people, understood as a wealth of humanity, experience and expertise that constitutes a unique competitive lever, an element of corporate identity capable of driving the sustainable success of its business. These intentions, in fact, have led the Group to adopt in Italy a People Plan - Plan INSIEME, characterized by numerous initiatives aimed at their development and well-being, and a Group Policy dedicated to Human Resources, the Human Resources, Organization & Real Estate Policy, which aims to ensure the best management and promotion of human capital.
In the context of employees development and motivation, continuous discussion with stakeholders has proven to be a key activity for the TIM Group in order to understand their instances and take the most effective actions to achieve important progress against the monitored indicators and targets set in the Business Plan. Moreover, with this in mind, discussion with corporate Management has been essential. In fact, in Italy, this has been actively involved in the process of assigning goals in the different Engagement Plans and, specifically, for those related to the clusters targeted by the Group, namely youth and women. The active participation of top management, on the one hand, has certainly enabled more effective actions to be taken that meet the needs of employees; on the other hand, at the materiality stage, it has contributed to the identification of a specific material topic focused on the issues of retention, engagement and development of human resources.
[GRI 3-3a] Describe the actual and potential, negative and positive impacts on the economy, environment, and people, including impacts on their human rights
TIM's activities and its value chain may have an impact on climate change in terms of greenhouse gas emissions and global warming as a result of fossil fuel consumption and refrigerant gas leakage.
The TIM Group can contribute to the negative impacts either directly, through its own activities, or also indirectly through the impacts recorded along the entire value chain, with particular reference to the supply chain, which includes, among the main business relationships, relationships with companies operating in the manufacturing, service, content producers sectors.
[GRI 3-3c] Describe its policies or commitments regarding the material topic As one of the leading players operating in the ICT sector, the TIM Group is keenly aware of its role in building a low-carbon future. In fact, the ICT sector structurally rests its business on fixed network, mobile, and data center infrastructures that are energy intensive, growing year by year, impacting the environment in terms
of CO2 emissions. The Group, therefore, has followed up with multiple initiatives to address this phenomenon.
The TIM Group's commitment to contributing to the resolution of negative climate change impacts in terms of emissions is reflected in its strategy, described and disseminated as part of the Group's broader Environmental Policy - structured in line with the main international reference standards (e.g., ISO 14001, ISO 14064, ISO 50001, GHG Protocol), which places, in relation to the issue, among the Organization's main objectives:
In addition, in order to go beyond the normal transposition of regulations in the management of climate change issues, some functions and/or companies in the Group with significant impact on stakeholders have achieved certifications in line with ISO 14001 and ISO 50001.
Further evidence of the Group's emphasis on the material topic is the validation of our emission reduction commitments by the Science Based Targets initiative (SBTi). Finally, the TIM Group is an active member of both specific industry associations and nonprofit organizations with environmental protection as their goal, the main ones of which are listed below:
Downstream of the materiality analysis, it was found that the main impact related to the material topic is of the actual negative type. For this reason, disclosure was provided solely with respect to the management of this type of impact. However, it should be specified that the TIM Group, in order to ensure transparency and fairness in business management to its stakeholders, has established a solid internal control system, consisting of rules, tools, activities, procedures and organizational structures. In this regard, as part of its risk management system, the Group has adopted an Enterprise Risk Management model capable of identifying potential events that may affect its business activities, including the plurality of ESG risks, enabling it to create the conditions useful for planning and implementing initiatives aimed at preventing or mitigating potential negative spillovers or bring about positive economic, social and environmental impacts.
The TIM Group is committed to developing projects aimed at providing and helping to provide a solution to the actual negative impacts on climate change in terms of greenhouse gas emissions and global warming. The most significant actions at the Group level include:
In relation to the initiatives carried out by BU Domestic, the main ones are listed below:
• implementation of projects aimed at saving energy and resources through the implementation of a Building Energy Management Systems, based on a series of HW IoT devices for monitoring, control and advanced maintenance management of technological systems (power and air conditioning) serving the halls of fixed-line power plants;
In addition, the Domestic BU continued the project undertaken in 2021 and starting from July 2023, aimed at implementing a plan to install 14 photovoltaic plants with a capacity of about 0.7 GWp, and also started an extraordinary maintenance work to improve the efficiency of 101 existing small-scale plants in the country with a capacity of about 0.9 GWp, with consequent benefits in terms of emissions.
With reference to the actions carried out by the Brazil BU, TIM over the past few years has implemented a number of initiatives aimed at managing its actual negative impacts, including:
[GRI 3-3d.iii] actions to manage actual and potential positive impacts (See point d.i)
[GRI 3-3e] Report the following information about tracking the effectiveness of the actions taken:
In order to monitor the effectiveness of the actions taken by the TIM Group, with the aim of proactively contributing to the resolution of the actual negative impacts on climate change, the Organization has defined a series of processes, incorporated in policies and operating procedures, which are declined into measurement systems, through indicators aimed at tracking the progress achieved with respect to its objectives and targets defined in this area, in the confirmation of ISO 14001 certification and in obtaining ratings on environmental matters from prestigious international organizations.
In line with what was disclosed as part of the 2023-2025 Business Plan, TIM has voluntarily set ambitious specific targets aimed at ensuring the Group's contribution to the transition to a low-carbon economy. Specifically, the TIM Group has adopted the following targets:
Therefore, in order to assess progress against its objectives and targets, the Group conducts constant monitoring of the following indicators:
In addition, the Group monitors the achievement of awards and ratings that are representative of its environmental performance.
The effectiveness of the actions taken by the Group to manage the actual negative impacts related to climate change is mainly demonstrated by:
The commitment of entities such as the TIM Group to ensure increasingly effective management of the actual negative impacts related to climate change appears to be necessary in light of its size and the specificity of business activities related to the ICT sector, which by its nature is highly energy intensive.
In fact, this awareness has led the Group to regulate in a timely manner the aspects related to the environmental impacts generated by its activities, strengthening its body of legislation on the subject and adopting processes and procedures in line with the main standards on the subject (e.g., ISO 14001, ISO 50001 and SBTi), and paying particular attention to providing proper, transparent and systematic communication to stakeholders of its commitment.
In this regard, the TIM Group understood that reporting up to par, capable of clearly and transparently communicating the actions put in place, the targets adopted, and the progress achieved, can not only ensure the generation of value in terms of brand reputation at the sector level, but at the same time lead the ICT sector itself in the pursuit of national and international ambitions in terms of combating climate change.
The discussion that took place with stakeholders as part of the 2022 materiality analysis, compared to 2021, emphasized the need to assign two distinct strategic relevance to the topics "Climate change" and "Energy transition", highlighting their relative specificities. In addition, the constant discussion conducted with stakeholders on the topic in the course of carrying out daily business activities has proven to be of primary importance in order to guide actions and define the Group's priorities on the issue, supporting the management of actual negative impacts. In fact, the dialogue with stakeholders has incentivized the Organization in implementing the many initiatives aimed at reducing carbon emissions, and in taking on important medium-long-term ambitions aimed at contributing to the transition path to a low-carbon economy of the communities in which TIM operates.
TIM's activities may have environmental, social, and economic impacts associated with the transition from a predominantly fossil energy production and consumption system to one based on renewable and alternative sources.
Downstream of the materiality analysis, it was found that the main impact related to the material topic is a potential positive one. For this reason, disclosure was provided solely with respect to the management of this type of impact. However, it should be specified that the TIM Group, in order to ensure transparency and fairness in business management to its stakeholders, has established a solid internal control system, consisting of rules, tools, activities, procedures and organizational structures. In this regard, as part of its risk management system, the Group has adopted an Enterprise Risk Management model capable of identifying potential events that may affect its business activities, including the plurality of ESG risks, enabling it to create the prerequisites for planning and implementing initiatives to manage potential and actual negative economic, social and environmental impacts.
The TIM Group has always been aware of its role in facilitating the energy transition. Every ICT company can contribute concretely to the energy transition through efficient management of its core business activities (network management and data center) in addition to other characterizing solutions: smart working, telemedicine platforms, sharing and e-learning platforms, and videoconferencing systems are services that can promote more sustainable lifestyles and ensure the performance of activities while safeguarding the environment. The TIM Group is present and active in sector associations and nonprofit organizations whose objectives include environmental protection; in fact, the relevance for TIM of environmental topics and their impacts is highlighted in the materiality matrix, which incorporates the assumptions of the Sustainable Development Goals and is translated into the TIM Energy Transition Strategy, described and disseminated as part of the Group's broader Environmental Policy:
In addition, again in order to go beyond the normal transposition of regulations in the management of energy transition topics and generate value in this regard, some functions and/or companies in the Group with significant impact on stakeholders have achieved and/or confirmed certifications in line with ISO 50001.
[GRI 3-3d.i, d.ii] actions to prevent or mitigate potential negative impacts; / actions to address actual negative impacts, including actions to provide for or cooperate in their remediation;
(See point b)
TIM has always been committed to implementing energy efficiency and rational resource consumption programs: within the Network Operation & Wholesale Department operates the Real Estate - Energy Management & Procurement Function, focused on energy issues with a mandate to identify and finalize appropriate interventions aimed at fostering energy transition. In addition, in liaison and functional coordination with the relevant structures of the Chief Technology Office, the function ensures design and implementation consistency of the adopted solutions with respect to the Company's efficiency plans. Below are the specific areas on which the main actions put in place are focused:
facilitate the use of sustainable means of people in the Domestic BU, such as the plan to replace 25% of the cars in Car Sharing with Full Electric powered cars.
In order to monitor the effectiveness of the actions taken by the Group with the aim of generating positive impacts through its energy transition path, the Parent Company has implemented a series of processes, incorporated in operational policies and procedures, concerning measurement systems, including indicators aimed at tracking progress achieved against its objectives and targets defined in this area, and the achievement/confirmation of ISO 50001 certification for the most representative sites.
In continuity with the targets already set in 2021, TIM confirms for Plan 23-25 the target on renewable energy to cover 100% of domestic electricity needs by 2025, to which the Brazil BU also aligned with 100% share of renewable electricity by the same year. This target enables the Group to make its contribution to relevant national and supranational goals, such as the United Nations Sustainable Development Goals.
In order to assess progress against its goals, TIM continuously monitors the percentage of green energy purchased out of total purchased energy, the increase in self-generated renewable energy use, the coverage of renewable energy by company in the Group, with the breakdown by asset or perimeter, and energy consumption based on non-renewable sources.
In addition, the Group measures its energy efficiency through the eco-efficiency indicator, declined for BU Domestic and BU Brazil, which relates the service offered to customers (transmitted bits) to the impact on the environment (joules of energy consumed).
The effectiveness of the actions taken by the Group to manage the positive impacts and its own goals and targets related to TIM's energy transition path(3) is mainly demonstrated:
• in obtaining certification related to the Energy Management System, in line
(3) The TIM Group companies included in the '22 environmental scope are listed below: TIM S.p.A, Sparkle Group (companies that meet the criteria as reported in the methodological note), Fibercop S.p.A, Noovle S.p.A., Olivetti S.p.A., Telecontact Center S.p.A., Telenergia S.r.l., Telsy S.p.A., TIM Retail S.r.l., TIM Servizi Digitali S.p.A., as well as BU Brazil.
with ISO 50001, for the most representative sites;
TIM's commitment to addressing its energy transition journey has led to an understanding of how optimizing production processes and logistics flows help customers reduce energy consumption generated by physical travel and related emissions. Improved efficiency, savings in economic terms, and reduced impacts on the environment associated with the effective use of TIM services also represent a real business opportunity for the Company: stakeholder and citizen awareness of issues related to the energy transition is growing resulting in a focus on companies that can ensure a sustainable future for the planet and society. All this translates into the incorporation of insights that emerge in the course of carrying out activities within the company's processes and policies, with the aim
Discussion with the Group's strategic stakeholders has particularly conditioned the actions taken related to the topic of energy transition. Specifically, the significance of the impact associated with it led to the separation of the discussion and assessment of impacts from the more generic "Climate change" topic into which it was originally subsumed, highlighting "Energy transition" as a separate topic. This initiative has led the Group to assume a stronger commitment to the topic, influencing planning and enabling more positive performance than in the past.
[GRI 3-3a] Describe the actual and potential, negative and positive impacts on the economy, environment, and people, including impacts on their human rights
Any behaviors of the TIM Group contrary to laws and regulations as well as uncompetitive behaviors may impact both the market environment in which the
of achieving increasingly high-performing results in terms of consumption from year to year.
(4) Also via GO purchase in Italy and RES in Brazil.
Group operates and the stakeholders directly or indirectly related to its activities.
The Organization could be involved in the negative impacts in the operation of its activities.
The TIM Group is committed to conducting its business in full compliance with the regulations and laws in force in the states in which it operates, and with universally accepted ethical principles inspired by transparency, fairness, legality and loyalty. Ensuring full compliance with the provisions inherent to TIM's industry, and to matters such as, for example, anti-corruption, fair competition and taxation, is of utmost importance to the Group, which is committed to doing so through the introduction of ad hoc policies, procedures and tools, as well as through the achievement of prestigious certifications (e.g., ISO 37001).
In particular, in confirmation of the Group's constant commitment to combating corruption in all its forms, TIM has adopted the Anti-corruption Management System (AMS) for which UNI ISO 37001 "Anti-bribery Management Systems" certification was obtained from an accredited body, both in Italy and Brazil.
Within the broader AMS, TIM has defined and periodically updated a number of tools, including, the Code of Ethics and Conduct, with the aim of condemning the use of illegitimate or unfair behavior, while refraining from the conduct, sharing or tolerance of any form of corruption and unfair competition.
The Group's Anti-Corruption Management System complements the broader anti-corruption compliance program, which also consists of the 231 Organizational Model (adopted in 2003 pursuant to Legislative Decree 231/2001 on the administrative liability of corporations) in which the area of corruption prevention is included, the latter adopted in Italy.
In addition, under the AMS, the Parent Company has adopted a Group Anti-Corruption Policy, updated in 2022, in order to represent the systematic framework in which the standards and rules of conduct to be adopted for the prevention of corruption throughout the Organization are defined.
As part of the management of corruption behaviors, the Domestic BU adopts the Whistleblowing Procedure which, where not expressly prohibited by local laws, encourages and allows employees and third parties to report in good faith or based on reasonable belief, behaviors (of any nature, including mere omissions) referable to TIM Personnel and/or Third Parties that are non-compliant/in violation of laws and regulations, the Code of Ethics and the 231 Organizational Model, as well as the system of rules and procedures in force in the Group, including but not limited to policies related to Human Rights, taxation, anti-corruption. As for the Brazil BU, similarly TIM S.A. adopts an ad hoc procedure in order to handle corrupt behavior in the area of whistleblowing.
With reference to the management of taxation, this is inspired by the principles
contained in the Group's Code of Ethics and Conduct, the latter believing that full transparency towards financial administrations is part of its duties as a taxpayer, also in terms of social responsibility. TIM is convinced that full compliance with tax obligations, by all businesses competing in the various markets, constitutes not only a duty of all taxpayers, but also a necessary condition for the establishment of an environment of fair competition, among businesses that compete, and compete, in the same markets. This commitment is reflected in the TIM Group's fiscal operations as outlined in the Fiscal Strategy document.
In relation, on the other hand, to the management of anticompetitive behavior, the Domestic BU over the years has implemented a comprehensive antitrust compliance program, engaging in multiple initiatives with the aim of ensuring more effective antitrust risk management. In addition, TIM in Italy has been committed to ensuring compliance with consumer protection regulations, thanks in part to commitments made in the Unfair Commercial Practices proceedings before the Italian Competition Authority (AGCM).
[GRI 3-3d.i] actions to prevent or mitigate potential negative impacts; As part of the activities carried out by the Group in managing the legal and
regulatory environment, specific actions aimed at preventing and mitigating the potential negative impact associated with the topic have been implemented. Among the most significant actions within the Group are:
In relation to the initiatives carried out by BU Domestic, the main ones are listed below:
the Company is involved, coordinated by the Mergers & Acquisitions Function of Chief Financial Office during the period between July 1, 2021 and May 31, 2022, comply with antitrust regulations on restrictive agreements and abuse of dominant position and must be notified to the AGCM under the regulations on prior control of merger transactions;
following the opening of the 3/18/DRS sanction proceedings for failure to take appropriate measures to ensure the confidentiality of OLOs' customer data when opening fixed-line fault or inefficiency tickets.
With reference, on the other hand, to the activity carried out by TIM S.A., the Brazil BU has carried out several actions aimed at mitigating the potential negative impact resulting from any behavior that does not comply with laws and regulations as well as non-competitive behavior. The main actions conducted in this regard are defined below:
Downstream of the materiality analysis, it was found that the main impact related to the material topic is of the potential negative type. For this reason, disclosure was provided solely with respect to the management of this type of impact. However, it should be specified that the TIM Group, in order to ensure transparency and fairness in business management to its stakeholders, has established a solid internal control system, consisting of rules, tools, activities, procedures and organizational structures. In this regard, as part of its risk management system, the Group has adopted an Enterprise Risk Management model capable of identifying potential events that may affect its business activities, including the plurality of ESG risks, enabling it to create the conditions useful for planning and implementing initiatives aimed at dealing with actual negative spillovers or bring about positive economic, social and environmental impacts.
With the aim of keeping track of the effectiveness of the actions taken to prevent and mitigate potential negative impacts, the Group has developed a series of processes that monitor the indicators adopted on multiple aspects, also taking into consideration the guidance of the main ISO standards on the subject (e.g., ISO 37001).
In addition, the TIM Group has adopted a process for monitoring reports from both internal and external sources (Whistleblowing). In this regard, in Italy TIM uses a single channel for the transmission of reports that can handle them with the maximum guarantee of confidentiality and protects those who adopt it from retaliation. In Brazil, on the other hand, TIM S.A. uses an automated end-to-end reporting management system, accessible via the intranet and from the company website, which can automatically record all reports received and allow status monitoring to the reporter.
In connection with its initiatives to prevent and mitigate the potential negative impact of the identified topic, the Group constantly monitors the occurrence of corruption incidents, the proceedings related to them against Group companies, as well as the annual rate of change in hours of training provided in the area of corruption.
At the same time, by virtue of the training programs provided in antitrust matters in Italy and the commitments achieved in the framework of the investigations with the Authorities, the Domestic BU has evaluated the monitoring of specific indicators capable of annotating the goodness of the actions, among which the main ones are listed below:
In line with its commitment to increase and incentivize employees' knowledge of behavior inconsistent with laws and regulations, thereby preventing their implementation by employees, the Group noted a significant improvement in 2022 in terms of hours of anti-corruption training provided; in particular, TIM showed a 758% increase (174,475 hours in 2022 vs 20,315 in 2021).
In addition, in line with previous years, the Group also found no corruption incidents in 2022.
In relation to the indicators monitored by the Domestic BU, as part of its program carried out, TIM noted a wide coverage of the training courses provided on anti-competitive issues; in fact, the program, concluded in early 2022, showed a utilization rate of 91%, confirming TIM's commitment to preventing possible unfair behavior by developing awareness of it.
Finally, with reference to the current fiscal year, TIM in Italy noted the AGCM's approval of its commitments, which were deemed capable of eliminating the alleged anticompetitive profiles that were the subject of the investigation, and assessed as enabling an increase in the degree of infrastructural competition, causing the proceedings to conclude without the imposition of any sanctions.
The TIM Group's considerable commitment to the proper implementation of behaviors aimed at fostering compliance with regulatory provisions is represented by the multiplicity of initiatives carried out in this regard, and the proper application of them, allows the Organization to be aware of its leading role in the market and the community for full compliance with legality, transparency, fairness and loyalty.
TIM, in fact, has increasingly realized over time that it can set an example for the market and the community at large, by virtue of its business and its importance in the ICT sector as a major player in terms of development, size and relevance. The TIM Group, therefore, will be able to proactively influence the market and the community, both in the present and in the future, through the execution of preventive actions aimed at countering behavior that is not in line with laws and regulations, thus ensuring, at the same time, that the integration of its actions into the company's operating policies can ensure their lasting effectiveness, not only internally but also externally.
Stakeholder engagement was of primary importance for the TIM Group, both in compliance with regulations and in relation to the initiatives conducted in order to prevent non-transparent, unfair and unfair behavior; in fact, the 2022 materiality analysis revealed the need to detect a specific negative and potential impact associated with the topic.
In particular, the managed confrontation with the Authorities was found to be necessary and relevant in order to ensure increasingly robust compliance with regulatory demands and commitments conducted in compliance with the deliberate proceedings against it.
At the same time, with a view to continuous improvement of its employees' compliance with relevant policies and best practices, constant discussion with stakeholders has fostered the adoption of tools aimed at regulating, controlling and monitoring the effectiveness of its actions in the area of anti-corruption, enabling the achievement of important results in line with its expectations.
TIM's processes (e.g., hiring, compensation, career development, financial and non-financial benefits) can impact the Group's diversity, equal pay and opportunity.
The Organization could be involved in the negative impacts through its resource management activities.
Promoting a corporate culture marked by respect, inclusion and appreciation of diversity, ensuring equal opportunities on every aspect to all employees, is a matter of fundamental importance to the TIM Group. TIM's commitment to the topic is defined first and foremost within the Code of Ethics, where it is stated that for the Group one of the critical success factors is the contribution that each person can make to the Organization, where diversity is considered a strategic asset for long-term sustainable growth. TIM's commitment was also renewed through the Human resources, Organization & Real estate Policy, which makes explicit the Group's principles aimed at ensuring an inclusive work environment, in the belief that there is a deep and positive relationship between inclusion and business performance. In fact, the Group guarantees equal opportunities in hiring, remuneration, access to training, promotion, retirement, in relation to race, class, nationality, religion, disability, sex, gender, sexual orientation, union membership or political affiliation, and age, taking into account the cultural and legal peculiarities of individual countries. Within the same Policy, discipline was given to compensation policies, among other aspects. TIM's Remuneration Policy, in fact, aims to support the achievement of the guidelines defined in the Business Plan, ensuring on the one hand, the competitiveness of the company in the market, and on the other hand, the protection of the principles of equity. The goal is to have a compensation architecture that provides for the balancing of the monetary component of compensation (fixed and variable pay) and the enhancement of the nonmonetary component (benefits and welfare).
In addition, TIM is a founding partner of "Valore D," an association of companies for the promotion of women's employment and leadership, the main initiative under its Diversity and Inclusion (D&I) program in Italy. In this regard, the Group has certified its practices in line with the UNI ISO 30415 "Human Resource Management Diversity and Inclusion" standard and, in 2023, will engage in the drafting of a Career Policy, including a specific affirmation on the gender gap, and will embark on the path of obtaining UNI PdR 125:2022 (Certification for Equal Gender Opportunity).
Finally, the company has committed, with the signing in 2017 of the Manifesto for Women's Employment and the publication in March 2020 of the TIM Manifesto for Reducing the Gender Gap, to monitor company performance on certain areas such as gender quotas, the pay gap, succession and promotions, talent management, STEM subjects and professions, training, parenting, and flexibility tools.
With respect to the material topic of equal pay and opportunity, TIM is committed to taking all necessary actions to prevent and mitigate potential negative impacts. In this regard, the Domestic BU, in order to ensure equal opportunity and enhance diversity and inclusion, has developed the Diversity & Inclusion program, which has 5 specific areas: dissemination of the Culture of Inclusion, Disability Management, Longevity Management, Gender Gap, and LGBT Management. Under the program, among others, TIM in Italy conducts the following actions:
and adapt to the specific needs of this category of workers;
Another strategic project carried out in D&I by the TIM Group in Italy is the Women's Project, developed in three areas: Climate & Nature, Empowerment & Career and Governance & Address, aimed first and foremost at reducing the gender gap and improving women's perceptions of equal opportunities in the Company. Included in the actions of this project are initiatives such as:
With reference to the equal pay aspect, the Nominating and Remuneration Committee is in charge of establishing Variable Incentive Plans with predetermined and measurable financial and non-financial objectives, consistent with the Strategic Plan, setting short and medium-long term incentive targets (MBOs and LTIs) in order to be able to guarantee equal treatment in this regard. In this regard, as part of its Remuneration Policy, the Group has adopted management incentive goals that promote, for example, equal pay and opportunity, particularly related to the gender pay gap and the percentage of women in senior positions.
With respect to BU Brazil, some main actions carried out by TIM S.A. are listed below:
professionals, as part of the activation of the Black People Development Program, offering them the opportunity to grow in their careers and gain a leadership position in the future;
• launch of the Crash Program, created to accelerate the hiring of people with disabilities and educate all staff on the inclusion of this segment.
Downstream of the materiality analysis, it was found that the main impact related to the material topic is of the potential negative type. For this reason, disclosure was provided solely with respect to the management of this type of impact. However, it should be specified that the TIM Group, in order to ensure transparency and fairness in business management to its stakeholders, has established a solid internal control system, consisting of rules, tools, activities, procedures and organizational structures. In this regard, as part of its risk management system, the Group has adopted an Enterprise Risk Management model capable of identifying potential events that may affect its business activities, including the plurality of ESG risks, enabling it to create the conditions useful for planning and implementing initiatives aimed at dealing with actual negative spillovers or bring about positive economic, social and environmental impacts.
[GRI 3-3e] Report the following information about tracking the effectiveness of the actions taken:
In order to keep track of the effectiveness of the actions TIM has taken with the aim of ensuring equal pay and equal opportunities, the Group adopts measurement systems aimed at the constant monitoring of diversity and inclusion and equal pay indicators, subjecting itself, in addition, to different assessment processes conducted by external agencies to receive an assessment with respect to its level of maturity in relation to Diversity, Inclusion and Gender Equality topics (e.g., Bloomberg, Refinitiv).
In addition, a Salary Review Rolling process is conducted annually at the Domestic BU level in order to progressively align fixed compensation with market practices, intended as a tool for attracting and retaining resources of high managerial ability, while respecting economically sustainable business management. In addition, the Nominating and Compensation Committee conducts specific analyses to monitor the Gender Gap & Inclusion over time.
In line with the TIM Group's ambitions regarding the enhancement of diversity and equal opportunities, each year the Group sets itself increasingly challenging goals, monitored through specific performance indicators that enable it to understand the effectiveness of the actions taken.
Specifically, as part of the new 2023-2025 Business Plan, the Group has a goal of achieving ≥29% women in leadership positions by 2025. In order to evaluate the goodness of the actions taken useful for the achievement of this objective, the Group monitors the percentage of female presence within the Collegiate Bodies. Added to this is the monitoring of additional specific indicators such as:
With reference to BU Domestic, targets have been set related to the shortand long-term variable incentive system intended for a part of the company management, such as:
With specific reference to the Brazil BU, in line with the ESG Plan, the Company has the ambition to achieve:
In line with these objectives and, more generally, with the goal of ensuring equal pay and opportunities in the Company, the Group monitors, among others, the following performance indicators:
The effectiveness of the actions implemented by the Group with regard to equal pay and equal opportunity is demonstrated by the achievement of the following results:
In a context in which attention to respecting and valuing diversity is increasingly high, for the TIM Group, the commitment made through initiatives aimed at communicating a strong sensitivity of the same to these topics leads to an improvement in its brand reputation but above all in its performance, enabling the definition, in this way, of an organization that is inclusive, attracts new talent and ensures the well-being of its resources in the performance of its activities. This focus led TIM to be the first company, in the Italian panorama, to undertake an Equity & Inclusion Management program and, since 2009, to introduce the figure of the Diversity Manager.
The commitment put in place, has also led the Group to further structure its practices and processes, including introducing supporting Policies, in order to achieve increasingly relevant performance in this regard, to the point of becoming the first telco Group in the world to be included in the Top 100 of the Refinitiv D&I Index and to ensure its presence, for the third consecutive year, within the Bloomberg Gender Equality Index (GEI).
Achieving a work environment in which there are no distinctions of any kind, all physical and cultural barriers are broken down, and a culture of inclusion and valuing diversity is spread, is only possible if the Company has continuous moments of discussion with its stakeholders. The activities, in fact, of internal and external discussion with stakeholders make it possible to determine a widespread sensitivity on the topic and to collect different opinions, instances and ideas, which allow rethinking the initiatives aimed at inclusion and enhancement of diversity and to initiate projects that affect the areas in which deficiencies are detected.
This approach has enabled the Group to achieve very significant results, including the recent achievement of UNI ISO 30415 "Human Resource Management Diversity and Inclusion" certification.
[GRI 3-3a] Describe the actual and potential, negative and positive impacts on the economy, environment, and people, including impacts on their human rights
The TIM Group - through communication mechanisms (reporting, systematic transmission of information related to corporate trends and performance), involvement and collaboration with its stakeholders - can generate impacts on local and non-local communities by supporting their development and fostering initiatives related to social, environmental and volunteer projects.
Downstream of the materiality analysis, it was found that the main impact related to the material topic is of the actual positive type. For this reason, disclosure was provided solely with respect to the management of this type of impact. However, it should be specified that the TIM Group, in order to ensure transparency and fairness in business management to its stakeholders, has established a solid internal control system, consisting of rules, tools, activities, procedures and organizational structures. In this regard, as part of its risk management system, the Group has adopted an Enterprise Risk Management model capable of identifying potential events that may affect its business activities, including the plurality of ESG risks, enabling it to create the prerequisites for planning and implementing initiatives to manage potential and actual negative economic, social and environmental impacts.
TIM Group companies, insofar as they are fully integrated with the territory in which they operate and with the related social and economic-productive fabric, intend to contribute to the economic well-being and growth of communities, responding to the needs of the community, even in its weakest components, through communication, the development and delivery of services that are increasingly digitized and increasingly oriented toward fostering sustainable lifestyles, and support in the development of projects with a social-environmental impact.
The TIM Group has always stood out for its sensitivity and attention to the needs of society by also acting through its foundations. In particular, in Italy the Domestic BU introduced the TIM Foundation by promoting and spreading the culture of innovation through initiatives and projects that promote social inclusion, research and education, art and culture in all expressions, in ways and strategies that are in line with its statutory purposes and values.
In addition, the TIM Foundation pursues its mission through calls for proposals or by directly awarding grants, funding private and public nonprofit or religious entities, in line with the provisions of its Regulations.
BU Domestic also supports humanitarian, scientific, social promotion and environmental protection projects of Third Sector Entities, as well as those in support of national emergencies sponsored by the Civil Defense, by making available solidarity numbers, such as solidarity text messages and landline calls, and by fully disbursing donated amounts to the sponsoring entities.
Regarding BU Brazil, the commitment implemented by TIM S.A. aims to promote the social inclusion of disadvantaged groups in Brazilian society, particularly children and adolescents, through the implementation of educational programs related to Science, Technology and Innovation (STI). In fact, Instituto TIM was founded with the goal of defining strategies and providing resources for the dissemination of science, technology and innovation to support community development in Brazil.
The TIM Group structures its activities on the continuous discussion and involvement of its stakeholders, both internal and external, communicating to them its environmental, social and governance performance through the publication of the Group's Sustainability Report, with a view to maximum transparency. Engaging them is considered essential in order to understand their views and achieve improvements with respect to the Organization's environmental, social and governance performance, aiming to maximize reputation and value.
With a view to constant involvement and collaboration with the Institutions, the TIM Group maintains a collaborative and transparent relationship with supranational, national and local Institutions, with the aim of facilitating dialogue on issues of common interest and ensuring proper representation of the Organization's position in Italy and Brazil, the main ones being:
• central national Institutions, such as Parliament, Government, Ministries and Public Administration;
[GRI 3-3d.i, d.ii] actions to prevent or mitigate potential negative impacts; / actions to address actual negative impacts, including actions to provide for or cooperate in their remediation;
(See point b)
The TIM Group has carried out and continues to carry out specific actions aimed at managing actual positive impacts by virtue of its commitment to ensuring greater involvement and collaboration with institutions, better communication with its stakeholders, and the development of initiatives that can contribute to the economic well-being and growth of communities.
The most significant actions at the Group level include:
In relation to the initiatives carried out by BU Domestic, the main ones are listed below:
With reference to the activity carried out by BU Brazil, TIM S.A. has implemented a series of initiatives aimed at managing actual positive impacts. The main actions are summarized below:
In order to keep track of the effectiveness of the actions taken by the TIM Group, which aim to generate real positive impacts on local and non-local communities, the Organization has defined processes capable of quantifying the goodness of its initiatives.
In this regard, in fact, the Group has structured a series of processes that are translated both into measurement systems, through the monitoring of specific indicators, and into public performance reporting systems, through the publication of annual sustainability reports and assessments organized by prestigious rating agencies.
As part of its own monitoring processes conducted by the Group in order to detect the effectiveness of the actions implemented to manage the positive impacts related to the topic, TIM monitors, for example, the economic magnitude and/or coverage and involvement of people within the initiatives carried out as a function of the efforts made through Fondazione TIM, in Italy, and Instituto TIM, in Brazil, as well as the number of solidarity campaigns activated by the Domestic BU and the collection, in economic terms, related to them.
In addition, in order to provide transparent and clear reporting of its ESG performance to stakeholders, the Group monitors certification by an independent third-party organization and subsequent publication of its annual Sustainability Report, and participation in assessments conducted by rating agencies and the subsequent obtaining of public ratings representative of its performance.
The effectiveness of the actions taken by the Group in order to manage the actual positive impacts related to the topic can be demonstrated mainly by the following findings:
Over the years, the TIM Group's commitment to ensuring clear and transparent communication to its stakeholders and to fostering the socio-economic development of the communities in which it operates has become even more evident through the increasing ESG disclosure activities it has put in place and the establishment and operation of its Non-Profit Organizations (TIM Foundation in Italy and Instituto TIM in Brazil), which have acted, and still act, to ensure greater sensitivity and attention to the needs of society.
The TIM Group, in fact, by virtue of its relevance in the sector and its market positioning, is aware that it has an important responsibility towards the community, since it is able to channel substantial resources, not only economic, towards projects and initiatives that contribute to the socio-economic well-being of the territories.
At the same time, the Group has realized that ESG topics are now a necessary area of disclosure to incentivize sustainable community development and progress; which is why, it has strengthened its ESG Reporting process over time, digitizing it and leading to an increasingly widespread involvement of its people. The same motivations, have also led the Group to take part in an increasing number of public sustainability assessments conducted by the world's leading rating agencies, ensuring clear and transparent outward reporting of its ESG performance.
The TIM Group annually conducts materiality analysis in order to incorporate stakeholder input into its sustainability priorities. In 2022, discussions with various stakeholders at the materiality stage revealed the increasing importance attached by Institutions and society at large to ESG indicators. In particular, it brought out how the topic of community and stakeholder relations can have important feedback in terms of the TIM Group's positive impacts to the outside world.
In addition, ongoing discussion with the Group's stakeholders has proven to be crucial in order to pursue specific actions aimed at ensuring positive impacts on local and non-local communities. In fact, through continuous involvement and collaboration with them, the Group has been able to plan initiatives and monitor the progress of implemented actions aimed at communities.
Specifically, its presidium within important working groups that deal with topics close to both the Organization and the community has enabled the Group first to understand more clearly and comprehensively the needs of the community, and then to make their implementation possible through the development of calls for tenders and the provision of donations and economic resources capable of following up on its social commitment.
TIM can generate impact through useful activities to address major public health risks (including the spread of infectious diseases and possible pandemics), lifethreatening noncommunicable diseases, and natural and human-induced disaster events.
[GRI 3-3b] Report whether the organization is involved with the negative impacts through its activities or as a result of its business relationships, and describe the activities or business relationships
Downstream of the materiality analysis, it was found that the main impact related to the material topic is of the actual positive type. For this reason, disclosure was provided solely with respect to the management of this type of impact. However, it should be specified that the TIM Group, in order to ensure transparency and fairness in business management to its stakeholders, has established a solid internal control system, consisting of rules, tools, activities, procedures and organizational structures. In this regard, as part of its risk management system, the Group has adopted an Enterprise Risk Management model capable of identifying potential events that may affect its business activities, including the plurality of ESG risks, enabling it to create the prerequisites for planning and implementing initiatives to manage potential and actual negative economic, social and environmental impacts.
The TIM Group has among its founding values the protection of human resources inside and outside the Organization, the safeguarding of the value of its own and third parties' tangible and intangible assets, and the continuity and quality of telecommunications services.
The communications network has always been a strategic infrastructure for the social and economic fabric; as such, it is interdependent on other critical infrastructures. Communication services are, in fact, essential services for a community, and they become even more so in the emergency phase; for this reason, TIM is called upon to be part of any Crisis Units activated at the institutional level. Therefore, the Group prepares and maintains an efficient Crisis Management System aimed at preventing a state of emergency/crisis and, where not possible, managing and overcoming it as best it can.
The TIM Group's Crisis Management System is aimed at:
The protection of communities and tangible and intangible resources, is also realized through the management of the plurality of risks so-called "noncompetitive", to which they are exposed. These risk scenarios are constantly evolving, due in part to, for example, the effects of climate change, cybersecurity threats, terrorism phenomena, and, more broadly, national and international socio-political events, and must be managed, to the extent possible, through positive-impact strategies, processes, and actions.
The "Group Policy for Crisis Management" defines responsibilities, processes, organizational and managerial dynamics that must be activated during emergencies/crises, in order to plan and apply suitable methodologies and techniques to cope, in a very short time, with events of high severity, minimizing their consequences, including the long-term ones, highlighting the Group's resilience to non-competitive risks. This Policy applies to:
[GRI 3-3d.i, d.ii] actions to prevent or mitigate potential negative impacts; / actions to address actual negative impacts, including actions to provide for or cooperate in their remediation; (See point b)
In carrying out its activities, the TIM Group has identified specific actions aimed at managing the actual positive impacts associated with the material topic. The following are the main ones:
services. Specifically, the Security Control Room (within the Chief Public Affairs & Security Office/Physical Security) is the unified collection and monitoring center for all reports of critical events and emergencies/crises;
• integration of climate change risks within the Group's risk matrix so that these are monitored, prevented and mitigated. Examples may be physical hazards related to rising temperatures causing extreme and unexpected atmospheric precipitation, landslides, floods or overflows, and transition hazards, with reference to BU Domestic; other examples related to physical hazards, concerning BU Brazil, are inherent in water shortages, storms and cyclones.
In order to foster the continuous improvement of the practices adopted by the Group in managing the actual positive impacts generated with respect to the material topic, TIM monitors the effectiveness of its actions taken through specific processes that detect their quality in achieving the Organization's objectives, through the use of performance indicators. The same goals are also pursued through the processes aimed at obtaining relevant certifications for the highest impact sites from independent third parties (e.g., ISO 14001, ISO 27001, ISO 45001).
The Group's goal is to align itself with the provisions contained in the relevant regulations by addressing, through its positive impact actions, the main risks to public health, events related to natural disasters and socio-political phenomena, bringing value in this regard and fulfilling any requests received by the Company from institutions, especially during emergencies. Furthermore, in order to positively impact climate change by contributing to national and supranational climate change targets, the Group has taken on the ambitions of becoming Carbon Neutral (Scope 1+2) by 2030 and Net Zero (Scope 1+2+3) by 2040, making its contribution to averting the occurrence of natural disasters.
To this end, the TIM Group monitors a number of useful indicators to assess progress in this regard:
In addition, in case of emergencies, the heads of activated OCTs monitor the actions taken during the management of the specific emergency and share their results with other facilities, including in the post-emergency period in order to improve planning.
The effectiveness of the efforts and actions put in place by the TIM Group is proven:
Within the Crisis Management cycle, which consists of 4 phases (planning, preemergency/crisis, emergency/crisis, and post-emergency/crisis), the activities and studies conducted by the actors assigned to ensure the management of crises and emergencies in the Company have led the Group to give increasing attention to the planning (or re-planning) phase aimed at analyzing the findings of emergency/crisis management and improving the processes of the Crisis Management System. In addition, with the aim of speeding up the operation and synergy of the actions deployed among the corporate functions involved, the Group has agreed on the adoption of digital modes of organizing OCT meetings.
[GRI 3-3f] Describe how engagement with stakeholders has informed the actions taken (3-3-d) and how it has informed whether the actions have been effective (3-3-e)
Cooperation with institutions, both in the so-called "ordinary time" (also called "peacetime") that in times of crisis, allows the Group:
Results useful for the improvement of the Crisis Management System are shared with the Crisis Management Committee and Operational Crisis Teams, who participated in the emergency management, through post-emergency and post-exercise debriefings conducted both within the Company and within the institutional tables activated.
Significant results for the entire Group are also shared with stakeholders through internal communication initiatives. Some of these initiatives are also aimed at supporting communication campaigns promoted by institutions and aimed at
increasing awareness of risks and developing a culture of prevention among citizens, creating shared value in this regard.
Finally, entering into agreements, partnerships and conventions has improved the processes of service delivery required by Institutions.
[GRI 3-3a] Describe the actual and potential, positive and negative impacts on the economy, the environment, and people, including impacts on their human rights
TIM - through the activities of qualification, management of purchase requests and tenders, formalization and execution of contracts, and performance evaluation of its supply chain - can reduce the ESG impacts generated by its suppliers. In addition, procurement activities that employ local resources can stimulate economic growth and development while generating social, business and employment opportunities for local residents.
Downstream of the materiality analysis, it was found that the main impact related to the material topic is of the actual positive type. For this reason, disclosure was provided solely with respect to the management of this type of impact. However, it should be specified that the TIM Group, in order to ensure transparency and fairness in business management to its stakeholders, has established a solid internal control system, consisting of rules, tools, activities, procedures and organizational structures. In this regard, as part of its risk management system, the Group has adopted an Enterprise Risk Management model capable of identifying potential events that may affect its business activities, including the plurality of ESG risks, enabling it to create the prerequisites for planning and implementing initiatives to manage potential and actual negative economic, social and environmental impacts.
The relationship and activities carried out with suppliers are governed by the Purchasing Policy for Products and Services, with the aim of governing the management of ESG topics within supply relationships, generating positive impacts on people and the environment.
The document, which can also be consulted and downloaded from the institutional website www.gruppotim.it, helps guide the Group's purchasing policies in favor of products and services that have a low environmental impact, and that take workers' rights into account in their production and delivery.
In this regard, the Policy governs the Group's commitment to take into account and manage the environmental, social and economic impacts arising from its activities in its close relationships with its suppliers. In fact, the TIM Group's purchasing process is aimed at ensuring the procurement of products and services in line with the needs and timing appropriate to carry out its activities, ensuring the optimization of the overall cost and, at the same time, the requirements of quality, safety and environmental protection of the products/ services purchased, in compliance with the current regulatory and procedural framework. Specifically, the process is implemented through the comparison of technical/economic bids from qualified suppliers, according to Group-wide company procedures that are based on, among other things, negotiating ethics, regulations and sustainable aspects.
In addition, TIM is committed to encouraging suppliers' continued pursuit of innovative technological solutions in the area of environmental sustainability, as well as social and economic sustainability, by promoting best practices and duly taking them into account in the Vendor Rating methodology.
[GRI 3-3d.i, d.ii] actions to prevent or mitigate potential negative impacts; / actions to address actual negative impacts, including actions to provide for or cooperate in their remediation; (See point b)
In the area of supply relationships, the TIM Group deploys a series of specific actions aimed at managing them virtuously and in line with best practices, generating positive impacts. The main ones are explained below:
• actions to encourage and engage suppliers to develop a proactive approach to
sustainability issues and provide sustainable solutions;
In order to monitor the effectiveness of the actions taken and principles adopted, with which suppliers must comply, the Group has established monitoring processes that examine different specific indicators and evaluation/control of the economic operators with which it has supply relationships.
In particular, TIM conducts audits of suppliers, either directly or through external bodies, including in cooperation and through agreements with partners or other operators active in the telecommunications sector, such as within the framework of the Joint Audit Cooperation - JAC initiative (http://jac-initiative.com) of which TIM is a founding member. JAC is a collective of telecommunications companies that aim to promote safe and fair working conditions and responsible business, social and environmental management. If the checks yield negative results, appropriate corrective measures are taken in accordance with the provisions of the contracts to ensure that the sustainability requirements set out in the JAC guidelines and protocol are met, ensuring continuous performance improvement in this regard.
As part of its environmental ambitions impacting the supply chain, the Group has taken on the Scope 3 emissions reduction target of 47% (categories 1, 2 and 11 GHG Protocol - 2019 baseline) by 2030. In order to assess progress against the same target, TIM monitors the amount of indirect emissions generated within the supply chain, specifically, through purchased products and services (GHG Protocol category 1) and purchased capital goods (GHG Protocol category 2). In addition, the TIM Group monitors a number of additional indicators useful for assessing progress against its sustainable sourcing practices, including:
The effectiveness of the actions implemented by the TIM Group for the purpose of sustainable management of its supply chain is demonstrated through the results achieved during the period, including:
In carrying out its business activities, the TIM Group has become increasingly aware of how crucial it is to define a collaborative relationship with its suppliers and partners marked by sustainability values and practices in order to achieve continuous improvement in the purchasing process. In fact, the supply chain is considered an integral part of the business, whose actors play a crucial role in creating value both inside and outside the Organization.
With this in mind, TIM in 2022 became a value chain Partner of the Open-es alliance, which through a platform and ESG assessment system based on international standards, provides analytical tools to create a sustainable development ecosystem. At the end of 2022, there are 921 TIM suppliers registered in the platform, 360 of which belong to the ESG risk market.
TIM has also gradually introduced sustainability parameters at the line request phase and in tenders where, if applicable, a sustainability grid is included alongside the technical and economic one with a weight of up to 10%.
The Organization carries on an ongoing discussion with its stakeholders in order to understand their expectations with respect to the principles and good practices to be put into practice in the context of supply relationships.
This comparison has led the Group, over time, to define and update its policies governing procurement in a sustainable manner, summarized in the Product and Service Purchasing Policy, adjusting the Company's internal processes. Confrontation with the market and increasingly demanded ESG requirements in tenders is leading to the incorporation of ESG criteria in supplier selection and in the choice of products/services to be purchased.
Finally, the discussion with stakeholders that took place as part of the 2022 materiality analysis highlighted the importance of the positive impacts generated by the Group through its sustainable sourcing practices, consequently confirming the goodness of the path taken in this regard, and further orienting the Company's focus toward the challenges of sustainable development that characterize supply chains.
[GRI 3-3a] Describe the actual and potential, negative and positive impacts on the economy, environment, and people, including impacts on their human rights
TIM's activities can have an impact on human rights, especially along the value chain. In particular, such impacts could involve violations of basic human rights, as well as legal rights and labor relations principles, and could affect freedom, dignity, equality and justice.
The TIM Group could contribute to the negative impacts both directly, through its own activities, but especially indirectly along the entire value chain, with particular reference to the supply chain, which includes, among its main business relationships, relationships with companies operating in manufacturing, services, and content producers.
The TIM Group operates in full compliance with the relevant regulations to which it is subject in all the countries in which it operates, striving to prevent any human rights violations that might occur in the conduct of its operations and mitigating the associated potential negative impacts. The human rights identified by TIM include not only human rights common to all industries, such as respect for the right to fair remuneration, non-discrimination, no use of forced/compulsory/ compulsory labor, etc., but also human rights peculiar to a telecommunications company, such as the right to access information, freedom of expression (especially online expression), protection of privacy and online safety, and protection of children (e.g., from cyberbullying).
In this regard, the Group's commitment to the respect and protection of human rights and labor standards is set forth in the Code of Ethics, in which document the prohibition is enshrined with respect to any form of discrimination or harassment, whether based on sex, sexual orientation, race, ethnic origin, citizenship, language, religion, political or other opinions.
This principle is reiterated in all relevant Group Policies on the subject, first and foremost the Human Resources Policy in which not only all forms of discrimination but also harassment or bullying are condemned. More specifically, as part of the Human Rights Policy, the TIM Group defines its commitment to becoming a promoter of the same rights and a proactive leader in initiatives and networks concerning them, both nationally and internationally.
These reasons led the Group, in 2002, to become a signatory to the UN Global Compact, constantly encouraging its partners to commit to the protection of human rights through the adoption of specific international Declarations and Guidelines (e.g., the UN International Bill of Human Rights; the Declaration on Fundamental Principles and Rights at Work, issued by the International Labor Organization (ILO); the ISO 26000 Guidelines for private and public organizations of all sizes, etc.).
As a further demonstration of its commitment to the topic, TIM in Italy also introduced, in May 2021, the Policy Management of incidents of gender, sexual and bullying harassment, which enshrines the complete non-tolerance of behaviors assimilated to this type of episodes, through awareness-raising and training activities regarding both the functioning of the Policy itself and the tools for preventing and managing harassment, guaranteeing protection and privacy to possible victims.
Finally, the Group is one of the founders and active participants in the local Global Compact Italy and Brazil Networks and the Joint Audit Cooperation (JAC), an ICT sector-specific initiative that aims to raise human rights-related standards along the supply chain.
In order to prevent or mitigate potential negative impacts related to the topic of human rights advocacy, the TIM Group has undertaken a number of initiatives and actions over time, such as:
In addition, the human rights (in)formation path has been launched in Italy, which is a digital tour that aims to expand knowledge with respect to the same rights, consisting of seven stages at the end of which you have all the necessary information on what to do in case you suffer a violation of one of the human rights or witness it.
On the other hand, as far as the Brazil BU is concerned, TIM has implemented the "Respeito Gera Respeito" (Respect begets Respect) program, which aims to combat all forms of violence, bullying and all types of harassment through monthly trainings for employees aimed at spreading a culture based on respect. In addition, a partnership with Instituto Avon, the company that developed "Angela," a WhatsApp chatbot that helps Brazilian women in situations of violence, was finalized, and membership in the Coalizão Empresarial Pelo Fim da Violência Contra Mulheres e Meninas, an important business movement fighting against gender-based violence, was established.
Downstream of the materiality analysis, it was found that the main impact related to the material topic is of the potential negative type. For this reason, disclosure was provided solely with respect to the management of this type of impact. However, it should be specified that the TIM Group, in order to ensure transparency and fairness in business management to its stakeholders, has established a solid internal control system, consisting of rules, tools, activities, procedures and organizational structures. In this regard, as part of its risk management system, the Group has adopted an Enterprise Risk Management model capable of identifying potential events that may affect its business activities, including the plurality of ESG risks, enabling it to create the conditions useful for planning and implementing initiatives aimed at dealing with actual negative spillovers or bring about positive economic, social and environmental impacts.
[GRI 3-3e] Report the following information about tracking the effectiveness of the actions taken:
In order to ensure respect for fundamental human rights, the TIM Group has specific processes in place to monitor the degree of maturity of the practices and policies that the Organization deploys with respect to the topic. In fact, periodically, it is planned to conduct an internal due diligence process carried out on the basis of the Guiding Principles on Business and Human Rights, approved by the UN Human Rights Council in June 2018, with the aim of:
In addition, the TIM Group has adopted a process for monitoring reports from both internal and external sources (Whistleblowing), and conducts periodic monitoring processes through measurement systems that consider particular performance indicators.
[GRI 3-3e.ii] goals, targets, and indicators used to evaluate progress; In line with the principle that Freedom, Justice and Peace are at the foundation of
the Organization, the TIM Group's ambition is that no incidents of human rights violations occur throughout the value chain.
In this regard, in order to assess the effectiveness of the actions put in place by the Group with respect to the defense of human rights and evaluate the progress made, TIM monitors specific indicators, including:
The effectiveness of the actions taken can be demonstrated through the results achieved by the Group, including:
In the course of carrying out its business activities, the TIM Group has become increasingly aware of how crucial it is for the TLC sector to ensure the defense of human rights, by virtue of the fact that, among others, it is through the accessibility of new technologies that situations can arise in which the right to privacy and the protection of personal data, the right to freedom of expression, the failure to protect minors from adult content, and the occurrence of incidents of harassment are not respected.
This awareness has led TIM to define, as part of its Policy dedicated to human rights, a broader meaning of the term "human right," which goes beyond "basic" human rights, and considers the specificity of the Group's business, including, therefore, the right to access to information, freedom of expression (especially online), the protection of privacy and online safety, and the protection of minors (e.g., cyberbullying).
The feedback gathered from stakeholders as part of the due diligence process conducted by TIM (concluded in 2014), highlighted the need to prepare a TIM Group Human Rights Policy (about 2/3 of the insufficient self-assessments concerned this aspect), leading the Group to prepare a document on the subject. In addition, in 2022, the discussion with stakeholders that took place as part of the materiality analysis enabled the TIM Group to identify the topic of defending human rights as a material topic, despite the fact that the Organization operates in countries with a low/medium risk of human rights violations and in a particular sector such as telecommunications, leading the Group to increasingly place people at the center of its strategies and to guarantee them a work environment in which the protection of fundamental rights is guaranteed and encouraged.
[GRI 3-3a] Describe the actual and potential, negative and positive impacts on the economy, environment, and people, including impacts on their human rights Through its activities, TIM handles a large amount of sensitive data, which could give rise to exploitation, abuse or harmful practices, considering the increasingly prevalent phenomena of internet bullying, child pornography and online gambling.
The Organization could be involved in the negative impacts in the operation of its core activities.
The TIM Group, as part of its activity carried out within the ICT sector and in full compliance with current regulations, is constantly committed to combating any episodes of cyberbullying, child pornography and online gambling, providing customers with a series of tools to protect minors from access to sensitive content offered, and providing constant updating and related communication.
In this regard, because of the aforementioned commitment to preventing harmful practices in this area, the Group has expanded the definition of human rights within its Human Rights Policy to also cover all areas concerning children, such as cyberbullying.
As a further demonstration of its commitment, BU Brazil has decided to join the cooperation agreement against pedophilia with SaferNet and other entities/ companies, taking on the task of combating and preventing crimes committed through the Internet; at the same time, in Italy TIM is active in Working Groups in the OECD and B20, also participating in multiple institutional tables, such as "Alliance to better protect minors online" launched by the European Commission.
In addition, in relation to its activities in Italy, TIM has introduced, from an organizational point of view, the role of "Referent for the Postal Police," included in the Security Operations Center (SOC) Function within the Public Affairs & Security Office. This figure is in charge of managing relationships and information flows with the Postal Police and relevant authorities and coordinates, within TIM, the abuse management process. The introduction of this figure, moreover, demonstrates BU Domestic's willingness and commitment to deploy all resources, technologies, processes and tools aimed at preventing and counteracting any type of activity that could result in a violation of behavioral and legislative rules governing the use of network services and/or information systems, such as abuse.
TIM offers adult content services, and as a child protection measure, users wishing to access the content provider's web portal must declare that they are of legal age, via a disclaimer with a password to restrict access to minors.
In addition, BU Domestic is an active member in the Advisory Board of the Safer Internet Centre (SIC) - Generations Connected, through which the Company intends to raise awareness of young people belonging to the age groups most at risk of cyberbullying.
Lastly, in relation to gambling, the TIM Group manages the topic by ensuring constant alignment with the regulations and monitoring their evolution over time, such as the transposition by the Domestic BU of the requests of the Customs and State Monopolies Agency (AAMS), in compliance with Law 296/2006 art.1 co.50 relating to the fight against tax evasion and avoidance in the gaming sector, with the aim of proceeding to block the reported resources, making them inaccessible to its customers.
In order to prevent or mitigate the potential negative impacts related to the topic of cyberbullying, child pornography, and online gambling, the TIM Group has undertaken a number of initiatives in this regard, the main ones of which are listed below:
In relation to the actions carried out by the Domestic BU, the main ones are listed below:
On the other hand, with regard to actions put in place by BU Brazil, TIM, in continuity with previous years, has implemented appropriate filtering services for adult content - such as downloading images, wallpapers, streaming videos, audio content (podcasts), and erotic information via text messaging - delivered in Brazil; therefore, customers can access this content through the provider's web portal, only after declaring that they are of legal age. In addition, TIM limits its adult-only content portfolio to level 3,2 of the international classification (international code).
Downstream of the materiality analysis, it was found that the main impact related to the material topic is of the potential negative type. For this reason, disclosure was provided solely with respect to the management of this type of impact. However, it should be specified that the TIM Group, in order to ensure transparency and fairness in business management to its stakeholders, has established a solid internal control system, consisting of rules, tools, activities, procedures and organizational structures. In this regard, as part of its risk management system, the Group has adopted an Enterprise Risk Management model capable of identifying potential events that may affect its business activities, including the plurality of ESG risks, enabling it to create the conditions useful for planning and implementing initiatives aimed at dealing with actual negative spillovers or bring about positive economic, social and environmental impacts.
In order to ensure the fight against phenomena attributable to cyberbullying, child pornography and online gambling, and to enable safe browsing where threats from the web are minimized, the TIM Group has equipped itself with specific processes, in terms of monitoring systems for its initiatives, by means of punctual indicators, which allow it to evaluate and keep track of the effectiveness of the actions taken.
With particular reference to abuse, the Domestic BU has defined processes aimed at keeping track of any reports to be forwarded to the Postal Police; in fact, in the event that the reporting process is activated by users/customers, TIM has provided for the involvement of the relevant Abuse Desks and, where necessary, also the Legal functions.
In order to assess the effectiveness of actions put in place with respect to preventing and mitigating any negative impacts related to the topic of cyberbullying, child pornography, online gambling, the Domestic BU voluntarily monitors specific indicators, including:
The effectiveness of the actions taken, which demonstrate TIM's willingness to offer increasingly secure browsing to its users, can be demonstrated through, for example, the recording in Italy, in the period from January 2022 to February 2023, of 137 million blocked botnets, 1.6 million blocked malware, and finally 688,000 blocked phishing, a condition that underscores the efficiency of the TIM Navigazione Sicura APP application in protecting against online threats and TIM's ability to adopt adequate protection of its customers' data.
By virtue of its important role in the telecommunications industry and in the countries in which it operates, the Group has become increasingly aware of the need to ensure safe browsing for its users and to monitor content that minors may have access to so that it does not affect their mental and physical development. This awareness has led the Organization, over time, to put forth a major effort in order to increasingly ensure the prevention of such phenomena as online bullying, child pornography and gambling.
In particular, with reference to the operational activities carried out in Italy, TIM has not only expanded the range of services to which customers can resort and implemented increasingly innovative systems aimed at ensuring protection from web threats and blocking access to dangerous sites, but at the same time it has also encouraged the structuring of processes aimed at keeping track of and managing the reports received from customers using the TIM network in the event of cybercrime.
Continuous discussion with stakeholders was found to be of primary importance in the introduction of a figure within the Organization capable of handling relations with the relevant Authorities.
In fact, ongoing collaboration with institutions that actively work to counter the phenomena of cybercrime and online child pornography has led to the identification of a specific figure with the goal of managing relations with the Postal Police and relevant authorities and information flows in a continuous and effective manner.
Moreover, in continuity with previous years, the discussion with the Group's stakeholders that took place during the materiality phase noted the importance of the impact related to the topics of cyberbullying, child pornography, and online gambling, guiding the actions taken and providing guidance for future ones as well.
Substances or products used or disposed of by TIM during their life cycle may pose a threat to human health or the environment. The generation, processing, as well as the management, storage, and use of hazardous materials can have significant environmental impacts.
The TIM Group could contribute to the negative impacts either directly, through its own activities, or also indirectly by means of the impacts recorded throughout the value chain, with particular reference to the supply chain that includes, among its main business relationships, relationships with companies operating in the manufacturing, service, and content producers sectors.
The TIM Group strongly believes that the socio-economic progress of the territory also passes through the definition of procedures and processes increasingly oriented to ensure efficient use of resources and products, enhancing the reuse and recycling of materials. In fact, the Group promotes goods and services designed and manufactured with a view to eco-sustainability and practices of reuse and recycling of materials and products, from the choice of raw materials to their disposal, taking care of the aspects of eco-compatibility and proper finance management.
In addition, the TIM Group's environmental impact is related not only to purely energy consumption, but also depends on its ability to intervene with recycling, reuse and repurposing activities so that resources are not turned into waste. With this in mind, in Italy TIM is committed to managing waste production not only by complying with current regulations and adopted standards, but also by implementing a series of commitments and actions aimed at both minimizing the volume of materials produced and encouraging their reuse in the form of goods or materials, in a circular economy logic.
The Domestic BU, with reference to its supplier selection and purchasing practices adopted, in order to support the circular economy, has established both a selection practice based on their sustainability performance and policies for tracking, sorting, recovery and resale of industrial waste. In addition, in Italy TIM has included in tenders and contracts requirements related to specific internationally recognized certifications.
The commitment of the Domestic BU with regard to the material topic is evidenced not only by the choice to evaluate the purchase of products following specific eco standard guidelines and by the constant reuse of all goods and materials already available in the Company, but also by the donation of what, on the other hand, can no longer be used.
In addition, in order to go beyond the normal transposition of regulations in the management of topics related to the circular economy and waste generation and generate value in this regard, some functions and/or companies in the Group with a significant impact on stakeholders have achieved certifications in line with ISO 14001.
During 2022, BU Domestic took multiple actions aimed at preventing and mitigating potential negative impacts associated with waste management. The following are the main ones:
Downstream of the materiality analysis, it was found that the main impact related to the material topic is of the potential negative type. For this reason, disclosure was provided solely with respect to the management of this type of impact. However, it should be specified that the TIM Group, in order to ensure transparency and fairness in business management to its stakeholders, has established a solid internal control system, consisting of rules, tools, activities, procedures and organizational structures. In this regard, as part of its risk management system, the Group has adopted an Enterprise Risk Management model capable of identifying potential events that may affect its business activities, including the plurality of ESG risks, enabling it to create the conditions useful for planning and implementing initiatives aimed at dealing with actual negative spillovers or bring about positive economic, social and environmental impacts.
In order to track and monitor the effectiveness of the actions taken with respect to topic related to the circular economy and virtuous waste management, TIM in Italy has identified different types of processes falling within both its own operations carried out and within the incoming quality control processes, as well as in the specific certifications acquired, including with reference to the Brazil BU (e.g., ISO 14001).
BU Domestic sets goals annually from previous years' results, monitoring and encouraging their continuous improvement. In this regard, TIM in Italy periodically observes the progress of the actions taken and their quantitative effects on the indicators of effectiveness, monitoring the volumes of waste generated and the value of waste and equipment valued, as well as through summary indicators of process efficiency.
The TIM Group's 2023-2025 Business Plan includes among its pillars the spread of the circular economy model, the reduction of waste generated and the reuse of materials. With these aims in mind, the same Plan defines environmental targets at the Group and Domestic BU levels, with the latter having the ambition by 2025 to reach a ≥70% share of "green" products and smartphones and to raise, also in the same period, the Circular Economy Ratio(5) to 2€/kg.
Furthermore, in Italy TIM observes additional indicators that allow monitoring the degree to which it is making good progress against its circular economy and waste generation goals and targets, such as the ratio of remanufactured material to new material and revenues related to the resale of technological waste, in addition to the percentage of recyclability, as well as EoW (End of Waste), at the Group level.
The effectiveness of the actions put in place by the Group can be demonstrated through:
(5) Unit revenue from resale of used materials and goods and waste recycling per kg of waste generated. Baseline 2021 €0.04/kg.
In addition, TIM in Italy in 2022 found a strong increase in the valorization of waste and discarded materials, nearly tripling revenues from the resale of technological waste compared with the previous year, as well as optimizing the sale of equipment through brokers and discarded copper cables. Specifically, in the Domestic BU, the Network Function valorized about 1,500 tons of technological waste and earned a total of about 2 Mln€ from waste recovery and the sale of equipment through brokers and decommissioned copper cables.
The TIM Group over the years has made progressive and relevant efforts with the aim of encouraging the transition from a linear economy to a circular economy that can safeguard resources, extend their useful life and reduce the amount going to landfill. This commitment has enabled the activation of a virtuous circle with third sector operators and the entire TIM population, who are proactive and attentive to the values of the circular economy.
The experiences gained in the course of carrying out the activities make it possible to verify with increasing maturity the effectiveness of the processes and foster the continuous improvement of the Group's indicators. The realizations gained have consequently led the Group to make very ambitious commitments with reference to the BU Domestic - which is responsible for the production of about 77% of the waste generated by the entire Organization (FY 2022) - sanctioned as part of its Business Plan 2023-2025.
Finally, in the area of logistics, lessons learned and needs that arose in the
course of business activities led the Domestic BU to reduce the number of TPLs (Third Party Logistics) from two to one, enabling optimization of warehouse and inventory costs.
The TIM Group annually conducts materiality analysis in order to incorporate stakeholder input into its sustainability priorities. In 2022, discussions with various stakeholders at the materiality stage led the Organization to identify an ad hoc material topic focused on the circular economy and waste management aspects, impacting the Group's activities, processes and strategic planning.
The topic of the circular economy and, in general, of the most effective ways to reuse materials and apparatus, are also explored in Italy by TIM with suppliers, brokers, and other international operators and interest groups (e.g., GSMA); such moments of engagement with them on different levels are instrumental to the Domestic BU in order to improve its results and increase its positive impact on the socio-economic fabric from the perspective of circular economy and waste management and storage.
Finally, ongoing discussion with internal Functions enables the creation of synergies that ensure the contribution of all actors within the Organization for the improvement of processes related to materials and virtuous waste management.
Risks related to the most relevant material topic are mapped and monitored by the Enterprise Risk Management (ERM) Function through specific activities managed in collaboration with the Risk Owners.
Below for the topics that are relevant in terms of risk(1) inherent associated are explained the methodologies for calculating risk and the activities carried out to manage it.
| ESG Topic | Areas of Risk | Inherent Risk Level |
|---|---|---|
| Privacy and cybersecurity | Privacy / Cyber | High |
| Risk Calculation Methodology | ||
|---|---|---|
| Privacy: | Cyber: | |
| • Methodology: Monte Carlo simulation - Variables: |
• FAIR (Factor Analysis of Information Risk) methodology with Monte Carlo simulation engine. |
|
| Sanctions applied by Authority on other companies/ | • Variables: Common Platform Enumeration (CPE); Common Vulnerabilities and Exposures (CVE); Internet Exposure; |
|
| groups and on TIM, Domestic TIM Turnover, Frequency of | Database Size; Recovery Point Objective; Recovery Time Objective; Business Impact Analysis; HW and SW Aging; | |
| Authority Audits on TIM, Compliance Assurance Findings. | Frequency Benchmarks and Impact of Occurrence. |
• Enabled integration with Compliance and Data Protection Officer (DPO) processes in order to identify key risk factors.
• Engineering a cross-cutting process for cyber risk analysis, assessment and monitoring, integrated with vertical Risk Management Security activities as well as with technical ICT (Chief IT Corporate and Market Sistems Office) and NW (Chief Network, Operations and Wholesale Office) activities.
(1) Risk level assessed gross of mitigation actions already implemented in the company.
| ESG Topic | Areas of Risk | Inherent Risk Level |
|---|---|---|
| Customer interaction and service transparency | Market | High |
| Risk Calculation Methodology | ||
|---|---|---|
| Fixed/Mobile: • Methodology Model based on Game Theory + Monte Carlo model. • Variables: GDP evolution, Customer Base, the ARPU and the level of perceived quality (Customer Satisfaction Index), benchmark competitors. |
Relevant Projects: • Methodology based on Monte Carlo simulations. • Variables: Perceived quality level, Bid Prices, project Capex/Opex, fees to project partners, minimum commitment, penalties, bid launch timing. |
• Enabled integration with Planning, Strategy and Marketing processes in order to analyze development drivers and identify key risk factors as well as to update the progress of mitigation actions (contractual, process, supply) over time.
• Implemented an econometric model, supported by Monte Carlo engine, for economic valuation of risk.
• Developed a cross-cutting process of strategic investment project analysis (and follow-up) with the involvement of proposer functions.
| ESG Topic | Areas of Risk | Inherent Risk Level | ||
|---|---|---|---|---|
| Digital inclusion Infrastructures and emerging technologies |
Technological | High |
• Methodology: Game theory and Monte Carlo model.
• Variables: FTTX network coverage requirements, FTTX revenue activations trend, TIM-FiberCop-KKR Partnership agreement constraints, Reference inflationary environment trend, Commodity price volatility, Gross Domestic Product (GDP) evolution, Customer Base, ARPU, perceived quality level (Customer Satisfaction Index), competitor benchmarks.
• Enabled integration with Network, Strategy and Financial Reporting processes in order to assess risks of fiber roll-out delays, overspending on inputs and Decommissioning of the transmission network as well as to update the progress of mitigation actions (mainly process) over time.
• Implemented an econometric model, supported by Monte Carlo engine, for economic valuation of risk.
| ESG Topic | Areas of Risk | Inherent Risk Level |
|---|---|---|
| Employee health and safety | Health and Safety | High |
• Variables: Work hours lost annually due to occupational injuries and illnesses (net of hours reimbursed by INAIL), Near Miss trends, Worker injury litigation, FTE (Full Time Equivalent) used to support ASL inspections, ASL sanctions, Average Hourly Enterprise Labor Cost (MOI).
• Activated integration with HSE and Compliance control processes in order to assess the effects of manifested and potential accidents.
• Analyzed the vertical model of Health and Safety risk analysis, assessment and management.
• Implemented a quantitative model based on Monte Carlo simulation.
| ESG Topic | Areas of Risk | Inherent Risk Level | ||
|---|---|---|---|---|
| Climate change (Climate) Resilience to physical, public health, and sociopolitical risks (Climate/Regulatory*) |
Climate/Regulatory* | Medium |
* For the Regulatory risk area: ERM activities under analysis.
| ESG Topic | Areas of Risk | Inherent Risk Level | ||
|---|---|---|---|---|
| Legal and regulatory context management | Regulatory/Privacy | High |
• Methodology: Delphi Methodology and Monte Carlo Model.
• Variables: Wholesale revenues related to Copper Activation Contributions, Fiber Activation Contributions, Copper Fees and Fiber Fees, Elementary Data 28-day billing (budget provision, fund utilizations, potential Customer Base entitled to reimbursement, likelihood of unfavorable European Court ruling).
• Enabled integration with Regulatory, Legal and Financial Reporting processes in order to identify the elemental data needed to assess and monitor the risk impacts of regulatory and management changes.
• Implemented a quantitative model based on Delphi methodology (interview on a panel of experts to assess the probability of occurrence of alternative scenarios to the Plan scenario) integrated with Monte Carlo simulation.
| ESG Topic | Areas of Risk | Inherent Risk Level | ||
|---|---|---|---|---|
| Sustainable supply chain | Supply Chain | Medium |
• Methodology: Economic-financial evaluation methodology using financial statement analysis and Monte Carlo Model.
• Variables: Supplier balance sheet data, supplier production capacity ratio, inflationary environment trends, constraints arising from the implementation of the National Recovery and Resilience Plan tenders (implementation time, penalties, batch implementation requirements).
ENVIRONMENT1
• expenditure on energy and fluids (k€): 0.1% of expenditure.
(5) For BU Brazil includes Cozani.
(1) The reporting boundary of the Non-Financial Statement coincides with the boundary of the Annual Financial Report, excluding environmental data. In determining the scope of environmental consolidation, threshold values were applied to the scope of BU Domestic 2021 as found in the 2022 Financial Report. In particular:
• turnover (k€): 0.5% of turnover;
• number of employees (no.): 0.5% of the number;
The TIM Group companies included in the '22 environmental scope are listed below: TIM S.p.A, Sparkle Group (Companies that meet the criteria), Fibercop S.p.A, Noovle S.p.A., Olivetti S.p.A., Telecontact Center S.p.A., Telenergia S.r.l., Telsy S.p.A., TIM Retail S.r.l., TIM Servizi Digitali S.p.A., as well as BU Brazil.
(2) For BU Brazil includes Cozani except for the reporting of diesel consumption for generator sets, steam and cooling.
(3) For BU Brazil includes Cozani; for BU Domestic only companies based in Italy are considered.
(4) For BU Brazil includes Cozani.
(6) For BU Brazil includes Cozani. For BU Domestic, only companies based in Italy are considered.
(7) Group calculation is based on GHG inventory for both BUs. For BU Brazil it also includes Cozani for Scope 1 emissions (except emissions from Gensets) and Scope 2.
Climate change events can have physical, economic, and regulatory implications, with financial repercussions on TIM's image and reputation. For the resulting risks to be monitored, prevented and mitigated, TIM builds its risk matrix, aimed at proposing adaptive actions to anticipate and avoid adverse effects. Managing these risks opens up opportunities for the Group to strengthen the resilience and efficiency of its assets and begin a process of energy transition. As a company of TLC sector, the dematerialization services that have always been offered can become a real opportunity if the demand for these services increases as a result of situations generated by climate change. Internally, TIM seizes this opportunity through the expanded application of agile working.
The BU Domestic Enterprise Risk Management Department identifies and assesses the following risks related to Climate Change.
Physical risks related to rising temperatures causing extreme and unexpected atmospheric precipitation, landslides, flooding or overflow.
In particular:
Hydrogeological risk:
Transition risks ie:
In this context, TIM may have to manage Capex and Opex overspending to ensure business continuity, expected customer quality as well as compliance with Strategic Plan goals, through the following targeted interventions:
In 2022 TIM in Brazil incorporated climate change risk into its Corporate Risk Management process to strategically monitor non-performance or inadequate performance in service delivery due to extreme weather events.
An assessment of future climate risks was conducted "and it was" based on a set of existing models and scenarios to define the potential climate impacts to which assets are subject. The geographic location where most network equipment and technical buildings are located in Brazil, including infrastructure such as biosites and traditional ERBs (GreenField and Rooftop), were taken into account: the vulnerability of network equipment varies depending on the location and geographic distribution and the function performed by the equipment.
Extreme events caused by climate change that can damage facilities/ infrastructure directly impacting TIM's business include water shortages, storms, and cyclones. Regarding water scarcity, it should be noted that energy from water sources has an important representation in Brazil's electricity matrix.
Anticipating this possible risk scenario, TIM promotes initiatives aimed at selfgeneration of energy and reduction of consumption in its services and facilities, restructuring processes and research into technologies to achieve maximum efficiency. The Company invests in renewable contracting through its distributed generation plan with solar, hydro, and biogas plants, reducing its dependence on the Brazilian energy grid. The Company also operates by purchasing clean energy on the free market and certificates of origin for energy from renewable sources (I-RECs).
From an opportunity perspective, Brazil believes that the TLC sector has a role in helping to reduce greenhouse gas emissions by enabling remote communication and reducing the need for travel that necessitates the burning of fossil fuels. Therefore, TIM S.A. invests in offering solutions based on new technologies, stimulating more efficient production models and logistics processes in various sectors, acting to be a company that stimulates a less GHG-intensive economy.
The Group's energy consumption is broken down into consumption of electricity purchased and produced from renewable sources, purchase of electricity from mixed sources, consumption from heating fuels, consumption from fuels for transport, and consumption for self-generation of electricity. No share of electricity, heating energy, cooling energy, or steam is sold.
BU Brazil's share of energy produced from biomass is included in production from renewable sources.
For BU Domestic, 45% of the electricity out of the total electricity consumed by the same BU comes from renewable sources.
| 2022 | 2022 | 2021 | 2020 | |||||
|---|---|---|---|---|---|---|---|---|
| Energy from Mixed Sources | u.m. | Group | BU Domestic | BU Brazil | BU Domestic | BU Brazil | Group | Group |
| Energy from unleaded petrol | MJ | 42,087,104 | 85% | 15% | 35,919,058 | 6,168,045 | 31,655,676 | 37,852,626 |
| Energy from diesel fuel | MJ | 426,265,874 | 100% | 0% | 426,073,007 | 192,866 | 413,231,373 | 423,960,083 |
| Energy from ethanol fuel | MJ | 739,636 | 0% | 100% | - | 739,636 | 0 | 0 |
| Energy from natural gas fuel | MJ | 12,248 | 100% | 0% | 12,247 | 0 | 0 | 0 |
| Energy from LPG | MJ | 2,025 | 100% | 0% | 2,025 | - | 12,778 | 317 |
| Total energy from transport | MJ | 469,106,887 | 98% | 2% | 462,006,340 | 7,100,547 | 444,899,827 | 461,813,026 |
| 2022/2021 | 5% | |||||||
| 2022/2020 | 2% | |||||||
| Energy from heating oil | MJ | 1,616,735 | 100% | 0% | 1,616,735 | 0 | 1,551,680 | 20,202,925 |
| Energy from heating natural gas | MJ | 139,389,993 | 100% | 0% | 139,389,993 | 0 | 149,172,887 | 148,764,722 |
| Total energy from heating | MJ | 141,006,728 | 100% | 0% | 141,006,728 | 0 | 150,724,567 | 168,967,647 |
| 2022/2021 | -6% | |||||||
| 2022/2020 | -17% | |||||||
| Self-production of electricity from biogas | MJ | 19,038,011 | 0% | 100% | 0 | 19,038,011 | ||
| Energy for diesel fuel for generators | MJ | 34,634,165 | 56% | 44% | 19,441,830 | 15,192,334 | 20,144,204 | 24,369,951 |
| 2022/2021 | 72% | |||||||
| 2022/2020 | 42% | |||||||
| Energy for methane for trigeneration systems | MJ | 1,031,142,229 | 100% | 0% | 1,031,142,229 | 0 | 1,368,361,863 | 1,302,219,029 |
| 2022/2021 | -25% | |||||||
| 2022/2020 | -21% | |||||||
| Purchase of electricity from mixed sources | MJ | 2,700,114,851 | 100% | 0% | 2,700,114,851 | 0 | 3,184,671,650 | 5,032,817,134 |
| 2022/2021 | -15% | |||||||
| 2022/2020 | -46% | |||||||
| Total energy from mixed sources | MJ | 4,395,042,870 | 99% | 1% | 4,353,711,978 | 41,330,892 | 5,168,802,111 | 6,990,186,786 |
| 2022/2021 | -15% | |||||||
| 2022/2020 | -37% |
2022 2022 2021 2020
| Energy from Mixed Sources | u.m. | 2022 Group BU Domestic BU Brazil |
2022 BU Domestic BU Brazil |
2021 Group |
2020 Group |
|||
|---|---|---|---|---|---|---|---|---|
| Energy from Renewable Sources | u.m. | Group | BU Domestic | BU Brazil | BU Domestic | BU Brazil | Group | Group |
| Self-production of electricity from renewable sources |
MJ | 976,144,298 | 0% | 100% | 1,525,528 | 974,618,769 | 885,365,449 | 405,331,636 |
| 2022/2021 | 10% | |||||||
| 2022/2020 | 141% | |||||||
| Purchase of electricity from renewable sources | MJ | 3,814,585,441 | 67% | 33% | 2,553,211,126 | 1,261,374,314 | 3,298,629,370 | 1,954,655,250 |
| 2022/2021 | 16% | |||||||
| 2022/2020 | 95% | |||||||
| Self-production of electricity from biogas | MJ | 429,997,300 | 0% | 100% | 0 | 429,997,299 | ||
| Total energy from renewable sources | MJ | 5,220,727,039 | 49% | 51% | 2,554,736,656 | 2,665,990,383 | 4,183,994,819 | 2,359,986,886 |
| 2022/2021 | 25% | |||||||
| 2022/2020 | 121% | |||||||
| Total energy consumed | MJ | 9,615,769,909 | 72% | 28% | 6,908,448,634 | 2,707,321,275 | 9,352,796,929 | 9,350,173,672 |
|---|---|---|---|---|---|---|---|---|
| 2022/2021 | 2.8% | |||||||
| 2022/2020 | 2.8% |
It should be noted that, starting from 2022 and with respect to the reporting of non-financial data of the subsidiary TIM S.A., in relation to the energy consumed within the organization at a consolidated level, the consumption of natural gas and biogas used for self-production has been disclosed of electricity in Brazil, in order to ensure greater compliance with the requirements of the GRI 302-1 disclosure.
Steam and cooling output generated by trigeneration plants 2022 is shown in the table below. Consumption of natural gas, used as a primary source in trigeneration,
is included in the calculation of energy consumed within the organization, displayed in the Energy consumed table and included in Scope 1 emissions.
| 2022 | ||||||
|---|---|---|---|---|---|---|
| Steam and Cooling | u.m. | BU Domestic | BU Brazil | |||
| Energy for cooling | MJ | 179,958,883 | 0 | |||
| Energy from steam | MJ | 335,494,676 | 0 |
For the BU Domestic, consumption related to the use of third-party infrastructure (TIM S.p.A. perimeter) contributes to the calculation of energy consumed outside the organization. The energy consumption estimate refers to mobile service and is based on consumption net of what is supplied directly by Telenergia (which falls under Scope 2 as mobile network) and infrastructure sites (which fall under Scope 2, included in fixed network).
For BU Brazil, energy generated by Business travells and Downstream Transportation and Distribution is included and represented in the calculation.
| TIM S.p.A.(8) | u.m. | 2022 |
|---|---|---|
| Total | GJ | 1,377,966 |
| BU Brazil | u.m. | 2022 |
|---|---|---|
| Total | GJ | 36,848 |
The Group measures its energy efficiency through the eco-efficiency indicator that relates the service provided to customers (bits transmitted) to the impact on the environment (joules of energy consumed). Data and voice traffic values from landline and mobile networks are taken into account, as well as industrial consumption (for transmission and power plant air conditioning use), civilian consumption (electricity for office use, air conditioning, and office heating), and automotive consumption.
The Group calculates different indicators for Italy and Brazil because the two realities are very different from operational and environmental point of view: in
(8) The data reported here are for TIM SpA only.
Brazil, traffic is mainly from the mobile network, no heating fuels are used given the particular climatic conditions, and there are no trigeneration plants.
The indicator considers only consumption within the organization. The Italy perimeter includes only companies with headquarters and assets in Italy.
| Italy | u.m. | 2022 | 2021 | 2020 | BU Brazil | u.m. | 2022 | 2021 | 2020 |
|---|---|---|---|---|---|---|---|---|---|
| Eco-efficiency in Italy | bit/J | 29,071 | 25,768 | 20,648 | Eco-efficiency in Brazil | bit/J | 19,991 | 19,271 | 16,146 |
| 2022 | 2021 | 2020 | ||||||
|---|---|---|---|---|---|---|---|---|
| Group | u.m. | Gruppo | BU Domestic | BU Brazil | BU Domestic | BU Brazil | Group | Group |
| Emissions from trigeneration | kgCO2 eq |
57,921,819 | 100% | 0% | 57,921,819 | - | 77,174,832 | 73,229,289 |
| Emissions from transport | kgCO2 eq |
33,045,972 | 99% | 1% | 32,725,535 | 320,437 | 31,017,337 | 33,959,890 |
| Emissions from heating | kgCO2 eq |
7,944,985 | 100% | 0% | 7,944,985 | - | 8,521,733 | 9,851,888 |
| Emissions from electricity self-production by mixed sources* |
kgCO eq 2 |
3,577,678 | 39% | 61% | 1,384,154 | 2,193,524 | 1,408,143 | 1,792,763 |
| Emissions from ozone depleting gases | kgCO eq 2 |
10,498,868 | 33% | 67% | 3,465,788 | 7,033,080 | 9,688,453 | 11,816,301 |
| Total direct emissions Scope 1 GHG | kgCO2 eq |
112,989,321 | 92% | 8% | 103,442,280 | 9,547,041 | 127,810,498 | 130,650,131 |
| 2022/2021 | -12% | |||||||
| 2022/2020 | -14% |
*Emissions from self-production of electricity from mixed sources in the table include both emissions from diesel for generator sets and emissions from natural gas for self-production of energy.
The Group's Scope 1 greenhouse gas emissions consist almost exclusively of carbon dioxide generated from fossil fuels for heating, automotive, and power generation. Leakage of hydrochlorofluorocarbon (HCFC) and hydrofluorocarbon (HFC) gases and other gases when present in air-conditioning and fire-fighting systems are also considered and included in the calculation converted to CO2 . The emissions reported here refer to the year 2022 and the Domestic and Brazil BUs as identified in the environmental scope.
The emission factors used in 2022 are CO2 equivalent factors published by DEFRA (Department For Environment, Food and Rural Affairs). The valuation of CO2
equivalent emissions of HCFCs, HFCs and other refrigerant gases is done by reference to their respective Global Warming Potentials (GWP): the index is based on a relative scale that compares the gas considered with an equal mass of carbon dioxide whose GWP is 1. For BU DOMESTIC, the IPCC Fourth Assessment was used in the calculation; BU Brazil refers instead to the IPCC Fifth Report Assessment (AR5 - 100 years). The method used by the Brazilian GHG Protocol Program uses global warming potentials (GWPs) of the 100-year time horizon in relation toCO2. Although AR5 values are the most recent, the method also considers values from the second assessment report (1995) and fourth assessment report (2007) for inventory purposes.
| 2022 | 2021 | 2020 | |||
|---|---|---|---|---|---|
| CO2 emissions u.m. |
Group | BU Domestic | BU Brazil | Group | Group |
| Market Based kgCO2 eq |
341,806,828 | 100% | 0% | 405,235,181 | 495,622,685 |
| 2022/2021 | -16% | ||||
| 2022/2020 | -31% |
| 2022 | 2021 | 2020 | ||||
|---|---|---|---|---|---|---|
| CO2 emissions |
u.m. | Group | BU Domestic | BU Brazil | Group | Group |
| Location Based | kgCO2 eq |
399,188,397 | 96% | 4% | 442,596,650 | 458,843,480 |
| 2022/2021 | -10% | |||||
| 2022/2020 | -13% |
Represented here are the Scope 2 Market Based and Location Based emissions expressed in kg of CO2 -equivalent using the atmospheric greenhouse gas emission factors in the electricity sector from the AIB 2022 report for Italy and Greece and the 2021 Location Based Terna coefficients for Turkey in the absence of the Market Based; for BU Brazil the average factor from the Ministry of Science, Technology Innovation and Communication Location Based was used in the absence of the Market Based factor. Scope 2 Location Based emissions are calculated for companies consolidating in the BU Domestic perimeter using the atmospheric emission factors of greenhouse gases in the electricity sector from the ISPRA 2022 report for Italy and the 2021 Terna coefficients for Greece and Turkey; for BU Brazil the average factor of the Ministry of Science, Technology Innovation and Communication of Brazil was used.
| Group | u.m. | 2022 | 2021 |
|---|---|---|---|
| Indirect GHG emissions (Scope 3) - Category 1 | tCO2 eq |
862,780 | 912,842 |
| 2022/2021 | -5% | ||
| Indirect GHG emissions (Scope 3) - Category 2 | tCO2 eq |
3,338,948 | 3,914,964 |
| 2022/2021 | -15% | ||
| Indirect GHG emissions (Scope 3) - Category 11 | tCO2 eq |
404,795 | 442,227 |
| 2022/2021 | -8% | ||
| Total Indirect Emissions (Scope 3) | tCO2 eq |
4,606,523 | 5,270,033 |
| 2022/2021 | -13% |
Similar to 2021, the calculation of CO2 eqScope 3 emissions is done for the entire Group on a purchase basis and with Quantis Evaluator of the GHG Protocol for Categories 1 and 2 with the same methodology used in 2021. The share of emissions from the use of third-party infrastructure in Italy, reported in 302-2 and transformed into AIB residual mix coefficient emissions, was also added to Category 1. The calculation of category 11 was carried out only for TIM S.p.A. using internal methodology and is based on the average consumption of TIM equipment at users' homes.
The emission factor used in the calculation is ISPRA 2022 LB.
The calculation of the three categories shown is in NFS as of 2021, the year on which the historical comparison depicted here is based(9).
The calculation shows CO2.eq. emissions. Emissions of a biogenic nature constitute a separate calculation, the details of which are given in 305-2 and are related to the BU Brazil perimeter only and amount to 54,131.99 tCO2 eq.
(9) The 2022 reporting excludes categories 6 and 7 moving progressively closer to the categories on which TIM has an SBT target.
| Italy | u.m. | 2022 | 2021 | 2020 |
|---|---|---|---|---|
| Emission intensity | kgCO2 eq/Terabits |
2.17 | 2.92 | 4.04 |
| BU Brazil | u.m. | 2022 | 2021 | 2020 |
| Emission intensity | kgCO2 eq/Terabits |
0.41 | ND | ND |
TIM has carbon-intensity indicators, which differ by geographic area due to the different composition of emissions in Italy and Brazil. For companies in the Italy perimeter (foreign Sparkle companies are excluded from the calculation), the indicator relates direct and indirect CO2 eq emissions (Scope 1 and Scope 2, measured in kg and generated through their own activities) to the service offered to customers (Tbit transmitted). Landline/mobile voice and data traffic values and direct emissions generated by consumption of fossil fuels for heating, selftraction and self-generation of electricity together with indirect emissions related to the purchase of electricity generated by third parties are taken into account. For BU Brazil, Scope 1 and Scope 2 emissions are considered, which include CO2 , CH4 , N2 Oand HFCs gases. Both TIM S.A. and Cozani were considered in the scope. No indicator history is available for BU Brazil.
The figures shown here refer to the Group perimeter and express the change in CO2 equivalent emissions in the year 2022 compared to the emissions reported in 2021. The calculation is based on accounting for emissions according to the GHG Protocol approach by distinguishing between direct emissions or Scope 1, indirect emissions or Scope 2, and other indirect emissions or Scope 3.
| Group | u.m. | 2022 vs. 2021 | 2021 vs 2020 | % 2022 vs 2021 | % 2021 vs 2020 |
|---|---|---|---|---|---|
| Scope 1 | tCO2 eq |
-14,821 | -2,840 | -12% | -2% |
| Scope 2 | tCO2 eq |
-63,428 | -90,388 | -16% | -18% |
| Scope 3 | tCO2 eq |
-664 | ND | -13% | ND |
For BU Domestic, the waste generated by the company, tracked and reported, is special waste, hazardous and nonhazardous.
Their production is related to network infrastructure management activities and the management and reorganization of locations. The waste generated is mainly delivered for recycling, and only a small portion is delivered for disposal. Instead, municipal waste from the ordinary operation of the sites is delivered through the municipal utilities.
As for BU Brazil, the Company generates hazardous and non-hazardous waste, both in administrative processes and in infrastructure installation and maintenance. Waste is disposed of properly, in accordance with the requirements of the legislation, so as not to cause environmental damage or generate fines and penalties. In addition, Brazil recognizes its direct and shared responsibility in the management of electronic waste (such as cell phones, batteries, accessories, modems, etc.) and undertakes to avoid and/or eliminate waste and reuse and/or recover materials. Reported impacts refer to waste generated in the organization's activities.
As for BU Domestic specific contractual clauses are included in service contracts in order to regulate the management of special waste; in goods supply contracts additional clauses are included to avoid the use of certain hazardous substances. For assets that are not in use, the possibility of their reuse in the business environment is assessed in advance before they are disposed of.
The waste produced is delivered to suppliers authorized to transport and handle it. Suppliers are obliged to provide copies of the registrations and authorizations required by legal regulations in order to enable prior control during contracting and field verifications during the course of conferring activities.
Data related to waste delivery are recorded through a computerized loading and unloading log management system.
For BU Brazil, efficient and responsible management of solid waste is one of the objectives assumed by TIM in the ESG Plan and is provided for in the Company's Environmental Policy. In addition, in compliance with the National Solid Waste Policy (L. 12,305/2010), TIM shares with business partners the responsibility for receiving and properly disposing of post-consumer electronic equipment (such as smartphones, modems, batteries and accessories). Another vector for reducing waste generation is the digitization of services, which reduces the amount of paper needed to issue invoices and collections.
In the pursuit of constant improvement of its processes, in 2021 TIM in Brazil began reporting the disposal of waste called CPE (Customer Premises Equipment) from customers (individuals or legal entities) who requested its cancellation or stopped paying for service. All collected material goes through the reconditioning process that evaluates the possibility of reusing the equipment. Measuring the number of cell phones recovered for reuse in the TIM Smart Troca program, which turns old cell phones into vouchers, was also initiated in 2022.
Waste data show a variable trend over time in relation to quantity and type of waste. The most important figure is the ratio of waste generated to waste delivered for recycling/recovery.
Waste is delivered to authorized parties outside the Company.
| 2022 | 2021 | 2020 | ||||
|---|---|---|---|---|---|---|
| Indicator | u.m. | Group | BU Domestic | BU Brazil | Group | Group |
| Non-Hazardous Waste | ton | 7,652 | 5,915 | 1,737 | 8,314 | 7,911 |
| 77% | 23% | |||||
| Hazardous Waste | ton | 2,582 | 2,006 | 576 | 3,116 | 2,097 |
| 78% | 22% | |||||
| Total Waste generated | ton | 10,234 | 7,921 | 2,313 | 11,430 | 10,008 |
| 77% | 23% | |||||
| 2022 out of 2021 | -10% | |||||
| 2022 out of 2020 | 2% |
| 2022 | ||||
|---|---|---|---|---|
| Indicator | u.m. | Group | BU Domestic | BU Brazil |
| Paper/cardboard | t | 551 | 100% | 0% |
| Metal | t | 538 | 100% | 0% |
| Organic | t | 191 | 0% | 100% |
| Plastic | t | 59 | 100% | 0% |
| Glass | t | 28 | 100% | 0% |
| More | t | 6,286 | 75% | 25% |
| Hazardous waste (batteries, used LEDs, etc.) | t | 2,582 | 78% | 22% |
| Total solid waste generated | t | 10,234 | 77% | 23% |
| Waste diverted from disposal | 2022 | |||
|---|---|---|---|---|
| Indicator | u.m. | Group | BU Domestic | BU Brazil |
| Total waste for recycling | t | 9,449 | 7,859 | 1,590 |
| Total waste for reuse | t | 92 | 0 | 92 |
| Total waste diverted from disposal | t | 9,541 | 7,859 | 1,682 |
| Total waste produced | t | 10,234 | 7,921 | 2,313 |
| % recycled waste to total products | % | 93% | 99% | 73% |
Below is the detail regarding hazardous waste. Hazardous waste
| 2022 | ||||||
|---|---|---|---|---|---|---|
| Indicator | u.m. | Group | BU Domestic | BU Brazil | ||
| Total hazardous waste for recycling | t | 2,528 | 1,953 | 576 | ||
| Total hazardous waste for reuse | t | 0 | 0 | 0 | ||
| Total hazardous waste diverted from disposal | t | 2,528 | 1,953 | 576 | ||
| Total hazardous waste generated | t | 2,582 | 2,006 | 576 | ||
| % of total hazardous waste | % | 98% | 97% | 100% |
| 2022 | |||||
|---|---|---|---|---|---|
| Total non-hazardous waste | Total hazardous waste | ||||
| Indicator | u.m. | BU Domestic | BU Brazil | BU Domestic | BU Brazil |
| Total waste directed to disposal | t | 6 | 631 | 57 | 0 |
| Total non-hazardous waste | Total hazardous waste | |||||
|---|---|---|---|---|---|---|
| Indicator | u.m. | BU Domestic | BU Brazil | BU Domestic | BU Brazil | |
| More | t | 3 | 631 | 57 | 0 | |
| Paper | t | 0 | 0 | 0 | 0 | |
| Metal | t | 0 | 0 | 0 | 0 | |
| Plastic | t | 0 | 0 | 0 | 0 | |
| Waste from electrical and electronic equipment | t | 3 | 0 | 0 | 0 |
| Total non-hazardous waste | Total hazardous waste | ||||||
|---|---|---|---|---|---|---|---|
| Indicator | u.m. | BU Domestic | BU Brazil | BU Domestic | BU Brazil | ||
| Landfilling - on site | t | 0 | 0 | 0 | 0 | ||
| Landfilling - at an external site | t | 3 | 631 | 0 | 0 | ||
| Incineration (with energy recovery) - on-site | t | 0 | 0 | 0 | 0 | ||
| Incineration (with energy recovery) - at an external site | t | 0 | 0 | 0 | 0 | ||
| Incineration (without energy recovery) - on-site | t | 0 | 0 | 0 | 0 | ||
| Incineration (without energy recovery) - at an external site | t | 1 | 0 | 0 | 0 | ||
| Other disposal operations - on-site | t | 1 | 0 | 0 | 0 | ||
| Other disposal operations - at an external site | t | 1 | 0 | 57 | 0 | ||
| Total other disposal operations | t | 2 | 0 | 57 | 0 | ||
| Total landfilling | t | 3 | 631 | 0 | 0 | ||
| Total Incineration (with energy recovery) | t | 0 | 0 | 0 | 0 | ||
| Total Incineration (without energy recovery) | t | 1 | 0 | 0 | 0 |
2022
[GRI 406-1a] Complaints received and handled regarding the whistleblowing channel (whistleblowing channel does not cover all BU Domestic companies). GRI 406 focuses on discrimination not also on other Human Rights.
| 2022 | 2021 | 2020 | |
|---|---|---|---|
| Total number of complaints Italy | 8 | 5 | 8 |
| Number of substantiated complaints Italy | 1 | 1 | 0 |
| Total number of complaints Brazil | 61 | 59 | 59 |
| Number of substantiated complaints Brazil | 22 | 20 | 18 |
| Complaints received and handled regarding discrimination in Italy | 2022 | 2021 | 2020 |
|---|---|---|---|
| Total number of complaints regarding discrimination received through the whistleblowing mechanism | 2 | 2 | 0 |
| Total number of complaints regarding discrimination received through the mechanism of whistleblowing substantiated |
1 | 1 | 0 |
| Number of complaints handled regarding discrimination during the reporting period | 2 | 2 | 0 |
| Number of complaints handled regarding discrimination during the reporting period substantiated | 1 | 1 | 0 |
| Number of resolved complaints regarding discrimination during the reporting period | 2 | 1 | 0 |
| Number of resolved complaints regarding discrimination during the reporting period substantiated | 1 | 1 | 0 |
| Total number of complaints received before the survey period and resolved in the reporting period | 1 | 0 | 0 |
| Total number of complaints received before the survey period and resolved in the substantiated reporting period | 0 | 0 | 0 |
| Complaints received and handled regarding discrimination in Brazil | 2022 | 2021 | 2020 |
|---|---|---|---|
| Total number of complaints regarding discrimination received through the mechanism of whistleblowing |
13 | 14 | 6 |
| Total number of complaints regarding discrimination received through the mechanism of whistleblowing of which substantiate |
5 | 1 | 2 |
| Number of complaints handled regarding discrimination during the reporting period | 13 | 14 | 6 |
| Number of complaints handled regarding discrimination during the reporting period of which substantiated |
5 | 1 | 2 |
| Number of resolved complaints regarding discrimination during the reporting period | 12 | 8 | 6 |
| Number of resolved complaints regarding discrimination during the reporting period of which substantiated | 5 | 1 | 2 |
| Total number of complaints received before the survey period and resolved in the reporting period | 6 | 0 | 0 |
| Total number of complaints received before the survey period and resolved in the reporting period of which substantiated |
1 | 0 | 0 |
[GRI 406-1b.ii] [GRI 406-1b.iii] [GRI 406-1b.vi] For the one substantiatedreport in BU Domestic(1), the employee who engaged in discriminatory behavior (verbal harassment for gender discrimination) was ordered to attend mandatory Human Rights training and fined one hour's pay.
In addition, outreach to other resources in the facility was undertaken, including non-compulsory use of the aforementioned course. In the BU Domestic(2), monitoring on the actual utilization of the training course was successful.
(1) The whistleblowing channel does not cover all BU Domestic companies.
(2) The whistleblowing channel does not cover all BU Domestic companies.
Of the thirteen reports received in BU Brazil,
Of the six reports received in 2021 that were resolved in 2022, five were related to ethnicity/physical appearance (unsubstantiated) and one was related to sexual orientation (substantiated, which resulted in disciplinary action of dismissal from the Company).
In Domestic BUs, monitoring conducted as of September 2022, on the conduct of the employee who engaged in discriminatory behavior, did not reveal any critical issues.
To strengthen the fundamentals of corporate governance, marked by the principles of transparency and confidentiality, in the Brazil BU made available to stakeholders internal and external the www.whistleblowing channel, in bilingual format (Portuguese and English), accessible through the corporate intranet and internet (https://www.tim.com.br/rj/canal-de-denuncias) e www.tim.com.br > Serviços > Canal de Denúncias) or by telephone (on 0800 900 8007), available 24 hours a day, 7 days a week. Full information is available at this link: www.tim.com.br/sp/canal-de-denuncias.
In the Domestic BU, in 2021 the action plan implemented (consisting of a ban on the reported - non-employee - future dealings with TIM) did not lend itself to a monitoring activity in view of the type of action reported.
GRI 201-3 | Defined benefit plan obligations and other retirement plans and opportunities
GRI 401-1 | New employee hires and employee turnover
GRI 401-2 | Benefits provided to full-time employees that are not provided
to temporary or part time employees
GRI 401-3 | Parental leave
GRI 402-1 | Minimum notice periods regarding operational changes
GRI 403-1 | Occupational health and safety management system
GRI 403-2 | Hazard identification, risk assessment, and incident investigation
GRI 403-3 | Occupational health services
GRI 403-4 | Worker participation, consultation, and communication on occupational health and safety
GRI 403-5 | Worker training on occupational health and safety
GRI 403-6 | Promotion of worker health
GRI 403-7 | Prevention and mitigation of occupational health and safety
impacts directly linked by business relationships
GRI 403-8 | Workers covered by an occupational health and safety
management system
GRI 403-9 | Work-related injuries
GRI 403-10 | Work-related ill health
GRI 404-1 | Average hours of training per year per employee
GRI 404-2 | Programs for upgrading employee skills and transition assistance programs
GRI 404-3 | Percentage of employees receiving regular performance and career development reviews
GRI 405-1 | Diversity of governance bodies and employees
GRI 405-2 | Ratio of basic salary and remuneration of women to men
GRI 407-1 | Operations in which the right to freedom of association and collective bargaining may be at risk
GRI 408-1 | Operations and suppliers at significant risk for incidents of child labor
GRI 409-1 | Operations at significant risk for incidents of forced or compulsory labor
National Supplementary Pension Fund for Employees of Telecommunication Companies-"Telemaco," a negotiated defined-contribution pension fund of the telecommunication services enterprise sector (Art. 52 of the CCNL).
Telemaco established in 1998 in the form of a recognized nonprofit association has been operational since October 2000; the objective of this pension fund is to enable members to have supplementary pension benefits from the mandatory system upon retirement. To this end, it provides for the collection of contributions, the management of resources in the sole interest of members, and the provision of benefits in accordance with the provisions of the supplementary pension regulations in force from time to time. Telemaco is intended for blue-collar, white-collar and middle-collar workers, hired on a permanent basis or under an apprenticeship contract as per Article 20 of the CCNL; tax dependents of members and beneficiaries enrolled in the Fund may also join Telemaco.
The contribution to the Fund to be borne by companies, effective December 1, 2022, increased from 1.3% of the salary taken as the basis for determining severance pay to 1.4%. Said contribution is recognized in favor of workers enrolled in Telemaco who, in addition to severance pay, decide in turn to contribute to the Pension Fund with a minimum contribution of 1% of the salary taken as the basis for determining severance pay. The number of current employees - belonging to TIM Group companies - as of January 1, 2023 enrolled in Telemaco is 37,945. More information can be found at https://www.fondotelemaco.it/.
Fontedir is the Supplementary Pension Fund for Group executives who, on a voluntary basis, decide to join by establishing an individual position fueled by contributions made by the Company and the members themselves. It provides, through agreements with insurance companies, for the provision of supplementary pension benefits from the compulsory system to which it belongs and directly disburses the benefits accrued in the pension position (liquidations, surrenders, advances, transfers ...) if the legal requirements are met. The Fund operates under a defined contribution system: the amount of retirement benefits is determined according to the contributions made, based on the principle of capitalization. It follows that the obligations under the plan are, by mathematical calculation, covered by the resources managed.
Annuities on individual positions, for Fontedir, are provided by the separate management subject to a special agreement with insurance companies; pension plan obligations are 100% covered by what is set aside specifically. For Fontedir, the obligations under the plan are, by mathematical calculation, covered by the resources managed. There are 1,157 executives enrolled in the Fund as of Dec. 31, 2022, of whom 448 are employed by TIM Group. More information can be found at https://www.fontedir.it/.
[GRI 201-3a, b.i, b.ii, b.iii, c, d, e] In BU Brazil, the status of each pension plan is given in a separate report; in summary:
Closed supplementary pension plans (those inherited from acquisitions of other companies) are currently in the black. However, should it be necessary to balance one of these plans due to a possible shortfall, TIM S.A. will assume this obligation. It is important to note that the value of all liabilities is 5.85 million reais. Finally, it should be noted that the pension plan offered by TIM S.A. has a more modern structure with a defined contribution, which in itself mitigates the need for future contributions based on actuarial risk.
The percentage of salary contributed by the employee or employer is 5%, with the possibility of increasing it to 15% for managerial figures.
Currently, the plan offered by TIM S.A. is voluntary and universal (offered to all employees).
Participation is 53%.
| [GRI 401-1a] | ||||||||||
|---|---|---|---|---|---|---|---|---|---|---|
| 2022 2021 |
2020 | |||||||||
| Group | u.m. | Men Women | Total | Men Women | Total | Men Women | Total | |||
| Employees hired | n | 1,965 | 1,594 | 3,559 | 2,019 | 1,533 | 3,552 | 1,406 | 869 | 2,275 |
| Terminated employees |
n | 3,022 | 2,097 | 5,119 | 2,602 | 1,618 | 4,220 | 3,496 | 1,655 | 5,151 |
| Total | n | 4,987 | 3,691 | 8,678 | 4,621 | 3,151 | 7,772 | 4,902 | 2,524 | 7,426 |
| 2022 | ||||
|---|---|---|---|---|
| Group | u.m. | Men | Women | Total |
| Employees hired <30 | n | 797 | 567 | 1,364 |
| Employees hired 30-50 | n | 1,093 | 975 | 2,068 |
| Employees hired >50 | n | 75 | 52 | 127 |
| Employees hired | n | 1,965 | 1,594 | 3,559 |
| Terminated employees <30 | n | 582 | 462 | 1,044 |
| Terminated employees 30-50 | n | 1,061 | 1,039 | 2,100 |
| Terminated employees >50 | n | 1,379 | 596 | 1,975 |
| Terminated employees | n | 3,022 | 2,097 | 5,119 |
| Total employees | n | 4,987 | 3,691 | 8,678 |
| Total | n | 14,961 | 11,073 | 26,034 |
| 2022 | |||||||
|---|---|---|---|---|---|---|---|
| Group | u.m. | Men | Women | Total | |||
| Employees hired - Italy | n | 819 | 436 | 1,255 | |||
| Employees hired - Abroad | n | 1,146 | 1,158 | 2,304 | |||
| Employees hired | n | 1,965 | 1,594 | 3,559 | |||
| Terminated employees - Italy | n | 1,883 | 992 | 2,875 | |||
| Terminated employees - Abroad | n | 1,139 | 1,105 | 2,244 | |||
| Terminated employees | n | 3,022 | 2,097 | 5,119 | |||
| Total employees | n | 4,987 | 3,691 | 8,678 | |||
| Total | n | 14,961 | 11,073 | 26,034 |
| 2022 | 2021 | 2020 | |||||||||
|---|---|---|---|---|---|---|---|---|---|---|---|
| Group | u.m. | Men Women | Total | Men Women | Total | Men Women | Total | ||||
| Positive turnover rate |
% | 6 | 8 | 7 | 4 | 3 | 7 | 3 | 2 | 4 | |
| Negative turnover rate |
% | 9 | 11 | 10 | 5 | 3 | 8 | 7 | 3 | 10 |
| 2022 | 2021 | 2020 | ||||||||||||
|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|
| Group | u.m. | <30 30-50 | >50 | Total | <30 30-50 | >50 | Total | <30 30-50 | >50 | Total | ||||
| Positive turnover rate |
% | 49 | 10 | 0 | 7 | 3 | 4 | 0 | 7 | 2 | 2 | 0 | 4 | |
| Negative turnover rate |
% | 38 | 10 | 7 | 10 | 2 | 3 | 3 | 8 | 1 | 2 | 6 | 10 | |
| 2022 2021 |
2020 | |||||||||||||
| Group | u.m. | Italy Abroad | Total | Italy Abroad | Total | Italy Abroad | Total | |||||||
| Positive turnover rate |
% | 3 | 24 | 7 | 3 | 23 | 7 | 2 | 7 | 4 | ||||
| Negative turnover rate |
% | 7 | 24 | 10 | 5 | 23 | 8 | 8 | 8 | 10 |
[GRI 401-2a] All the Group's full-time or part-time, permanent or temporary workers enjoy the same benefits.
In Italy, the supplementary pension plan is extended to workers with apprenticeship and insertion contracts, as well as permanent workers.
In Brazil, any differences in benefit payments are not related to the different forms of contract.
[GRI 401-2b] See GRI 2-6 for the definition of a significant place of business.
| 2022 | 2021 | 2020 | |||||
|---|---|---|---|---|---|---|---|
| Group(1) | u.m. | Men | Women | Men | Women | Men | Women |
| Total number of employees who took parental leave | n | 482 | 456 | 414 | 541 | 152 | 553 |
| Total number of employees who returned to work during the reporting period after taking parental leave | n | * | * | 476 | 379 | 394 | 468 |
| Total number of employees who have returned to work after taking parental leave and are still employed by the organization in the 12 months after return |
n | * | * | 378 | 337 | 400 | 311 |
| Rate of return to work in the Company of employees who have taken parental leave | % | * | * | 99 | 83 | 95 | 87 |
| Company retention rate of employees who have taken parental leave | % | * | * | 93 | 81 | 91 | 100 |
(1) Total number of employees who were entitled to parental leave: As per specific Italian and Brazilian laws, Group employees all have the same right to take parental leave. Od December 31 of each year. In addition, only compulsory maternity and paternity leave was taken into account when recording the number of people who took parental leave. In contrast, parental leave for optional abstention is not considered because it is non-consecutive leave that varies over the 12 years of the employee's child. *The data will be available from the end of 2023.
The minimum notice period, for BU Domestic, is governed - for some matters - by the relevant legal and contractual regulations as well as by the company regulations applied to all TIM employees (the notice period differs depending on the change e.g. working hours, territorial transfers, job change, company transfer). In this regard, the Company operates in full compliance with the applicable regulatory framework. In general terms, TIM pays attention to listening to and involving employee representatives in advance, including reorganization processes. In this regard, the Company operates within the minimum timeframe where required by the law/collective bargaining applied.
TIM Brasil adopts the criterion of reasonableness on a case-by-case basis, but has no legal minimum term.
[GRI 402-1a] [GRI 402-1b] For BU Domestic, 3.5 weeks is the minimum notice period for the purposes of notice to the union, observed in accordance with the law, during procedures functional to the transfer of business.
Organizational changes with significant impact on employment and staffing levels are discussed with union representatives and, in some cases, an ad hoc agreement is made, in which case the agreement itself specifies the timing and modalities of the reorganization.
Of note, in 2022:
TIM Brasil adopts the criterion of reasonableness and has a good relationship with the union, where relevant decisions that the Company makes in advance are presented and brought to the negotiating table with the union, to arrive at the best scenario for both parties (Company and employees). An example of this criterion are the two outsourcing activities that took place in 2022 related to billing and anti-fraud. Both outsourcings were communicated at least 2 months in advance to the affected employees, with the main goal of relocating them, either internally or in the market. In addition, a number of exceptional clauses have been developed for the dismissal of these employees in order to generate as little impact on their personal lives as possible.
[GRI 403-1a] [GRI 403-1b] Within the Italian territory(2), the reference regulatory provisions for health and safety issues in the workplace, in addition to defining the necessary criteria for the identification and assessment of risks, require that in this context adequate worker participation and consultation be implemented through workers' safety representatives.
i) TIM ensures the full adherence of its management system to the regulatory
provisions of the Workers' Health and Safety Consolidation Act (Legislative Decree 81/2008).
(ii) Regarding the management of office/promiscuous real estate, the management system has been implemented according to UNI ISO 45001.
TIM's safety management system model, provides for the full involvement of all actors involved in the safety process: company management, operational coordination figures, competent doctors, workers and Workers' Safety Representatives (RLS).
In order to complement and reinforce these initiatives, an "Occupational Health and Safety Management Model" complying with recognized standards (UNI ISO 45001) has been implemented, having as its perimeter all processes related to the design, construction, operation and maintenance of the office and mixed-use real estate assets manned.
TIM S.A. establishes(3) guidelines and principles to be applied in all TIM activities in Brazil, with the aim of promoting continuous improvement in occupational safety and health actions.
The safety and health at work policy includes 3 key commitments: (a) Occupational injury prevention and health protection;
(2) Perimeter: TIM S.p.A., Telecontact, Noovle, Fibercop and Sparkle.
(3) Through PL 631 - Policy "Safety and health at work" and health at work policy safety and health at work.
(b) compliance with legal and other requirements of the organization; (c) continuous improvement of the management system, with the aim of increasing safety and health performance.
Scope: employees, service providers, interns, young trainees and visitors to TIM Group facilities in Brazil, including Instituto TIM.
Occupational health and safety regulations are referenced by national and international standards (ISO 14001) and best practices applicable to the Company.
[GRI 403-2a.i] [GRI 403-2a.ii] Within the Italian territory(4), the identification and assessment of risks present in the Company, which represents the preeminent activity of prevention action is governed by specific internal procedures and is ensured through the constant monitoring of business processes and their evolutions in close connection with line structures. To carry out this activity, specialized in-house resources operate, capable of carrying out instrumental analyses and surveys in the field of occupational safety (high and low-frequency electromagnetic fields, noise, vibration, natural radioactivity, lighting engineering, microclimate, manual handling of loads, etc.).
Work activities are classified on low and medium risk levels, in line with the
ATECO classification criteria of the National Institute of Statistics. In TIM S.p.A. as well as in the Group's other subsidiaries, there are no assets classified as high risk.
Control measures applied for the elimination or containment of risks include:
In Brazil, TIM S.A. identifies the hazards/aspects and risks/impacts of activities, products, and services that it can control and those that it can influence,
(4) Perimeter: TIMS.p.A, Telecontact, Noovle, Fibercop and Sparkle.
considering the life-cycle perspective, through direct observation of activities and operations, analysis of documents, including applicable legislation, occupational health and safety (OSH) inspections, reading of procedures, instructions, records, process flowcharts, and the results of internal and external audits.
Activities/processes with the presence of potentially hazardous risk factors are carried out by duly qualified professionals and have undergone service provision. TIM S.A. has not identified any unhealthy/dangerous conditions based on occupational risk management programs/analysis issued by companies/qualified professionals during the period.
The resulting programs are carried out by qualified occupational health and safety and environmental professionals.
These processes provide input for the implementation of control measures and improvements with the goal of minimizing risks and ensuring a healthy work environment.
[GRI 403-2b] Within the Italian territory the definition of safety roles allows each worker to know his or her hierarchical chain to which to report any hazards and dangerous situations at work, in addition workers can also report the presence of any hazards through CRM Facility System and the computerized procedure "Verification of supervisors and reporting anomalies."
In Brazil, there is an official public whistleblowing channel for employees of the Company that guarantees anonymity regarding reports of dangers and risk situations in accordance with the whistleblowing policy-channel.
[GRI 403-2c] Within the territory of Italy(5), the worker is always required to take care of his own health and safety and that of other persons in the workplace, on whom the effects of his actions or omissions fall, according to the training he has received and the instructions and means provided by the employer.
The worker in fact:
(5) Perimeter: TIM S.p.A, Telecontact, Noovle, Fibercop and Sparkle.
In Brazil, there is a whistleblowing channel for employees, an official company channel that guarantees anonymity regarding reports of hazards and risk situations in accordance with the whistleblowing policy-channel.
[GRI 403-2d] Within the Italian territory(6), occupational accidents are subject to analysis through the implementation of specific investigations aimed at analyzing the causes related to the event also in order to prepare possible corrective and improvement actions with the direct involvement of the lines concerned and the Human Resources & Organization Office Function for greater synergy.
The scope of the project for the detection and management of near misses was expanded to include all field technicians in 2022 and the start of detection for workers allocated in Real Estate as well.
In Brazil, as described in the internal regulation - Management of Occupational Events - all events are analyzed by the team of professionals in the field of occupational health and safety, as well as causes are identified and action plans are developed with the aim of preventing further events of the same nature.
[GRI 403-3a] TIM S.p.A.'s personnel health protection service is entrusted to specialized providers operating by territorial areas of responsibility with reference to the following areas:
In this context, to date, competent physicians have been appointed, with assignment perimeter on a regional/provincial/work location basis. An additional competent physician, third to the appointed ones made available by the providers, is specifically contracted by TIM S.p.A. to serve as coordinating competent physician.
The health surveillance pool, derived from the provisions of the risk assessment documents of TIM S.p.A.'s employer lines is, to date, approx. 17,800 workers, subjected to one or more examination protocols among the following: video
(6) Perimeter: TIM S.p.A, Telecontact, Noovle, Fibercop and Sparkle.
display screen work risk, manual load handling risk for technical profiles, work at height risk, electromagnetic field risk, chemical risk. The main worker profiles in the health surveillance pool are video screeners (approx. 10,900 workers) and field technicians (approx. 6,100 workers).
The Health Safety & Environment (HSE) Function and territorial safety principals monitor the activities of suppliers and the enforcement of relevant contracts.
The Operational Guideline "Management of Health Checks in Occupational Health and Safety" describes the responsibilities and operations inherent in the health protection process adopted in TIM S.p.A. in occupational health and safety, from planning to the organization, management and execution of health checks.
In order to protect the health and safety of workers, annual monitoring campaigns are carried out through instrumental surveys regarding physical agents in particular: indoor noise, outdoor noise, electromagnetic fields, ionizing radiation, optical radiation, vibration, outdoor and indoor microclimate parameters, and lighting parameters of working environments. Substances and preparations used in the Company and exposure to chemical and biological agents in work activities are also checked when necessary.
In Brazil, the Occupational Health Medical Monitoring Program (PCMSO) aims to indicate occupational medical examinations related to environmental risk conditions, if any, as a condition for monitoring worker health. Occupational health certificates (ASO, in the Portuguese acronym) are performed upon admission, return to work, dismissal, change of function, and periodically, as described in the PCMSO.
[GRI 403-4a] TIM S.p.A.'s corporate relational model on safety, which has always been inspired by participatory logics, includes about 80 Representatives distributed throughout the country.
The number, method of designating or electing Workers' Safety Representatives, as well as the paid working time and means of performing the functions are established in collective bargaining.
In Brazil, TIM S.A. has the internal Accident Prevention Committee in its subsidiaries, which meets monthly to discuss issues related to accident prevention, health promotion and suggestions for process improvement.
In branches where the number of employees does not reach the minimum required for CIPA composition, the company shall designate at least one employee to fill this role. Employees can contact the HSE team to ask questions about occupational health and safety processes.
TIM S.A. provides information channels on its intranet on actions and campaigns related to quality of life, accident prevention, health promotion, and the environment.
[GRI 403-4b] In TIM S.p.A. there are 5 committees (one for each territorial area and one national) with mixed Company/union participation with specific functions in the field of workers' health and safety.
These bodies, which are present at the national and territorial levels, have a participatory and collaborative role designed to ensure analysis and joint confrontation between the company and union sides on all issues related to the protection of health and safety in the workplace.
Meetings will take place as needed and in any case at least three national meetings for each committee as stipulated in the Industrial Relations Protocol of January 11, 2019.
In Brazil, 97% of the workforce is currently represented in health and safety committees(7).
Group(8):
| Health and safety training | u.m. | 2022 | 2021 | 2020 |
|---|---|---|---|---|
| Hours of health and safety training | h | 133,516 | 172,772 | 155,186 |
| Total hours of training | h | 2,708,738 | 5,316,361 | 2,000,600 |
| Percentage of health and safety training hours out of the total |
% | 5 | 3 | 9 |
The main types of courses organized during 2022 include: ISO 45001 training, first aid, environmental emergency management, occupational safety and health, and the use of signs in road and highway work.
(7) The change of 0.8% from the number submitted in 2021 is due to the increase in employees allocated in industrial warehouses, the number of which does not meet the composition requirement for representatives of these committees.
(8) For BU Domestic, with reference to the accident phenomenon, the timely analysis of events continues and where necessary the identification of corrective actions with the direct involvement of the lines concerned and the HR Function for greater synergy. The expansion of the scope of application of the pilot project for the detection and management of near misses continues, with 50% of on-field technicians (about 3,500 resources) in Chief Technology & Operations Office being involved in 2022 and the start of detection also for workers allocated in Real Estate. More details about the training hours are available in the appendix.
[GRI 403-6a] [GRI 403-6b] For TIM S.p.A., ASSILT (Association for Supplementary Health Care for Workers of TIM Group Companies), financed by TIM, its worker members and retired members, pursues the non-profit purpose of providing members and beneficiaries with benefits supplementary to those provided by the National Health Service, including, in cooperation with public health facilities, conducting research, cognitive surveys and group and individual preventive health care interventions, as well as promoting health education initiatives to protect the health and physical integrity of members. As of Dec. 31, 2022, more than 72,000 people were enrolled in the Association, including about 39,000 employees and 33,000 retirees, to which should be added more than 50,000 beneficiary family members. In 2022 ASSILT disbursed more than 52 million in member contributions. ASSIDA provides reimbursements to executives for health benefits supplementary to those provided by the National Health Service. As of Dec. 31, 2022, there were 2,927 people served by the Association, 510 executives enrolled, and about 10.9 million disbursed.
In order to support preventive health care for staff, TIM provides all those aged 45 years and older the opportunity to benefit from a flexible and personalized preventive health care program every two years.
Since 2019, TIM has created "Project WellBeing," a program of initiatives and educational paths aimed particularly at reducing stress, promoting movement and physical activity, improving lifestyles and preventing health. In addition, in collaboration with TIM myBroker (an insurance brokerage company, wholly owned by TIM), the TIMmyHealth service was identified-a Health Care policy that provides comprehensive health care for the whole family and offers telemedicine service.
On the subject of health education to protect the health and physical integrity of workers during 2022, the following health welfare campaigns were promoted in cooperation with ASSILT:
In Brazil, the Company provides health and dental plans for its employees and their dependents, according to clauses 17 and 18 of the Collective Bargaining Agreement. These plans also allow consultations via teleguidance when technically possible.
The Company offers an emotional, psychological and social support program: the Apoio Pass is a service that offers social, legal and psychological guidance with experts. Program counseling is totally free, confidential and available by phone 24 hours a day, 7 days a week.
It is important to emphasize the assistance provided by social service to contribute to sensitive social situations that require acceptance and proper guidance.
The company has an exclusive allowance for dependent children with significant health problems that make self-care impossible, regardless of the age of the dependent child. The program allows reimbursement for expenses related to necessary issues, such as diapers and equipment.
In 2022, the Company's new work model was launched, allowing for on-site and/ or remote work, depending on the area/location. In this new model, employees can also request to work temporarily in a completely remote mode because of the need to intensively care for a sick family member or even for some treatment that the employee needs to do that does not prevent him from working, according to his doctor. Examples include treatments that generate only some difficulty in locomotion or the need to stay at home to facilitate treatment. In addition to the usual professionals related to occupational medicine, the Company has a team of professionals specializing in health care who manage the plans offered. These professionals also study the epidemiological behavior of the population for the construction of targeted programs or individualized care, if appropriate. All information related to the employee's health is covered by confidentiality.
[GRI 403-7a] TIM S.p.A. ensures the fulfillment of all legal obligations in the area of occupational safety that impact its customers and contractors within the scope of ordinary customer-supplier relationships. In this regard, it ensures maximum cooperation and collaboration to minimize risks and ensure the safety of its own personnel and third parties.
The actions under this approach and applied for the elimination or containment of risks are:
• the establishment of necessary organizational arrangements carried out in cooperation with lines designed to ensure an acceptable level of risk where it cannot be eliminated.
In Brazil, TIM S.A. identifies, evaluates and permanently monitors the hazards/ aspects and risks/impacts of the activities, products and services it can control and those it can influence, considering the life cycle perspective, through direct observation of activities and operations, analysis of documents, including applicable legislation, reading of procedures, instructions, records, process flow and results of internal and external audits, according to TIM's internal regulations, such as: investigation of environmental aspects and impacts, occupational health and safety risks and hazards, chemical management.
TIM S.A. establishes, through specific access control regulations, potential risk areas, limiting qualified and eligible employees to activities in the Company's facilities.
| Employees covered by a health and safety at work system | u.m. | 2022 | 2021 |
|---|---|---|---|
| Employees covered | n | 50,377 | 51,913 |
| Total employees | n | 50,377 | 51,913 |
| Percentage of employees covered | % | 100 | 100 |
| Employees covered by a health and safety in at work management system that has been internally audited |
u.m. | 2022 | 2021 |
|---|---|---|---|
| Employees covered | n | 10,384 | 10,648 |
| Total employees | n | 50,377 | 51,913 |
| Percentage of employees covered | % | 21 | 20 |
| Employees covered by a health and safety in at work management system that has been externally audited |
u.m. | 2022 | 2021 |
|---|---|---|---|
| Employees covered | n | 8,347 | 3,716 |
| Total employees | n | 50,377 | 51,913 |
| Percentage of employees covered | % | 17 | 7 |
(9) A management system complying with recognized standards (ISO 45001) has been implemented having office/promiscuous real estate assets as its boundary.
[GRI 403-8b] The administered are excluded from the tables above.
[GRI 403-8c] A new management system complying with recognized standards (ISO 45001) has been implemented having as its perimeter the real estate assets under the Real Estate Function.
Some Group companies (Noovle and Sparkle Italia) also have a system certified by an external body and subject to internal audit.
Data on employees covered by an occupational safety and management system for 2022 are shown below.
[GRI 403-8b,c, e] TIM S.A., through its internal safety and health policy, establishes guidelines and principles to be applied in all TIM's activities in Brazil, with the aim of promoting continuous improvement in occupational safety and health actions.
The safety and health at work policy includes 3 key commitments:
| Accidents - Employees | u.m. | 2022 | 2021 | 2020 |
|---|---|---|---|---|
| Accidents recorded at work (including deaths) | n | 259 | 239 | 249 |
| Accidents at work with serious consequences (>6 months of absence), excluding deaths |
n | 3 | 1 | 3 |
| travel accidents (only if transport was arranged by the organization) |
n | 0 | 4 | 13 |
| Number of deaths as a result of work-related injuries | n | 0 | 0 | 0 |
| Hours worked - Employees | u.m. | 2022 | 2021 | 2020 |
|---|---|---|---|---|
| Hours worked | h | 73,886,548 | 79,947,742 | 81,211,899 |
| Accident rates (Frequency indices) - Employees | 2022 |
|---|---|
| Death rate(10) | 0.00 |
| Rate of commuting accidents (only if transportation was arranged by the organization) |
0.00 |
| Rate of work-related injuries with serious consequences (>6 months of absence), excluding fatalities |
0.03 |
| Rate of recordable occupational injuries (including fatalities) | 3.51 |
Rates calculated for salaried personnel are on 1,000,000 hours.
The rates shown are calculated without taking into account the accidents and the hours lost resulting from accidents suffered by executives or those occurring in
Commuting accident rate: number of commuting accidents/(hours worked/1,000,000)
Rate of occupational accidents with serious consequences: number of occupational accidents with serious consequences/(hours worked/1,000,000)
Recordable work injury rate: recordable work injuries/(hours worked/1,000,000)
(10) Calculated death rate: number of deaths from injuries/(hours worked/1,000,000)
transit, nor do they include so-called medication injuries, which did not therefore result in absences of at least one day (UNI 7249:2007 standard); moreover, agency contract workers are not taken into account.
| Group injury indicators - Employees | u.m. | 2022 | 2021 | 2020 |
|---|---|---|---|---|
| Severity index (conventional days lost due to injury per thousand hours worked) |
dd/h | 0.12 | 0.12 | 0.11 |
| Frequency index (no. of accidents/total hours worked/1,000,000) |
n/h | 3.51 | 2.99 | 2.91 |
| Average injury duration in days | dd | 36.16 | 39.81 | 37.18 |
| Unproductivity index (hours lost to injury per thousand worked) |
h | 0.76 | 0.78 | 0.71 |
| Accidents per 100 workers | 0.51 | 0.47 | 0.57 |
[GRI 403-9c] [GRI 403-9d] Domestic BU shall ensure the identification and assessment of risks to worker safety and health with a view to their progressive elimination or minimization by adopting the principles, standards and solutions that constitute international business "good practices" and considering, as a basic requirement, compliance with existing standards.
The Company plans the activities, resources and objectives of the risk assessment process by identifying the business processes involved, the workers affected, and the tools, techniques and methodologies to be used. In this context, information is collected, documentary and field investigations are carried out to enable the identification of sources of danger and exposed persons and to acquire all the information and data necessary for proper assessment. In this context, constant monitoring of the accident phenomenon makes it possible to highlight any critical areas in order to activate corrective or improvement actions. In 2022, there were 3 occupational accidents that had, in terms of days of absence (with prognoses greater than 180 days), serious consequences: 1 case for a generic fall hazard from building stairs,1 case for electrocution hazard and 1 caseof injury to the ankle following a fall from a height gain. The occupational injuries with serious consequences are being investigated in order to identify possible improvement actions.
Occupational injuries are the subject of appropriate investigations by the territorial safety units, which, through specific investigations, identify the causes of the injuries (which may be attributable to worker behavior, the work environment and/or external factors), also making use of the collaboration of the injured person himself and other company figures involved (such as the person in charge who oversees the work activity). Inquiries are aimed at highlighting any critical areas on which to intervene with improvement actions that may involve, for example, awareness talks, updated training/information, remedial work on facilities/ infrastructure up to and including the possible updating of risk assessment.
In Brazil, TIM S.A. identifies, evaluates, and monitors hazards and risks based on the detection of environmental aspects and impacts, hazards, and occupational health and safety risks.
Measures to eliminate and minimize hazards are guided by the Hazard Inventory and the Occupational Health Medical Monitoring Program (PCMSO).
[GRI 403-9e] Rates calculated for employees are on 1,000,000 hours.
[GRI 403-9f] In the data for salaried staff, temporary employees are not counted.
[GRI 403-9g] Useful data for reading are given in footnotes in the tables.
| Occupational diseases for employees | u.m. | 2022 | 2021 | 2020 |
|---|---|---|---|---|
| Number of recordable cases of occupational diseases |
n | 4 | 6 | 14 |
| Number of deaths from occupational diseases | n | 1 | 0 | 0 |
[GRI 403-10a.iii] For TIM S.p.A., the main types of occupational diseases include musculoskeletal, respiratory and hearing disorders.
[GRI 403-10c] For TIM S.p.A., the Company shall provide for the identification and assessment of risks to worker safety and health for the purpose of their progressive elimination or minimization by adopting the principles, standards and solutions that constitute international business "good practices" and considering, as a basic requirement, compliance with existing standards. The Company plans the activities, resources and objectives of the risk assessment process by identifying the business processes involved, the workers affected, and the tools, techniques and methodologies to be used. In this context, information is collected, documentary and field investigations are carried out to enable the identification of sources of danger and exposed persons and to acquire all the information and data necessary for proper assessment. In this context, constant monitoring of the phenomenon of occupational diseases makes it possible to highlight any areas where to activate corrective or improvement actions.
[GRI 403-10d] All TIM S.p.A. workers are included in this disclosure.
[GRI 403-10e] For Italy, regarding occupational diseases, complaints presented by employees to INAIL (Istituto Nazionale per l'Assicurazione contro gli Infortuni sul Lavoro) were taken into account in the reference year and submitted for recognition.
[GRI 404-1] Group:
| 2022 | 2021 | 2020 | |||||||||
|---|---|---|---|---|---|---|---|---|---|---|---|
| Total training hours provided to employees |
u.m. | Men Women | Total | Men Women | Total | Men Women | Total | ||||
| Senior managers |
h | 3,118 | 1,131 | 4,248 | 4,430 | 908 | 5,338 | 6,730 | 1,662 | 8,392 | |
| Middle managers |
h | 150,020 | 77,646 | 227,676 421,897 | 187,024 608,921 104,336 | 35,262 | 139,598 | ||||
| Office staff | h | 1,396,955 1,075,685 2,472,629 2,956,045 | 1,746,057 4,702,102 1,075,638 | 776,972 1,852,610 | |||||||
| Workers | h | 4,184 | 0 | 4,184 | 0 | 0 | 0 | 0 | 0 | 0 | |
| Total | h | 1,554,276 1,154,462 2,708,738 3,382,372 1,933,989 5,316,361 1,186,704 | 813,896 2,000,600 |
| 2022 | 2021 | ||||||||
|---|---|---|---|---|---|---|---|---|---|
| Hours of training provided to employees by type of training |
u.m. | Men Women | Total | Men Women | Total | ||||
| Environment | h | 1,935 | 1,768 | 3,703 | 2,201 | 1,594 | 3,795 | ||
| Health and Safety | h | 108,416 | 25,100 | 133,516 | 135,748 | 37,024 | 172,772 | ||
| Anticorruption | h | 105,901 | 68,575 | 174,476 | 10,068 | 10,247 | 20,315 | ||
| Human Rights | h | 0 | 2 | 2 | 2,840 | 4,155 | 6,995 | ||
| Privacy | h | 2,959 | 2,046 | 5,005 | 3,012 | 3,005 | 6,017 | ||
| Sustainability | h | 104,295 | 76,643 | 180,938 | 8,765 | 7,901 | 16,666 | ||
| Other themes | h | 1,230,771 | 980,328 2,211,098 3,219,736 | 1,870,064 5,089,801 | |||||
| Total | h | 1,554,276 1,154,462 | 2,708,738 3,382,370 | 1,933,991 5,316,361 |
Men: 48 h/pro-capite - Women: 59 h/pro-capite
Senior Managers: 7 h/pro-capite - Middle managers: 49 h/pro-capite - Office staff: 53 h/pro-capite - Workers: 26 h/pro-capite
Total: 52 h/pro-capite
| 2022 | 2021 | |||||||||
|---|---|---|---|---|---|---|---|---|---|---|
| Percentage of total training hours provided to employees by type of training |
u.m. | Men | Women | Total | Men | Women | Total | |||
| Environment | % | 0 | 0 | 0 | 0 | 0 | 0 | |||
| Health and Safety | % | 7 | 2 | 5 | 4 | 2 | 3 | |||
| Anticorruption | % | 7 | 6 | 6 | 0 | 1 | 0 | |||
| Human Rights | % | 0 | 0 | 0 | 0 | 0 | 0 | |||
| Privacy | % | 0 | 0 | 0 | 0 | 0 | 0 | |||
| Sustainability | % | 7 | 7 | 7 | 0 | 0 | 0 | |||
| Other themes | % | 79 | 85 | 82 | 95 | 97 | 96 |
[GRI 404-2a] The following are the main development activities that characterized 2022 for BU Domestic:
(agile, data culture, cybersecurity, etc.). Adherence rates to the various initiatives were decidedly high standing at over 77 percent for all surveys.
• Potential assessment system: is a process that contributes to the identification and enhancement of the Company's current and future managerial assets and supports the people involved in their development.
[GRI 404-2b] In Italy, TIM wants to make the occupational system consistent with changes in the labor market by integrating it with new trades, describing core skills and promoting the acquisition of emerging skills. During 2022, the revisiting of professional roles, related competencies and reference grading were validated with the lines.
In 2022, TIM S.A. in Brazil once again evolved its people development practices, focusing on digitization, personalization and inclusion.
Through research, benchmarking and numerous conversations with internal stakeholders, the performance management process has evolved to deliver even more value to employees. Three rounds of evaluation involving more than 5,600 people were initiated.
Earlier this year, Cycle 21 was launched, with over 98 percent participation. In July, TIM S.A. released the first peer review for projects, opening the 2022 cycle with improvements in the experience of our internal customers.
For leadership development, for example, new editions of the inter-company E-Coaching and Mentoring programs were launched, involving more than 270 people.
In the E-Coaching program, about 85 managers and senior managers experienced a short 5-session digital coaching course with an ICF-certified coach during this year to accelerate growth and address management challenges. So far, more than 340 leaders have been involved in this program since 2020. With the support of an external leadership consulting firm TIM S.A. mapped out the executives who are part of the Company's succession plan.
[GRI 404-3a] Group:
| 2022 | 2021 | 2020 | ||||||||
|---|---|---|---|---|---|---|---|---|---|---|
| Employees | u.m. | Men | Women | Total | Men | Women | Total | Men | Women | Total |
| Senior managers | n | 262 | 66 | 328 | 344 | 79 | 423 | 266 | 61 | 327 |
| Middle managers | n | 2,964 | 1,291 | 4,255 | 2,842 | 1,213 | 4,055 | 2,628 | 1,117 | 3,745 |
| Staff office | n | 25,709 | 14,317 | 40,026 | 26,922 | 15,884 | 42,806 | 22,993 | 12,535 | 35,528 |
| Workers | n | 0 | 0 | 0 | 0 | 0 | 0 | 0 | 0 | 0 |
| 2022 | 2021 | 2020 | ||||||||
|---|---|---|---|---|---|---|---|---|---|---|
| Percentage of employees | u.m. | Men | Women | Total | Men | Women | Total | Men | Women | Total |
| Senior managers | % | 63 | 63 | 63 | 79 | 70 | 77 | 66 | 67 | 67 |
| Middle managers | % | 96 | 94 | 95 | 97 | 95 | 97 | 96 | 96 | 96 |
| Staff office | % | 99 | 97 | 98 | 99 | 96 | 98 | 92 | 93 | 92 |
| Workers | % | 0 | 0 | 0 | 0 | 0 | 0 | 0 | 0 | 0 |
| 2022 | 2021 | 2020 | |||||||||
|---|---|---|---|---|---|---|---|---|---|---|---|
| Governing body members | u.m. | Men | Women | Total | Men | Women | Total | Men | Women | Total | |
| Under 30 years old | n | 0 | 0 | 0 | 0 | 0 | 0 | 0 | 0 | 0 | |
| 30 to 50 years old | n | 16 | 11 | 27 | 15 | 10 | 25 | 31 | 2 | 33 | |
| Over 50 years | n | 42 | 10 | 52 | 40 | 5 | 45 | 66 | 3 | 69 | |
| Total | n | 58 | 21 | 79 | 55 | 15 | 70 | 97 | 5 | 102 |
| 2022 | 2021 | 2020 | |||||||||
|---|---|---|---|---|---|---|---|---|---|---|---|
| Percentage of members of the organization's governing bodies by gender and age group | u.m. | Men | Women | Total | Men | Women | Total | Men | Women | Total | |
| Participants in management committees - under 30 years old | % | 0 | 0 | 0 | 0 | 0 | 0 | 0 | 0 | 0 | |
| Management committee participants - 30 to 50 years old | % | 20 | 14 | 34 | 21 | 14 | 36 | 30 | 2 | 32 | |
| Participants in management committees - over 50 years old | % | 53 | 13 | 66 | 57 | 7 | 64 | 65 | 3 | 68 |
| 2022 | 2021 | 2020 | ||||||||
|---|---|---|---|---|---|---|---|---|---|---|
| Number of employees by category and gender | u.m. | Men | Women | Total | Men | Women | Total | Men | Women | Total |
| Senior managers | n | 441 | 111 | 552 | 482 | 118 | 600 | 424 | 97 | 521 |
| Middle managers | n | 3,210 | 1,457 | 4,667 | 3,209 | 1,419 | 4,628 | 2,826 | 1,206 | 4,032 |
| Staff office | n | 27,453 | 17,550 | 45,003 | 28,593 | 18,092 | 46,685 | 24,641 | 13,717 | 38,358 |
| Workers | n | 155 | 0 | 155 | 0 | 0 | 0 | 0 | 0 | 0 |
| Total | n | 31,259 | 19,118 | 50,377 | 32,284 | 19,629 | 51,913 | 27,891 | 15,020 | 42,911 |
| 2022 | 2021 | 2020 | ||||||||
|---|---|---|---|---|---|---|---|---|---|---|
| Percentage of employees by category and gender | u.m. | Men | Women | Total | Men | Women | Total | Men | Women | Total |
| Senior managers | % | 80 | 20 | 100 | 80 | 20 | 100 | 81 | 19 | 100 |
| Middle managers | % | 69 | 31 | 100 | 69 | 31 | 100 | 70 | 30 | 100 |
| Staff office | % | 61 | 39 | 100 | 61 | 39 | 100 | 64 | 36 | 100 |
| Workers | % | 100 | 0 | 100 | 0 | 0 | 0 | 0 | 0 | 0 |
| 2022 | 2021 | 2020 | ||||||||
|---|---|---|---|---|---|---|---|---|---|---|
| Percentage of Executives by age group and gender | u.m. | Men | Women | Total | Men | Women | Total | Men | Women | Total |
| <30 | % | 0 | 0 | 0 | 0 | 0 | 0 | 0 | 0 | 0 |
| >50 | % | 76 | 64 | 70 | 76 | 58 | 67 | 80 | 64 | 72 |
| 30-50 | % | 24 | 36 | 30 | 24 | 42 | 33 | 20 | 36 | 28 |
| Percentage of Middle Managers by age group and gender | 2022 | 2021 | 2020 | |||||||
|---|---|---|---|---|---|---|---|---|---|---|
| u.m. | Men | Women | Total | Men | Women | Total | Men | Women | Total | |
| <30 | % | 0 | 0 | 0 | 0 | 0 | 0 | 0 | 0 | 0 |
| >50 | % | 73 | 66 | 69 | 72 | 63 | 67 | 74 | 65 | 69 |
| 30-50 | % | 27 | 34 | 30 | 28 | 37 | 33 | 26 | 35 | 31 |
| 2022 | 2021 | 2020 | ||||||||
|---|---|---|---|---|---|---|---|---|---|---|
| Percentage of Employees by age group and gender | u.m. | Men | Women | Total | Men | Women | Total | Men | Women | Total |
| <30 | % | 6 | 7 | 6 | 6 | 8 | 7 | 2 | 2 | 2 |
| >50 | % | 59 | 41 | 50 | 58 | 39 | 48 | 64 | 46 | 55 |
| 30-50 | % | 35 | 52 | 44 | 36 | 53 | 44 | 34 | 52 | 43 |
| 2022 | ||
|---|---|---|
| Percentage of workers by age and gender | u.m. | Men |
| <30 | % | 13 |
| >50 | % | 55 |
| 30-50 | % | 32 |
| Percentage of distinct employees for other indicators of diversity |
u.m. | 2022 | 2021 | 2020 |
|---|---|---|---|---|
| Ethnic minority employees | % | 7 | 6 | 0 |
| Disabled employees | % | 3 | 3 | 3 |
| Ethnic minority staff employees | % | 0 | 1 | 0 |
| Ratio of annual basic salary (RAL) of women than men by occupational category |
u.m. | 2022 |
|---|---|---|
| Senior managers | % | 101 |
| Middle managers | % | 97 |
| Staff office | % | 92 |
| Remuneration ratio (RGA) of women than men by occupational category |
u.m. | 2022 |
|---|---|---|
| Senior managers | % | 102 |
| Middle managers | % | 95 |
| Staff office | % | 92 |
| Ratio of annual basic salary (RAL) of women than men by occupational category |
u.m. | 2022 |
|---|---|---|
| Senior managers | % | 105 |
| Middle managers | % | 98 |
| Staff office | % | 68 |
| Remuneration ratio (RGA) of women than men by occupational category |
u.m. | 2022 |
|---|---|---|
| Senior managers | % | 103 |
| Middle managers | % | 98 |
| Staff office | % | 69 |
| Ratio of annual basic salary (RAL) of women than men by occupational category |
u.m. | 2022 |
|---|---|---|
| Middle managers | % | 84 |
| Staff office | % | 152 |
| Remuneration ratio (RGA) of women than men by occupational category |
u.m. | 2022 |
|---|---|---|
| Senior managers | % | 0 |
| Middle managers | % | 82 |
| Staff office | % | 146 |
Salary (RAL) was taken to mean gross annual fixed salary.
Remuneration (Annual Global Remuneration - RAG) was taken to mean RAL plus all individual incentive systems (MBO, Performance Bonus, Vendor Incentive).
[GRI 405-2b] See GRI 2-6 for the definition of significant place of business.
[GRI 407-1a] The activities carried out by the staff do not restrict freedom of association and all the rights and prerogatives provided by law and contract regarding union rights. Collective bargaining is applied to all employees within the perimeter of BU Domestic.
In Brazil, TIM S.A. guarantees its employees the full right to union freedom and collective bargaining (through the union). All these rights are guaranteed by a collective agreement.
TIM Brazil's collective agreements cover 100 percent of employees.
[GRI 407-1b] For the Domestic BU, TIM's industrial relations model is inspired to intensify the preventive phases of information and moments of union discussion, including through specific company bodies (in the form of committees), with the task of delving into specific matters in a technical manner, such as, by way of example, training, health and safety in the workplace, welfare and equal opportunities.
At the territorial level, the Unitary Trade Union Representatives (RSUs) have a widespread presence in all Italian regions to encourage adequate participation in decentralized discussions. The position of RSU member is held by about 380 people at TIM S.p.A. To the trade union representatives present in the Company, TIM recognizes specific prerogatives in addition to the protections and rights provided by law and the collective agreement.
At the employee's request, the employer in compliance with the provisions of the law and the contract shall make a deduction from the paycheck as a membership contribution to the union organization chosen by the employee. The percentage of workers who are union members is 39 percent (about 13,700 TIM S.p.A. employees).
In Brazil, TIM S.A. guarantees its employees the full right to union freedom and collective bargaining (through the union). All these rights are guaranteed by a collective agreement.
[GRI 408-1a] Within the BU Domestic perimeter, there are no activities at risk of incidents of child labor.
In Brazil, TIM S.A. does not identify this type of risk for employees.
[GRI 408-1b] Within the BU Domestic perimeter, there are no activities at risk of incidents of child labor.
In Brazil, TIM S.A. does not identify this type of risk for employees.
[GRI 408-1c] Within the BU Domestic perimeter, there are no activities at risk of incidents of child labor.
In Brazil, TIM S.A. does not identify this type of risk for employees.
[GRI 409-1a] In the BU Domestic Perimeter, no activities are at risk of incidents of forced or compulsory labor. In Brazil, TIM S.A. does not identify this type of risk for employees.
[GRI 409-1b] For the Domestic BU, TIM's industrial relations model is inspired by intensifying the preventive phases of information and moments of union discussion, including through specific company bodies (in the form of committees), with the task of delving into specific matters in a technical manner, such as, by way of example, training, health and safety in the workplace, welfare and equal opportunities.
At the territorial level, the Unitary Trade Union Representatives (RSUs) have a widespread presence in all Italian regions to encourage adequate participation in decentralized discussions. The position of RSU member is held by about 380 people at TIM S.p.A. To the trade union representatives present in the Company, TIM recognizes specific prerogatives in addition to the protections and rights provided by law and the collective agreement.
At the employee's request, the employer in compliance with the provisions of the law and the contract shall make a deduction from the paycheck as a membership contribution to the union organization chosen by the employee. The percentage of workers who are union members is 39 percent (about 13,700 TIM S.p.A. employees).
In Brazil, TIM S.A. does not identify this type of risk for employees.
Supply chain data in BU Domestic pertains to the following companies: Telecontact Center S.p.A. - Olivetti S.p.A. - TI Sparkle S.p.A. - TI Trust Technol. S.r.l. - TI Ventures S.r.l. - FIBERCOP S.p.A. - TIM MY BROKER S.r.l. - TIM SERVIZI DIGITALI S.p.A. - Telecom Italia S.p.A. - Noovle S.p.A. - TI SPARKLE GERMANY GmbH - TI SPARKLE NETHERLANDS BV - TI SPARKLE FRANCE S.a.s. - TI SPARKLE AUSTRIA GmbH - TI SPARKLE TURKEY - TI Sparkle Israel Ltd.
[GRI 204-1a] With reference to the BU Domestic perimeter(1), in 2022 total orders were placed with 2,813 suppliers of which 2,506 have production units in Italy and account for 93% of the total order.
Specifically, of the 2,506 suppliers, 97% are Italian companies and the remaining 3% are companies belonging to multinational corporations that conducted business through companies under Italian law.
In the BU Brazil, products are sourced as much as possible from local suppliers. The number of local Brazilian suppliers is 6,716, accounting for 98.8% of all BU Brazil suppliers and representing 98.8% of total orders.
[GRI 204-1b] In the Domestic BU, "local" is defined as suppliers having production units in the Italian territory.
In the BU Brazil, suppliers with production units in Brazil are considered local.
The main geographical areas in which the TIM Group operates are Italy and Brazil, for more details see GRI 2-6.
[GRI 308-1a] [GRI 414-1a] In the Domestic BU, the selection of Group's suppliers takes place through a pre-contractual qualification, aimed at assessing their economic-financial and technical-organizational characteristics. If the result of this assessment - which includes compliance checks on environmental issues - is positive, suppliers are entered into the Group's supplier registry. In 2022, 100% of newly qualified suppliers committed in writing on behalf of themselves and any authorized subcontractors, contractors and employees to abide by the behavioral principles of the Group's Code of Ethics and Conduct.
A mandatory self-assessment questionnaire on sustainability issues was sent to suppliers with significant risk in Brazil in 2022, accounting for 22% of the total number of new suppliers. 100% of the 243 providers involved responded by the end of 2022. The results are used as guidance for future selection processes.
(1) Excluding Infragroup, Energy and delegated purchases.
[GRI 308-2a, b, c, d, e] [GRI 414-2a, b, c, d, e] In the Domestic BU, the application of the process that defines activities aimed at improving supply chain sustainability continued during 2022. These activities involve the qualification, incoming quality and vendor rating stages. A matrix was created to divide purchasing markets into four classes, identifying those that were critical from the perspective of sustainability and economic impact.
Suppliers subject to sustainability audits conducted under the initiative called JAC (Joint Audit Cooperation)(2) are chosen from those in the highest risk classes. These audits are carried out by third-party specialized in the field and are repeated periodically to monitor the implementation of any corrective actions and, if successful, to verify that the level of performance found is maintained over time.
Where the JAC audit finds nonconformities against the required standard, a CAP (corrective action plan) is established, committing the supplier to resolve these nonconformities within the timeframe stipulated in the CAP.
During 2022, the JAC project resulted in 98 audits. During these audits, a total of 549 nonconformities were found, of which 104 related to environmental aspects and 445 to social aspects, with no "priority level" nonconformities.
To complement the JAC project, during 2022, TIM became a Value Chain Partner of the Open-es project. As part of this initiative, all active suppliers during 2022 were asked to register on this platform, where through the completion of a 114-question questionnaire the evaluation of the mentioned criteria through dedicated scoring takes place.
As of the end of 2022, 921 TIM suppliers have completed the ESG questionnaire on the Open-es platform. The detail of environmental and social impacts has not yet been processed.
For more information please refer to the Open-es website:https://www.openes.io/it
TIM S.A., in Brazil, performs qualification of all its suppliers related to activities considered critical to the socio-environmental management system. The socio-environmental qualification process is part of the process of contracting
(2) The Joint Audit Cooperation (https://jac-initiative.com/) was established under a memorandum of understanding signed in late 2009 by TIM, Orange and Deutsche Telekom. In the years since, the initiative
has expanded in a major way, and by the end of 2022, 27 telephone operators from around the world are part of the association, representing 2.7 billion telephone lines and >51% of the turnover of the world's Top 50 telephone operators.
new suppliers for the company's supply chain and also contributes to check the qualification criteria of suppliers who already have a relationship with the company. Throughout 2022, 243 suppliers participating in tenders for the provision of goods and services were evaluated. Of the 243 suppliers, 5% did not pass the qualification process, being considered critical and possibly causing social and environmental impacts to the Company. This framework refers to suppliers who did not meet the minimum score for approval in the process.
Since suppliers who do not pass the qualification process are prevented from continuing with the procurement process, there was no need to implement improvement plans with suppliers (GRI 308-2 d,c).
In parallel with the process described above, 292 suppliers who already had active contracts with TIM were evaluated between 2021 and 2022, thus ensuring the qualification of 100% of suppliers responsible for activities considered critical from a socio-environmental perspective.
Requirements not met by providers refer to deficiencies in the documentation listed below:
[GRI 407-1a.i, a.ii] In the Domestic BU, suppliers operating in the following geographic areas are considered to have higher social risk: Asia, Central and South America, North Africa and Eastern Europe.
[GRI 407-1b] Based on what is expressly prescribed in the "Purchasing Policy for Products and Services," and consistent with Group values, TIM requires (and promotes through its suppliers) respect for Freedom of Association and the right to collective bargaining. More details can be found in GRI indicators 2-23 and GRI 2-24.
The actions TIM puts in place for supplier controls vary depending on the risk level of the supplier and the amount of the purchase. Where any checks and/or audits show negative outcomes, appropriate corrective measures will be taken in accordance with the provisions of the contracts to ensure that the sustainability requirements set out in the guidelines are met.
[GRI 408-1a.i, a.ii, b.i, b.ii, c] No suppliers at risk of incidents of child labor were identified during 2022 among BU Domestic suppliers.
Regarding the issue of child labor, suppliers operating in the geographic areas Asia, Central and South America, North Africa and Eastern Europe are considered to be at greater social risk.
With regard to child labor, the "Products and Services Purchasing Policy" stipulates that no use is made of, nor support provided in any way for, the employment of persons under 18 years of age, unless different legal limits are set in individual countries and in any case, in compliance with relevant European policies. In any case, minors under the age of 18 should not be employed in hazardous work or at night. Again, where any checks and/or audits show negative results, appropriate corrective measures will be taken in accordance with the provisions of the contracts to ensure that the sustainability requirements set out in the guidelines are met.
In TIM S.A., activities are carried out according to the "Supplier Relationship Policy", which establishes commitments to be followed to prevent risks related to child labor in the sphere of supply chain and business partnerships. The policy regulates key points such as fair competition, quality, safety, human rights and social-environmental responsibility. The contractual instruments also require companies to adhere to the Company's Integrity Program and the principles of the United Nations Global Compact, as well as expressly providing for the repudiation of child labor. Suppliers are also evaluated according to Brazilian labor laws by consulting the databases of the Business Pact for Integrity and Against Corruption and the Brazilian National Pact for the Elimination of Forced Labor. In case of proven incidents related to non-compliance with labor laws, the supplier may not provide services or products to the Company. No suppliers with a significant risk of child labor were identified in 2022.
[GRI 409-1a.i, a.ii, b] Regarding the issue related to forced or compulsory labor, suppliers operating in the geographic areas Asia, Central and South America, North Africa, and Eastern Europe are considered to be at higher social risk. During 2022, no suppliers of the Domestic BU were identified among the suppliers with these types of risks. The "Products and Services Purchasing Policy" prohibits any form of compulsory labor or service, obtained under the threat of any penalty or as a form of extinguishing a debt; workers cannot be required to leave any deposit at the beginning of employment or sign blank documentation waiving their rights at an earlier date of their exercise or legitimate waiver of exercise. Where checks and/or audits show negative outcomes, appropriate corrective measures will be taken in accordance with the provisions of the contracts to ensure that the sustainability requirements set out in the guidelines are met.
In TIM S.A., activities are carried out according to the "Supplier Relationship Policy", which establishes commitments to be followed to prevent risks related to forced labor in the sphere of supply chain and business partnerships. The policy regulates key points such as fair competition, quality, safety, human rights and social-environmental responsibility. The contractual instruments also require companies to adhere to the Company's Integrity Program and the principles of the United Nations Global Compact, as well as expressly provide for the repudiation of forced or compulsory labor. Suppliers are also evaluated under Brazilian labor laws by consulting the databases of the Business Pact for Integrity and Against Corruption and the Brazilian National Pact for the Elimination of Forced Labor. In case of proven incidents related to non-compliance with labor laws, the supplier may not provide services or products to the Company. No providers with a significant risk of forced or compulsory labor were identified in 2022.
[GRI 416-1a] To verify that products placed on the market comply with health and safety standards, TIM Italia has special in-house facilities that plan "type tests" for the initial evaluation of products to company specifications and incoming quality checks of products passed into the marketing stage, taken both in Italy and at suppliers' production centers abroad. The Company also has laboratories that carry out tests on products marketed by the Group, particularly on electrical safety and electromagnetic emissions. In TIM S.p.A., the percentage of significant product and service categories in relation to which health and safety impacts are assessed with a view to improvement is 100 percent.
In 2022, at the request of TIM's Engineering functions, eight pieces of equipment for FWA(1), FTTH(2) and FTTCab(3) networks intended to be installed at the customer site were checked in the labs; no equipment for incoming quality checks was received in the labs in 2022.
Specifically, for product liability, TIM verifies:
In order to promote sustainable development in its areas of influence, in addition to the legally mandated requirements for electrical safety, power consumption
(1) Fixed Wireless Access, which is a set of transmission systems developed to use given radio spectrum frequencies in order to provide broadband Internet connectivity services with nominal connection speeds of 1 giga byte per second (Gbps).
(2) Fiber To The Home, that is, fiber optics runs from the central office and directly into the apartments.
(3) Fiber To The Cabinet, or fiber optics that runs from the central office to the cabinet in the street closest to the apartments.
(4) Required by the 2009/125/EC ErP (Energy-related-Products) Directive, as equipment placed on the market is verified against the Stand-by/Off-mode (pause/off) power consumption and efficiency limits of European Regulations Nos. 1275/2008/EC, 801/2013/EC and 2019/1782/EC, for equipment and its external power supplies (present as accessory equipment).
(5) In fact, compliance with the temperature and humidity ranges stipulated by the European Telecommunications Standards Institute (ETSI) standards for the specific "service condition," from which different levels of "severity" are derived, is controlled. The tests are conducted based on the ETSI EN 300019 family of standards, with the test methods provided by IEC-EN 60068-2-1 series (cold), 60068-2-2 (dry heat), 60068-2-14 (temperature changes), 60068-2-30 (humidity changes), 60068-2-78 (continuous humidity).
(6) Regulated by Directives 2014/30/EU and RED 2014/53/EU, in that there is a requirement to control the emission of unintentional electromagnetic signals - in order to avoid harmful interference to radiocommunications - and to meet certain requirements for immunity to electromagnetic interference. Continuous testing of terminals and network equipment is carried out at TIM to determine compliance with the requirements set by international standards for electromagnetic compatibility. In particular, the compliance of the equipment with the limits set by the standards to circumscribe the emissions of electromagnetic disturbances that, in addition to polluting the surrounding environment, may interfere with radio communications is verified.
and EMC(7) on marketed equipment, TIM also performs verifications of electrical and mechanical robustness requirements(8), so as to contribute to the reduction of waste electrical and electronic equipment (WEEE) at source(9). The addition of such robustness requirements, even within the TIM specifications of apparatus, requires the manufacturer to use appropriate protection devices on the electrical interfaces of the devices, such as overvoltage and overcurrent limiters, resulting in a reduction in the number of destructive type failures; with such technical arrangements, it follows that the functionality of the apparatuses is prolonged over time and, in cases of occasional damage, the same functionality can be easily recovered with the replacement of a few components/modules by repair centers.
With respect to equipment destined for customer sites, and transited through the laboratories during 2022 for verification of mandated requirements for CE marking, 50% of the products are modems/routers and accessories for VDSL(10) and FTTH services, 25% are FWA modems/routers, and 25% are ONT(11) optical network terminations.
By law, all telecommunications equipment sold in Brazil must be approved by
the ANATEL Regulatory Authority, which verifies, in its laboratories, compliance with Brazilian legislation regarding electrical and electromagnetic safety to ensure complete health and safety protection. There is ad hoc legislation that must be complied with for each type of equipment; TIM S.A. requires its suppliers to ensure that the devices have ANATEL's certificate of approval, and TIM S.A guarantees in the internal certification only that the product will work with the network/frequency that they operate in Brazilian territory.
[GRI 416-2a] The Entry Quality checklists for TIM S.p.A. provide for concurrent monitoring/surveillance of both "Requirements Impacting Product Health and Safety" and "Product Information and Labeling." Therefore, instances of noncompliance with regulations involving a warning are coincident in number between "Requirements Impacting Product Health and Safety" and "Product Information and Labeling."
(7) Electro Magnetic Compatibility; regulates radio equipment in order to affix CE Marking.
(8) In accordance with the installation classes stipulated in European standard ETSI EN 300019.
(9) Infact, by placing equipment with an appropriate level of electrical and mechanical robustness on the market with respect to the expected stresses in the field, the failure rate of equipment and, therefore, the amount of waste to be sent to appropriate disposal centers is reduced.
(10) Very High Bit Rate Digital Subscriber Line is a cable xDSL communication technology that enables higher speed performance than its predecessor ADSL.
(11 ) Optical Network Terminal, which is an apparatus that transforms the optical signal and allows you to connect your modem to the fast network.
| TIM S.p.A. | 2022 |
|---|---|
| Instances of noncompliance with regulations resulting in a fine or a penalty |
0 |
| Instances of noncompliance with regulations resulting in a warning | 3 |
| Cases of non-compliance with self-regulatory codes | 0 |
[GRI 416-2b] In Italy, in the last 3 years, for no product that has reached the final stage of commercialization, nonconformities have been found on health and safety for the customer according to European regulations.
No noncompliances with regulations and voluntary codes related to health and safety impacts of products and services have been identified in Brazil in the past three years.
[GRI 417-1a] Also in 2022, TIM required all of its fixed-line providers:
In addition to the above documents, for all new deliveries of the fixed, TIM continues to require the completion of an additional document called the "Sustainability Checklist," in which all information related to sustainability from production to the end of the product's life is to be reported, highlighting the different types of materials and their disposal, including packaging materials.
For warranty service, TIM continues to use only remanufactured modems; the possibility of selling these remanufactured products to the public remains under consideration.
As far as mobile phone equipment is concerned, since they are consumer products that TIM merely resells and for which no customization is required, the Company merely requires suppliers to comply with national regulations.
(12) Registration, Evaluation, Authorisation and restriction of Chemicals" is a European Union Regulation 1907/2006 on the Registration, Evaluation, Authorisation and Restriction of Chemicals.
The sale of remanufactured smartphones, which started in the fall of 2019, continued into 2022, with remanufactured iPhone models listed on Consumer Mobile. These products are exclusively Class A+ to ensure the highest quality (original spare parts only) for the end customer.
To reduce environmental impact, following the example of new models, accessories and packaging materials have also been minimized in the packaging of remanufactured smartphones; chargers and earphones are no longer included in the packages.
From Q4 2022 TIM launched the TIM VALUTA service, which allows end customers to hand over their old smartphone and get a discount on the installment purchase of new smartphone.
For obsolete smartphones, TIM has for the past few years organized recycling activities, which take place through disposal characterized by online sales competitions. Products are composed in batches, and companies identified and authorized for this purpose may participate in the tenders. Sold products are disassembled afterwards so that all components of interest are recovered for their "second life cycle."
In addition, to reduce the environmental impact in the use of plastic, TIM markets SIMs in half-card format (half the size of normal SIM cards) and uses recycled plastic for the card carrier(13). This saves about 14 tons per year of plastic.
In Brazil, TIM does not have procedures on product and service information and labels.
| TIM S.p.A. | 2022 | 2021 | 2020 |
|---|---|---|---|
| Number of batches tested between fixed and mobile terminals |
246 | 237 | 107 |
| Number of lots with negative test results | 3 | 3 | 0 |
| Number of lots with negative test results and sanctioned |
0 | 5 | 0 |
| Number of lots with negative test results and for which a notice was materialized |
3 | 3 | 0 |
In BU Brazil, there were no cases of anomalies in labeling of products and services during 2022.
(13) Supporting card.
[GRI 417-2a] Entry Quality checklists in the Domestic BU provide for concurrent monitoring/surveillance of both "Requirements Impacting Product Health and Safety" and "Product Information and Labeling." Therefore, instances of noncompliance with regulations involving a warning are coincident in number between "Requirements Impacting Product Health and Safety" and "Product Information and Labeling."
| TIM S.p.A. | 2022 |
|---|---|
| Cases of non-compliance with self-regulatory codes | 0 |
| Instances of noncompliance with regulations resulting in a warning | 3 |
| Instances of noncompliance with regulations that result in a fine or penalty | 0 |
[GRI 417-2a] In Brazil in the three-year period 2022-2020 for no products that reached the final stage of commercialization were found to have nonconformities concerning product disclosure and labeling.
[GRI 417-2b] The following list shows the results of the incoming quality checks carried out on "fixed and mobile terminals" performed for TIM S.p.A:
In Brazil, no cases of non-compliance with regulations on information and "labeling" of services were found in 2022.
TIM SpA was not subject to any new investigation or sanction during 2022.
| TIM S.p.A. | 2022 | 2021 | 2020 |
|---|---|---|---|
| Number of instances of noncompliance with voluntary codes(14) |
0 | 2 | 1 |
| Number of instances of non-compliance with regulations materialized in fines or penalties |
0 | 0 | 0 |
| Number of instances of noncompliance with regulations materialized in a notice |
0 | 0 | 0 |
In Brazil, the only notifications related to advertising and marketing communications are issued by CONAR, a non-governmental advertising selfregulatory body that assesses non-compliance with the Brazilian Code of Conduct for Advertising ("CBAP") and may recommend to the company the modification/
correction or suspension of the advertisement (it does not impose fines); CONAR aims to ensure that every advertising message is true, honest, compliant with the country's laws and the principle of fair competition. Infringement proceedings may be terminated if the parties reach an agreement, if the perpetrators cease the infringement, or if the infringement has not been proven of the Code of Ethics.
In December 2021 TIM applied for disassociation from CONAR. As a result, TIM can no longer request the initiation of proceedings from the Authority, but can still be sued as an advertiser.
In BU Brazil, during 2022, there were no non-compliance cases regarding marketing communications.
(14) Cases are settled by the Institute of Advertising Self-Discipline, which operates in accordance with the Code of Commercial Communication and is competent in settling all advertising disputes involving member entities, directly or indirectly. Jury decisions never result in financial penalties but, where appropriate, in an order to desist from the disputed advertising release. The two nonconformities in 2021 concerned:
• the case Wind Tre S.p.A. v. Telecom Italia S.p.A. (hearing on July 27, 2021). Telecommunications operators Windtre and Vodafone have filed a petition with the Advertising Self-Regulation Jury against TIM's communication advertising the TIM A-series wifi;
• the proceedings Windtre, Vodafone, Fastweb and Sky v. Telecom Italia S.p.A. (hearing on September 28, 2021). The mentioned operators petitioned the jury against TIM's advertisement that mainly advertised the offer of Serie A matches.
The 2020 non-compliance was related to the "Switch to Kena Mobile" telecommunication detected on commercial TV networks in June; TIM had ceased the advertising in question as of the date of the notification of the injunction.
| TIM S.p.A. | 2022 | 2021 | 2020 |
|---|---|---|---|
| Requests received from the Privacy Guarantor (number of cases/complaints reported) |
85 | 70 | 15 |
| Responses to requests to exercise customer privacy rights addressed to TIM Customer Care* |
157,747 | 284,830 | 1,103,502 |
| - of which responses to requests to exercise privacy rights addressed by TIM customers directly to the data protection officer |
3,489 | 2,797 | 2,760 |
| Total number detected of leaks, thefts or losses of customer data |
1 | 0 | 0 |
As for the other TIM Group Companies with DPO (Data Protection Officer) perimeter, based on the data provided by the companies themselves, the 2022 totals are as follows:
| BU Domestic | 2022 |
|---|---|
| Requests received from the Privacy Guarantor (number of cases/complaints reported): |
0 |
| Responses to requests for customers to exercise their privacy rights addressed to Group companies |
18 |
| - of which responses to requests to exercise privacy rights addressed by customers directly to the email boxes of the DPO of Group Companies |
13 |
| Total number detected of leaks, thefts or losses of customer data | 0 |
[GRI 418-1] In BU Brazil, there were no complaints regarding privacy breaches and/or loss of customer data during 2022, according to local regulations.
[GRI 418-1c] Also during 2022, BU domestic continued to put in place the necessary actions to ensure the implementation in internal processes of the provisions on personal data security breaches (c.d. "data breach"), as well as to respond to requests for information from the Privacy Guarantor (as a result of customer reports/complaints) and to numerous requests from customers to exercise their privacy rights (e.g., aimed at knowing what personal data TIM processes, objecting to promotional calls, requesting rectification of inaccurate data or deletion of data). It is represented that requests for information from the Privacy Guarantor and requests from customers to exercise privacy rights have nothing to do with this indicator regarding "Proven complaints regarding customer privacy violations."
In Brazil, the Data Protection Officer (DPO) of TIM S.A. has not become aware of any specific complaints related to privacy breaches and/or loss of data of the company's customers.
In 2022, TIM S.A. received more than 600 inquiries from customers regarding owners' rights.
Among the requests for privacy rights received so far, the most frequent have included:
(i) Right of access;
(ii) request for deletion of data;
(iii) request to discontinue advertising messages.
[GRI 201-1a] Economic value produced, distributed and retained.
| TIM Group data (in millions of euros) | 2022 | 2021 | 2020 |
|---|---|---|---|
| (a) Total operating income and revenues | 16,001 | 15,588 | 16,016 |
| (b) Interest income and dividends received | 276 | 165 | 311 |
| (c) Capital gains (losses) on the realization of non-current assets |
36 | 1 | -11 |
| (d) Directly produced economic value (a+b+c) | 16,313 | 15,753 | 16,316 |
| (e) Operating costs | 7,369 | 7,467 | 6,542 |
| (f) Personnel costs | 3,180 | 2,941 | 2,639 |
| (g) Lenders | 1,439 | 1,580 | 1,643 |
| (h) Duties and taxes | -476 | 110 | 676 |
| (i) Distributed economic value (e+f+g+h) | 11,512 | 12,098 | 11,500 |
| Economic value retained (d-i) | 4,801 | 3,655 | 4,816 |
[GRI 201-1b] The TIM Group's operating segments, organized with regard to the telecommunications business taking into account the relative geographical location, are as follows:
• Domestic: includes the activities in Italy related to voice and data services on fixed and mobile networks for end customers (retail) and other operators (wholesale), the activities of the Telecom Italia Sparkle group, which, in the international field (in Europe, the Mediterranean and South America), operates in the development of fiber optic networks for wholesale customers, the activities of the company FiberCop S.p.A. for the provision of passive access services of the secondary network in copper and fiber, the activities of Noovle S.p.A. (Cloud and Edge computing solutions), the activities of Olivetti S.p.A. (products and services for Information Technology) and the support structures for the Domestic sector;
[GRI 203-2a] [GRI 203-2b] The digitization process in Italy, to which TIM is contributing with the development of fixed and mobile ultrabroadband and related services, is an indispensable resilience tool for the country's economy: the positive impacts that the adoption of broadband and ultrabroadband generate on the global economy are confirmed by several international studies, according to which a doubling of broadband speeds produces 1.5 percent GDP growth.
Ultrabroadband, particularly in recent years, has proven more necessary than ever to prevent a part of the population from being denied the chance of keeping up with the rest of the country: the digital divide is in danger of turning into an economic and social divide, which is why the overcoming of the digital divide throughout the country will be completed by 2024. In addition, the digital transition leads to ensuring inclusiveness by expanding the pool of citizens who use it and improving their digital skills.
| BU Domestic | 2022 | 2021 | 2020 |
|---|---|---|---|
| LTE coverage | 99 | 99 | 99 |
| Next Generation Plan coverage (fixed-line telephony) FTTX | 89 | 89 | 85 |
| of which FTTH | 32 | 24 | 18 |
The European Commission annually publishes the results of the Digital Economy and Society Index (DESI) 2022, a report that presents data on human capital, connectivity, integration of digital technologies and digital public services in European countries. Italy's greatest acceleration is in the area of connectivity, thanks to TIM's strong contribution: Italy rises from 23rd in 2021 to 7th in 2022 in the rankings behind traditionally leading countries.
For more than 20 years in Italy, TIM has been a key player in the solidarity process linked to projects with humanitarian, scientific, social promotion and environmental protection purposes, which it supports by offering the possibility of making donations worth 2 euros by sending an SMS or 2, 5 or 10 euros through a phone call from a landline to a dedicated number. The amounts collected are paid entirely by TIM to the Promoting Entities (Non-Profit Organizations, NGOs, NPOs, VOs), according to transparency and sustainability requirements without any withholding or application of tax rate. The new Self-Regulatory Code, issued by AGCOM - Autorità per le Garanzie nelle Comunicazioni, has provided for the establishment of 60 numbers dedicated to solidarity fundraising and governed by a special price list.
There are two free numbers designated for emergencies or natural disasters at the request of the Civil Defense Department.
More than 100 solidarity campaigns were activated by TIM in 2022, raising about 11 million euros. The largest funds were raised for scientific research initiatives, followed by medical and social welfare initiatives.
[GRI 203-2a] [GRI 203-2b] TIM S.A. is committed to bringing 4G coverage to 100 percent of Brazilian municipalities, as well as investing in the country's infrastructure and offering convenient deals to its customers. TIM's telecommunications activities generate positive impacts beyond business, as mobile telephony and broadband Internet services enable not only communication, but also create countless opportunities for people and businesses, acting as a powerful tool for innovation. This transformation is also linked to digital inclusion by providing connectivity in regions that do not have access to these resources, such as isolated communities, rural areas, and lowincome areas. The digitization of various services and the migration of various activities to online platforms, particularly in the wake of the Covid-19 pandemic, have contributed to the recognition of telecommunications as an essential service. In addition, Instituto TIM plays an important role in terms of impacting and transforming society through investments in social, educational and cultural initiatives and projects. TIM S.A.'s materiality matrix also presents the boundaries of these impacts (TIM, supply chain, consumption chain, post-consumption chain), whether they are direct (caused by TIM's business) or indirect (arising from TIM's relationships with its value chain).
More information on these economic impacts of TIM S.A. is available in the ESG Reports and on the Instituto TIM website: https://institutotim.org.br/. With regard to combating climate change, TIM S.A. understands that telecommunications play an important role in reducing greenhouse gas emissions, as they enable remote communication and reduce the need for travel and thus the consumption of fossil fuels, and the opportunities that come with this. For this reason, TIM S.A. invests in offering solutions based on new technologies, stimulating more efficient production models and logistic processes in various sectors, presenting itself as a promoter of a low greenhouse gas economy.
| BU Brazil | 2022 |
|---|---|
| LTE coverage | 96 |
| Next Generation Plan coverage (fixed-line telephony) FTTX | 738,111 |
| of which FTTH | 722,697 |
[GRI 205-1a] TIM S.p.A. includes a special "anti-corruption clause" in its contracts. As part of this clause, compliance is required with both the anti-corruption regulations (including the U.S. (FCPA) and U.K. (Bribery Act), and the adopted Group Anti-Corruption Policy. There were 112 contracts submitted to the Compliance Department during 2022, of which 12 related to domestic subsidiaries of the Group.
In addition, the Company carries out due diligence activities on Third Parties, and during 2022 no red flags attributable to bribery hypotheses were revealed. Specifically, there were 1,729 due diligences conducted during 2022, of which about 970 related to Third Parties of domestic subsidiaries.
20 sensitive activities were identified by TIM S.A. in Brazil during 2022.
[GRI 205-1b] In 2019, TIM S.p.A. adopted the Anti-Corruption Management System (AMS), which applies to the Company, members of its corporate bodies, employees, and collaborators in various capacities.
In relation to subsidiaries, it is required to apply the AMS or appropriate safeguards for the prevention of corruption, to the extent that this is reasonable and proportionate in relation to the corruption risks to which these subsidiary organizations are exposed. With regard to the latter, it should be noted that TIM Brazil (March 2021), Olivetti S.p.A. (May 2022), Telecontact S.p.A. (July 2022) and Telecom Italia Trust Technologies S.r.l. (June 2022) are certified according to the ISO 37001 standard. In addition, the certification process for TI Sparkle S.p.A. is ongoing.
As part of this Anti-Corruption Management System, TIM S.p.A. has assessed about 650 business units as per the UNI ISO 37001:2016 certification obtained by TIM S.p.A. in 2019 and reconfirmed in the years 2020-2021 and most recently in October 2022.
All of these business units (100%) are included in the assessment for corruptionrelated risks within TIM S.p.A. In addition, TIM S.p.A. has analyzed the significant risk scenarios regarding conduct attributable to both active corruption and passive corruption, in the direct and indirect form, and towards both public and private entities.
As a result of the Anti-Corruption Risk Assessment activities, TIM S.p.A. has identified the following areas at risk of active/passive forms of corruption:
In addition, with reference to the Organizational Model 231 of TIM S.p.A. and
with reference to the risk areas reported above, the following sensitive processes exposed to the risk of corruption have been identified:
With reference to Third Parties, TIM S.p.A. has identified relationships that may present risk profiles in relation to anti-corruption regulations. These risks may arise from (i) the type or nature of the relationship (Relevant Relationships) and (ii) the characteristics of the third party or the activities performed by it (Relevant Third Parties).
With regard to Relevant Relationships, the following have been identified:
With regard to Relevant Third Parties, the following have been identified:
sub-agents and similar figures, whom TIM S.p.A. may use in the pursuit of its business activities;
In addition, job positions with non-low risk of Corruption (Relevant Positions) are identified:
• manager or employee of the Company who represents or acts on behalf of TIM S.p.A. with reference to activities or relationships with third parties that present Corruption risk profiles;
• manager or employee of the Company who has the role of manager with decision-making functions in processes that have profiles of risk Corruption.
Finally, the Company is in the process of equipping itself with an IT support system aimed at assessing the risk of third parties by conducting Anticorruption Due Diligence activities.
In Brazil, according to TIM S.A.'s Corporate Risk Management Policy, the TIM Group adopts a Corporate Risk Management (ERM) process for the identification and management of risks that may compromise business objectives and the effective adoption of related mitigation measures. In this context, the Compliance Board is involved in the process of risk identification and assessment, including the risk of corruption and the respective mitigation controls and ongoing monitoring of certain activities considered sensitive for this type of practice.
The Governance & Integrity Compliance area conducts an annual risk assessment of the Sensitive Activities and relates them to the respective relevant processes, the areas and functions responsible for those processes, the stakeholders involved, the risk scenarios and the respective mapped controls, the evaluation of the results of the controls, and the risk assessment. The objective of the corruption risk assessment is to enable the Company to establish the basis for the Anti-Corruption Management System (SGAA in Portuguese) through:
In particular, specific factors such as the location and sectors of activities, the nature and complexity of activities, the presence of third parties, and the relationships held are taken into consideration to carry out the corruption risk assessment. In carrying out these activities TIM Brasil:
The Company establishes criteria for assessing corruption risk, taking into account TIM's internal policies and objectives. This assessment is carried out and verified by the Compliance Function as part of the risk assessment:
In order to combat corruption, special attention and constant monitoring of certain activities considered sensitive for this type of practice (Sensitive Activities) is essential. The result of the annual Anti-Corruption Risk Assessment activity identifies relationships, third parties, roles and activities with a medium to high level of exposure to corruption risk. In general, the assessment of corruption risk thus depends on:
Following the risk assessment process and identification of sensitive activities under the anti-corruption laws applicable to the TIM Group in Brazil, the Company has identified the following sensitive activities, detailed below:
[GRI 205-2a] The Board of Directors of TIM S.p.A approves the Anti-corruption Policy, Code of Ethics and Conduct, 231 Organizational Model, and Compliance Management Activity Plan related to TIM S.p.A.'s Anti-corruption Management System and receives information on its progress.
Similarly, the Boards of Directors of domestic subsidiaries approve the Group's Code of Ethics and Conduct, its own 231 Organizational Model, the AMS in the case of ISO 37001-certified companies, as well as the Anti-corruption Policy (previous version, in the case of non-ISO 37001-certified companies).
[GRI 205-2b] Group employees, for 2022, have been informed of the anticorruption policies and procedures as below:
| GROUP | BU DOMESTIC | BU BRAZIL | |||||
|---|---|---|---|---|---|---|---|
| Executives | 534 | 92% | 469 | 92% | 64 | 88% | |
| Squares | 4,602 | 99% | 4,260 | 100% | 336 | 90% | |
| Employees | 44,737 | 97% | 36,043 | 96% | 8,691 | 99% | |
| Workers | 155 | 97% | 155 | 97% | 0 |
[GRI 205-2c] TIM S.p.A. publishes its Code of Ethics and Conduct, Anti-Corruption Policy and Anti-Corruption Manifesto on the Group Supplier Portal.
Key Partners can be providers of goods and services, professional consultants/lenders, indirect business network partners, as well as OLOs. In addition, the Anti-Corruption Policy, the Code of Ethics and Conduct and the 231 Organizational Model are disseminated to all external stakeholders through publication both on the website and on the intranet.
Lastly, as mentioned above, TIM S.p.A. includes a special "anti-corruption clause" in its contracts with its business partners.
As part of this clause, acknowledgment of the Code of Ethics and Conduct, the TIM S.p.A. Anti-Corruption Policy and the 231 Organizational Model is required. In particular, Order Vouchers are issued with the clause requiring acceptance of the documents mentioned above.
[GRI 205-2d] The Board of Directors of TIM S.p.A conducts induction sessions as needed, which also include issues in anti-corruption compliance.
[GRI 205-2e] Group employees, for 2022, who have received training on anticorruption policies and procedures are shown in the tables below:
| GROUP | BU DOMESTIC | BU BRAZIL | ||||||
|---|---|---|---|---|---|---|---|---|
| Executives | 214 | 37% | 149 | 29% | 64 | 88% | ||
| Squares | 4,227 | 91% | 3,891 | 91% | 330 | 88% | ||
| Employees | 36,254 | 78% | 27,669 | 74% | 8,582 | 98% | ||
| Workers | 0 | 0 | 0 |
[GRI 205-3a] In the past 3 years, no incidents of corruption have been established either in TIM S.p.A. or in the Group's domestic subsidiaries. In addition, during the same period, there were no corruption-related legal proceedings initiated against either TIM S.p.A. or domestic subsidiaries. As a result, none of the Group's domestic subsidiaries have registered any penalties or entered into plea bargains in connection with corruption incidents in the past 3 years. No cases of corruption were recorded in Brazil in 2022.
[GRI 205-3b] In the past 3 years, neither in TIM S.p.A. nor in any domestic subsidiary of the Group has there been an incident of corruption. Therefore, within this perimeter, no employee has been dismissed or charged for corruption. No cases of corruption were recorded in Brazil in 2022.
[GRI 205-3c] With regard to suppliers, neither TIM S.p.A. nor the Group's domestic subsidiaries have terminated a contract for reasons attributable to corruption in the past 3 years.
No cases of corruption were recorded in Brazil in 2022.
[GRI 205-3d] There have been no legal proceedings on corruption grounds against either TIM S.p.A. or the Group's domestic subsidiaries in the past 3 years. It follows that with regard to this perimeter, no sanctions were recorded, nor were any plea bargains concluded in connection with corruption incidents.
No cases of corruption were recorded in Brazil in 2022.
Since 2017, TIM S.p.A. has adopted its own tax strategy for the purpose of defining the objectives and principles adopted by the company in managing taxation, both at the corporate level and in its relations with tax authorities.
This strategy is approved by the TIM Group Board of Directors and is updated promptly in case of changes at the strategic and/or operational level.
TIM S.p.A., in adherence to the "general principles" set forth in the Code of Ethics and in the respect and autonomy of its management choices, intends to pursue a tax strategy inspired by principles of honesty, fairness and compliance with tax regulations.
To this end, TIM is committed to:
and have as their objective the development of business activities included in the corporate purpose;
• Carry out cross-border intercompany transactions in accordance with free competition principle as established by the OECD (Transfer Pricing Guidelines).
[GRI 207-2a] The Board of Directors of TIM S.p.A., whose evaluations and decisions are supported by adequate preliminary activity by the Audit and Risk Committee, is responsible for periodically verifying the adequacy of the internal control and risk management system, of which the tax risk management system is an integral part, as well as its effective functioning.
The TIM Group has adopted a fiscal risk management and control system that includes a governance model designed to ensure that:
implications of these activities, to ensure the proper management of the tax variable.
To this end, the incentive system of the Tax Function does not include specific targets related to tax rate reduction.
The TIM Group trains and supports all personnel involved in the management of tax-relevant activities, not limiting itself to resources specifically dedicated to tax matters, in order to ensure that all employees have the right skills and experience to fulfill their responsibilities.
In order to achieve the above goal, the Group also invests in the professional growth of staff through specific training plans.
TIM employees and management at all levels are expected to model their behavior on the "general principles" set forth in the Code of Ethics, such as honesty, fairness, transparency, confidentiality, impartiality, diligence, loyalty and mutual respect. Failure to comply with these principles may result in legal action being taken and measures being taken against the recipients, consistent with the provisions of the Code of Ethics.
Top management informs management and all employees involved about the aforementioned values and codes of conduct declined in the fiscal sphere, appropriately incentivizing and recognizing virtuous behavior and sanctioning recognized violations, according to the "Tone at the Top" principle.
TIM's goal is to minimize fiscal risks.
To this end, the Group:
To ensure effective tax risk management, TIM has adopted a system for the detection, measurement, management and control of tax risk (Tax Control Framework), governed by a specific Tax Policy, which provides:
[GRI 207-2b] The TIM Group, in observance of the principles of honesty, fairness and compliance with tax regulations, considers it essential to prevent the risk of incurring unethical or illegal behavior, with consequent reputational as well as financial impacts.
To this end, each function is required to seek prior advice from the relevant Tax Function on the tax implications of any facts with a novel character that affect its scope of operations.
In addition, the Group has adopted a reporting procedure (so-called whistleblowing procedure) through which each employee is required to report, using a special portal, cases of suspected fraud with tax impacts, or the risk of TIM incurring violations of tax regulations as a result of relevant conduct by third parties, of which he or she has become aware.
Relevant conduct to be reported concerns actions or omissions made by third parties that, by resulting in an untrue or fraudulent representation of facts, may mislead the Company regarding the application of relevant tax regulations.
[GRI 207-2c] The tax information to be reported in financial reporting is prepared by the Tax Department, which certifies its accuracy and completeness. There is no ad hoc external assurance report, but the data are reviewed in the broader audit work conducted by EY on the Consolidated Financial Statements.
The TIM Group, in compliance with the principle of "Corporate Responsibility," acts according to the values of honesty and integrity in managing the tax variable, protecting the interests of all stakeholders, being aware that tax revenues constitute one of the main sources of contribution to the economic and social development of the countries in which it operates.
With a view to imbuing its relations with the tax authorities with the principle of cooperation and good faith, TIM has joined the Collaborative Compliance Scheme (better known internationally as Cooperative Compliance) on a voluntary basis, effective from the 2017 tax year. This scheme involves a new way of interacting with the tax authorities, aimed at reducing the degree of uncertainty in the management of tax issues and preventing the risk of tax disputes.
In this regard, TIM, in particular, undertakes to:
With reference, however, to Brazil, the TIM Group has locally adhered to a Cooperative Compliance program developed by the State of São Paulo (so-called. "Nos Conformes"). In addition, the TIM Group, along with some other large contributors in Brazil, has joined a project (c.d. "Confia Program") for the future introduction of a Cooperative Compliance program in federal taxation as well. In addition, TIM adheres to the transfer pricing documentation requirements in accordance with the OECD Guidelines, which are based on the so-called "threetiered approach," consisting of Master File, Country File and Country-by-Country Report.
TIM acts in a transparent and collaborative manner with all Italian and European institutions and trade associations to support the development of effective systems in the countries in which it operates.
In particular, certain TIM representatives actively participate in Tax Policy activities carried out by Italian and EU trade and business associations, both in general business and industry-specific contexts; the same activity is also carried out by the TIM Group in Brazil, with reference to local operations.
The amount of key financial, economic and fiscal indicators for the jurisdictions in which the TIM Group operates is given at the end of this chapter. It should be noted that these indicators refer to the year 2021, and are those reported in the "Country by Country" reporting required by Art. 1, comm. 145 and 146 of Law 28/12/ 2015, No. 208, submitted by the TIM Group in 2022.
The construction of network infrastructures in some parts of Italy can sometimes have negative impacts on the local community in terms of aesthetic alteration of the environment or noise during their construction. All network facilities built by TIM are subject to permits issued by the relevant authorities and ensure the coexistence of the public interest in network coverage throughout the country and the guarantee of safety of the facilities themselves for the community. With particular reference to the construction of mobile network infrastructure (radiobase stations), all regulations and processes to ensure electromagnetic pollution limits, which are particularly stringent in our country, are respected.
In Brazil, TIM S.A. employs teams for licensing and compliance monitoring of the company's sites, such as Radio Base Stations (ERBs), technical buildings, and Data Centers.
ERBs result in impacts at the time of their construction due to the local movement of workers and works. In the operation phase, the main impact is associated with non-ionizing radiation emissions, which are the subject of theoretical and practical reports in order to ensure the safety of the facilities for society, within the limits set by the World Health Organization (WHO). Upon request, the Company also measures the noise level of network facilities.
In Brazil, L. 6,938/1981 and National Council on the Environment (Conama) Resolution No. 237/97 do not consider ERBs as potentially polluting.
Therefore, they are not subject to environmental licensing. TIM, however, understands that in order to fulfill the social function of telecommunication facilities, namely to generate digital inclusion, it is sometimes necessary to install such equipment in areas of biodiversity concern, such as Environmental Protection Areas (EPAs) or Permanent Protection Areas (APPs). In even less frequent cases, vegetation suppression may be required, which occurs only if the installation is to be carried out in an area with dense vegetation, with no possible geographic alternatives.
In such cases, installations are authorized by the government, complying with established legal and technical standards to avoid, mitigate or compensate for resulting environmental impacts.
TIM S.A.'s assets include more than 23,000 ERBs, licensed by Anatel, in line with local regulations, such as zoning and environmental licenses, when applicable.
TIM S.A. recognizes that although the negative impacts of its operation are not significant compared to other production activities that generate effects on the surrounding territory or communities, the installation of facilities in remote areas may cause inconvenience to residents of such areas due to, for example, the visual impact of antennas.
Although this is not a significant impact, TIM invests in the development of innovations such as biosites, with the goal of reducing this type of impact.
The Code of Ethics and Conduct explicitly prohibits direct or indirect disbursements, contributions, benefits or other advantages to political parties or movements and labor unions, or to their representatives or candidates.
TIM Brasil Group companies do not provide, directly or indirectly, contributions, advantages and other benefits to political parties, movements, representatives or candidates and/or trade union organizations, except in cases provided for by law.
| Country | Description of the main activities of the organization | Employees (no.) |
Revenues from sales to third parties (€/000) |
Revenues from intercompany transactions (€/000) |
Profit/loss (€/000) |
Assets (€/000) |
Share capital (€/000) |
Reserves (€/000) |
Income taxes paid (€/000) |
Accrued income taxes (€/000) |
|---|---|---|---|---|---|---|---|---|---|---|
| Argentina | Provision of administrative services, support in the technical management of equipment pertaining to the local network and management of the relationship with local customers for the provision of international telecommunication services. |
7 | 9,437 | - | -1,156 | 8,737 | 3,259 | - | -42 | - |
| Austria | Provision of administrative and support services in the technical management of equipment pertaining to the local area network, for the provision of international telecommunication services. |
1 | - | 1,683 | 87 | 541 | 2,735 | 291 | 56 | 27 |
| Belgium | Provision of administrative and support services in the technical management of equipment pertaining to the local area network, for the provision of international telecommunication services. |
- | - | 1,011 | 89 | 306 | 2,200 | 332 | 23 | 23 |
| Brazil | Landline and mobile phone services. | 9,336 | 2,848,115 | 5,364 | 582,878 | 1,724,646 | 3,322,338 | 1,919,327 | 1,011 | -31,228 |
| The amount shown is determined net of offsetting made against credits for taxes other than income taxes, amounting to €/000 22,964 |
The amount is net of reversal for income taxes set aside in previous years, amounting to €/000 97,867 |
|||||||||
| Bulgaria | Provision of administrative and support services in the technical management of equipment pertaining to the local area network, for the provision of international telecommunication services. |
- | - | 687 | 13 | 1,245 | 51 | 42 | - | 3 |
| Chile | Provision of administrative and support services in the technical management of equipment pertaining to the local area network, for the provision of international telecommunication services. |
1 | 4,613 | - | -1,001 | 6,647 | 9,146 | - | 66 | 66 |
| Colombia | Provision of administrative and support services in the technical management of equipment pertaining to the local area network, for the provision of international telecommunication services. |
- | 21 | 1,639 | 82 | 1,877 | 3,381 | - | -19 | 52 |
| France | Provision of administrative services, support in the technical management of equipment pertaining to the local network and management of the relationship with local customers for the provision of international telecommunication services. |
19 | 785 | 16,878 | 910 | 8,327 | 18,295 | 2,271 | 285 | 250 |
| continued |
| Country | Description of the main activities of the organization | Employees (no.) |
Revenues from sales to third parties (€/000) |
Revenues from intercompany transactions (€/000) |
Profit/loss (€/000) |
Assets (€/000) |
Share capital (€/000) |
Reserves (€/000) |
Income taxes paid (€/000) |
Accrued income taxes (€/000) |
|---|---|---|---|---|---|---|---|---|---|---|
| Germany | Provision of administrative services, support in the technical management of equipment pertaining to the local network and management of the relationship with local customers for the provision of international telecommunication services. |
5 | - | 14,609 | 1,397 | 10,487 | 25,625 | 17,339 | 262 | 585 |
| Greece | Provision of administrative services, support in the technical management of equipment pertaining to the local network and management of the relationship with local customers for the provision of international telecommunication services. |
38 | 8,338 | 6,308 | -1,027 | 28,852 | 369 | 11,227 | 123 | - |
| Israel | Provision of administrative services, support in the technical management of equipment pertaining to the local network and management of the relationship with local customers for the provision of international telecommunication services. |
15 | 21,569 | 3,297 | 2,918 | 3,826 | 1,823 | 22,121 | 1,729 | 1,803 |
| Italy | In Italy, the TIM Group operates in the entire chain of advanced communications services including: fixed, mobile and Internet telecommunications, multimedia and television, Information Technology products and services, and research and development. In addition, coordination functions are exercised by Italy with respect to subsidiaries-direct and indirect-nonresident companies. |
42,347 | 12,153,230 | 3,256,403 | -4,079,691 | 11,355,666 | 11,918,007 | 3,754,636 | 205,003 | 23,485 |
| Luxembourg | Financial activities, and subholding | 13 | - | 85 | 117,027 | 14 | 1,821,028 | 242,212 | 32,355 | 15,428 |
| Malta | Provision of administrative, management and support services; sale of IT solutions. |
- | 230 | - | -157 | 4 | 2 | - | - | - |
| Nigeria | Provision of administrative and support services in the technical management of equipment pertaining to the local area network, for the provision of international telecommunication services. |
- | 423 | - | -59 | 39 | 29 | - | 11 | - |
| Holland | Provision of administrative and support services in the technical management of equipment pertaining to the local area network, for the provision of international telecommunication services. |
- | - | 3,776 | 188 | 4,670 | 18 | 4,636 | 43 | 28 |
| Panama | Provision of administrative services, support in the technical management of equipment pertaining to the local network and management of the relationship with local customers for the provision of international telecommunication services. |
4 | 6,574 | 84 | -261 | 4,466 | 3,820 | -133 | 22 | 25 |
| Country | Description of the main activities of the organization | Employees (no.) |
Revenues from sales to third parties (€/000) |
Revenues from intercompany transactions (€/000) |
Profit/loss (€/000) |
Assets (€/000) |
Share capital (€/000) |
Reserves (€/000) |
Income taxes paid (€/000) |
Accrued income taxes (€/000) |
|---|---|---|---|---|---|---|---|---|---|---|
| Peru | Provision of administrative and support services in the technical management of equipment pertaining to the local area network, for the provision of international telecommunication services. |
- | 3,013 | 1,238 | -722 | 3,390 | 16,175 | - | -106 | 115 |
| Puerto Rico | Provision of administrative and support services in the technical management of equipment pertaining to the local area network, for the provision of international telecommunication services. |
- | 415 | 1,735 | 37 | 4,321 | 2,693 | 260 | 2 | - |
| United Kingdom |
Provision of administrative services, support in the technical management of equipment pertaining to the local network and management of the relationship with local customers for the provision of international telecommunication services. |
10 | 387 | 8,734 | -545 | 9,818 | 11,476 | 4,131 | 8 | 53 |
| Czech Republic |
Provision of administrative and support services in the technical management of equipment pertaining to the local area network, for the provision of international telecommunication services. |
- | 4 | 220 | -0 | 10 | 270 | - | 11 | -0 |
| Republic of San Marino |
Landline and mobile phone services | 40 | 9,633 | 297 | 2,071 | 1,719 | 1,886 | 1,743 | 491 | 303 |
| Romania | Provision of administrative and support services in the technical management of equipment pertaining to the local area network, for the provision of international telecommunication services. |
2 | 150 | 234 | 19 | 30 | 611 | - | 4 | 4 |
| Russia | Provision of administrative services, support in the technical management of equipment pertaining to the local network and management of the relationship with local customers for the provision of international telecommunication services. |
4 | 106 | 369 | 0 | 16 | 100 | 42 | -0 | 0 |
| Singapore | Provision of administrative services, support in the technical management of equipment pertaining to the local network and management of the relationship with local customers for the provision of international telecommunication services. |
12 | 32,778 | 8,663 | -482 | 437 | 4,521 | - | - | - |
| Slovakia | Provision of administrative and support services in the technical management of equipment pertaining to the local area network, for the provision of international telecommunication services. |
- | 10 | 165 | 3 | 6 | 305 | - | - | 8 |
| Country | Description of the main activities of the organization | Employees (no.) |
Revenues from sales to third parties (€/000) |
Revenues from intercompany transactions (€/000) |
Profit/loss (€/000) |
Assets (€/000) |
Share capital (€/000) |
Reserves (€/000) |
Income taxes paid (€/000) |
Accrued income taxes (€/000) |
|---|---|---|---|---|---|---|---|---|---|---|
| Spain | Provision of administrative services, support in the technical management of equipment pertaining to the local network and management of the relationship with local customers for the provision of international telecommunication services. |
4 | - | 1,413 | 74 | 155 | 1,687 | 519 | - | - |
| United States of America |
Provision of administrative services, support in the technical management of equipment pertaining to the local network and management of the relationship with local customers for the provision of international telecommunication services. |
44 | 163,968 | 66,133 | 4,044 | 32,673 | 13,738 | 39,416 | 68 | 132 |
| Switzerland | Provision of administrative and support services in the technical management of equipment pertaining to the local area network, for the provision of international telecommunication services; sale of IT solutions. |
- | 461 | 841 | -158 | 335 | 1,376 | 553 | 2 | 11 |
| Turkey | Provision of administrative services, support in the technical management of equipment pertaining to the local network and management of the relationship with local customers for the provision of international telecommunication services. |
27 | 15,828 | 232 | -1,460 | 12,630 | 15,849 | - | - | - |
| Venezuela | Provision of administrative and support services in the technical management of equipment pertaining to the local area network, for the provision of international telecommunication services. |
- | 322 | - | -747 | - | 419 | - | 36 | - |
| Virgin Island US |
Provision of administrative and support services in the technical management of equipment pertaining to the local area network, for the provision of international telecommunication services. |
- | 7 | 1,392 | 74 | 2,147 | 1 | 5,183 | 1 | - |
Note: The scope of disclosure and data reported refer to "country-by-country" reporting for the fiscal year 2021. Companies residing in Argentina: TI Sparkle Argentina S.A.; companies residing in Austria: TI Sparkle Austria Gmbh; companies residing in Belgium: TI Sparkle Belgium S.P.R.L. - B.V.B.A.; companies residing in Brazil: I-Systems S.A., TI Latam Participacoes e Gestao Administrativa LTD, TI Sparkle Brasil Partecipacoes LTDA, TI Sparkle Brasil Telecomunicacoes LTDA, TIAudit Compliance Latam S.A., TIM Brasil Servicios e Participacoes, TIM S.A.; companies residing in Bulgaria: TI Sparkle Bulgaria EOOD; companies residing in Chile: TI Sparkle Chile SPA; companies residing in Colombia: TI Sparkle Colombia LTDA; companies residing in France: Noovle France SASU, TI Sparkle France SAS; companies residing in Germany: Olivetti Deutschland Gmbh, TI Sparkle Germany Gmbh; companies residing in Greece: TI Sparkle Greece S.A.; companies residing in Israel: MED 1 Submarine Cables LTD, TI Sparkle Israel LTD; companies residing in Italy: Telecom Italia S.p.A. (also TIM S.p.A.), CD Fiber S.r.l., Daphne 3 S.p.A., Fibercop S.p.A., Global Space Tre S.r.l., Noovle AI S.r.l, Noovle S.p.A. benefit company, Noovle Sicilia - società consortile a r.l., Olivetti Payment Solutions S.p.A., Olivetti S.p.A. benefit company, Staer Sistemi S.r.l, Telecom Italia Sparkle S.p.A., Telecom Italia Trust Technologies S.r.l., Telecom Italia Ventures S.r.l., Telecontact Center S.p.A., Telenergia S.r.l., Telsy Elettronica e Telecomunicazioni S.p.A., Tiesse S.C.P.A., TIM My Broker S.r.l., TIM Retail S.r.l., TIM Servizi Digitali S.p.A.; companies residing in Luxembourg: Telecom Italia Capital S.A., Telecom Italia Finance S.A.; companies residing in Malta: Noovle Malta LTD; resident companies in Nigeria: TIS Lagos Limited; companies resident in the Netherlands: TI Sparkle Netherlands B.V.; companies residing in Panama: Panama Digital Gateway S.A., TI Sparkle Panama S.A.; companies residing in Peru: TI Sparkle Peru S.A.; companies residing in Puerto Rico: TI Sparkle Puerto Rico LLC; companies residing in the United Kingdom: Olivetti UK LTD, TI Sparkle UK LTD; companies residing in Romania: TI Sparkle Romania SRL; companies residing in Russia: TI Sparkle Russia LLC; companies residing in the Czech Republic: TI Sparkle Czech S.R.O.; companies residing in the Republic of San Marino: Telecom Italia San Marino S.p.A., Telefonia Mobile Sammarinese S.p.A.; companies residing in Singapore: TI Sparkle Singapore PTE/LTD; companies residing in Slovakia: Noovle Slovakia S.R.O., TI Sparkle Slovakia S.R.O.; companies residing in Spain: TI Sparkle Spain Telecommunications S.L.; companies residing in the United States of America: TI Sparkle Americas Inc, TI Sparkle North America Inc; companies residing in Switzerland: Noovle International SAGL, TI Sparkle Switzerland Gmbh; companies residing in Turkey: TI Sparkle Turkey Telekomunikasyon Hizmetleri Anonim Sirketi; companies residing in Venezuela: TI Sparkle Venezuela C.A.; companies residing in Virgin Island US: TI Sparkle St. Croix LLC.
Number of pending or concluded legal actions for BU Domestic
| 2022 | 2021 | 2020 | |
|---|---|---|---|
| Anti-competitive behavior | 2 | 2 | 1 |
| Violations of antitrust and monopolistic practice regulations |
1 | 1 | 1 |
For more information on litigation, please refer to Note 24 "Pending litigation and court actions, other information, commitments and guarantees" of the Annual Financial Report available at the following link:
https://www.gruppotim.it/en/investors/reports-presentations/financial-reports.html.
| 2022 | |
|---|---|
| Anti-competitive behavior | 0 |
| Violations of antitrust and monopolistic practice regulations | 0 |
[GRI 206-1b] With reference to anticompetitive behavior for BU Domestic, actions are still pending in the first instance. With regard to violations of antitrust and monopolistic practice regulations, the verdict in 2021 was favorable for TIM and is continuing in the second instance.
In BU Brazil, no new proceedings were included in 2022. The 12 proceedings identified in 2021 are reported, with updates on their progress.
| Scope Legislative Decree 254/2016 | Material Topic 2022 |
|---|---|
| CIRCULAR ECONOMY AND WASTE PRODUCTION | |
| CLIMATE CHANGE | |
| Environment | ENERGY TRANSITION |
| SUSTAINABLE SUPPLY CHAIN | |
| CUSTOMER INTERACTION AND SERVICE TRANSPARENCY | |
| DIGITAL INCLUSION | |
| RESILIENCE TO PHYSICAL, PUBLIC HEALTH, AND SOCIOPOLITICAL RISKS | |
| CYBERBULLYING, CHILD PORNOGRAPHY, ONLINE GAMBLING | |
| Social | COMMUNITY AND STAKEHOLDER RELATIONS |
| PRIVACY AND CYBERSECURITY | |
| INFRASTRUCTURES AND EMERGING TECHNOLOGIES | |
| LEGAL AND REGULATORY CONTEXT MANAGEMENT | |
| DEVELOPMENT AND MOTIVATION OF TIM EMPLOYEES | |
| Staff | EMPLOYEE HEALTH AND SAFETY |
| EQUAL PAY AND OPPORTUNITY | |
| Respect for human rights | HUMAN RIGHTS DEFENSE |
| Fighting Corruption | Scope reported even if not included in the 16 material topics 2022* |
* The 2021 material topic "Ethics and Corporate Governance" since it is not representative of a major impact generated by the Group externally is not considered as an impact topic for the 2022 Report. Combating Corruption will still be regularly reported according to GRI indicator 205 (Anti-corruption).
| GRI Standard | Disclosure | Page | Omissions and description |
|---|---|---|---|
| Statement of Use | TIM S.p.A. has reported with the GRI Standards for the period from January 1 to December 31, 2022 |
||
| GRI 1 USED | GRI 1: Foundation 2021 | ||
| GRI Sectors standard applied | N.A. | ||
| General Disclosure | |||
| GRI 2: General Disclosure | |||
| GRI 2-1: Organizational details | 88 | ||
| GRI 2-2: Entities included in the organization's sustainability reporting | 88 | ||
| GRI 2-3: Reporting period, frequency and contact point | 89 | ||
| GRI 2-4: Restatements of information | 89 | ||
| GRI 2-5: External assurance | 89 | ||
| GRI 2-6: Activities, value chain and other business relationships | 91 | ||
| GRI 2-7: Employees | 93 | ||
| GRI 2-8: Workers who are not employees | data At present, required by GRI 2-8 available, due are not complexity in data to collection process. The Group is TIM committed in the coming initiate years to a process of data collection and reporting, starting with the significant categories most of non-employee workers (e.g., call and centers |
continued
network enterprises).
| GRI Standard | Disclosure | Page | Omissions and description |
|---|---|---|---|
| GRI 2-9: Governance structure and composition | 94 | ||
| GRI 2-10: Nomination and selection of the highest governance body | 96 | ||
| GRI 2-11: Chair of the highest governance body | 97 | ||
| GRI 2-12: Role of the highest governance body in overseeing the management of impacts | 97 | ||
| GRI 2-13: Delegation of responsibility for managing impacts | 98 | ||
| GRI 2-14: Role of the highest governance body in sustainability reporting | 99 | ||
| GRI 2-15: Conflicts of interest | 99 | ||
| GRI 2-16: Communication of critical concerns | 99 | ||
| GRI 2-17: Collective knowledge of the highest governance body | 100 | ||
| GRI 2-18: Evaluation of the performance of the highest governance body | 100 | ||
| GRI 2-19: Remuneration policies | 101 | ||
| GRI 2-20: Process to determine remuneration | 103 | ||
| GRI 2-21: Annual total compensation ratio | shown for Data not confidentiality reasons |
||
| GRI 2-22: Statement on sustainable development strategy | 2 | ||
| GRI 2-23: Policy commitments | 104 | ||
| GRI 2-24: Embedding policy commitments | 111 | ||
| GRI 2-25: Processes to remediate negative impacts | 116 | ||
| GRI 2-26: Mechanisms for seeking advice and raising concerns | 117 | ||
| GRI 2-27: Compliance with laws and regulations | 118 | ||
| GRI 2-28: Membership associations | 121 | ||
| GRI 2-29: Approach to stakeholder engagement | 122 | ||
| GRI 2-30: Collective bargaining agreements | 125 | ||
| Material Topics | |||
| GRI 3: Material Topics | |||
| GRI 3-1: Process to determine material topics | 127 | ||
| GRI 3-2: List of material topics | 128 |
| GRI Standard | Disclosure | Page | Omissions and description |
|---|---|---|---|
| GRI 3: Privacy and cybersecurity | |||
| GRI 3-3: Privacy and cybersecurity | 129 | ||
| GRI 3: Digital inclusion | |||
| GRI 3-3: Digital inclusion | 134 | ||
| GRI 3: Infrastructures and emerging technologies | |||
| GRI 3-3: Infrastructures and emerging technologies | 139 | ||
| GRI 3: Customer interaction and service transparency |
|||
| GRI 3-3: Customer interaction and service transparency | 143 | ||
| GRI 3: Employee health and safety | |||
| GRI 3-3: Employee health and safety | 150 | ||
| GRI 3: Development and motivation of TIM employees |
|||
| GRI 3-3: Development and motivation of TIM employees | 154 | ||
| GRI 3: Climate change | |||
| GRI 3-3: Climate change | 159 | ||
| GRI 3: Energy transition | |||
| GRI 3-3: Energy transition | 164 | ||
| GRI 3: Legal and regulatory context management |
|||
| GRI 3-3: Management of the legal and regulatory environment | 167 | ||
| GRI 3: Equal pay and opportunity | |||
| GRI 3-3: Equal pay and opportunity | 173 | ||
| GRI 3: Community and stakeholder relations | |||
| GRI 3-3: Community and stakeholder relations | 178 | ||
| GRI Standard | Disclosure | Page | Omissions and description |
|---|---|---|---|
| GRI 3: Resilience to physical, public health, and sociopolitical risks |
|||
| GRI 3-3: Resilience to physical, public health, and sociopolitical risks | 184 | ||
| GRI 3: Sustainable supply chain | |||
| GRI 3-3: Sustainable supply chain | 188 | ||
| GRI 3: Human rights defense | |||
| GRI 3-3: Defense of human rights | 192 | ||
| GRI 3: Cyberbullying, child pornography, online gambling |
|||
| GRI 3-3: Cyberbullying, child pornography, online gambling | 196 | ||
| GRI 3: Circular economy and waste production | |||
| GRI 3-3: Circular economy and waste production | 201 | ||
| ENVIRONMENT/EMPLOYEES | |||
| Economic Performance | |||
| GRI 201: Economic Performance | |||
| GRI 201-1: Direct economic value generated and distributed | 272 | ||
| GRI 201-2: Financial implications and other risks and opportunities due to climate change | 213 | ||
| GRI 201-3: Defined benefit plan obligations and other retirement plans and opportunities | 232 | ||
| CIVIL SOCIETY | |||
| Indirect Economic Impacts | |||
| GRI 203: Indirect Economic Impacts | |||
| GRI 203-2: Significant indirect economic impacts | 272 | ||
| SUPPLIERS | |||
| Procurement Practices | |||
| GRI 204: Procurement Practices | |||
| GRI 204-1: Proportion of spending on local suppliers | 258 |
| GRI Standard | Disclosure | Page | Omissions and description |
|---|---|---|---|
| CIVIL SOCIETY | |||
| Anti-corruption | |||
| GRI 205: Anti-corruption | |||
| GRI 205-1: Operations assessed for risks related to corruption | 274 | ||
| GRI 205-2: Communication and training about anti-corruption policies and procedures | 278 | ||
| GRI 205-3: Confirmed incidents of corruption and actions taken | 279 | ||
| INDUSTRY BUSINESS COMMUNITY | |||
| Anti-competitive Behavior | |||
| GRI 206: Anti-competitive Behavior | |||
| GRI 206-1: Legal actions for anti-competitive behavior, anti-trust, and monopoly practices | 289 | ||
| CIVIL SOCIETY | |||
| Tax | |||
| GRI 207: Tax | |||
| GRI 207-1: Approach to tax | 280 | ||
| GRI 207-2: Tax governance, control, and risk management | 280 | ||
| GRI 207-3: Stakeholder engagement and management of concerns related to tax | 282 | ||
| GRI 207-4: Country by country reporting | 283 | ||
| ENVIRONMENT | |||
| Energy | |||
| GRI 302: Energy | |||
| GRI 302-1: Energy consumption within the organization | 214 | ||
| GRI 302-2: Energy consumption outside of the organization | 217 | data At present, are partially available as described within the text |
|
| GRI 302-3: Energy intensity | 217 | ||
| GRI Standard | Disclosure | Page | Omissions and description |
|---|---|---|---|
| Emissions | |||
| GRI 305: Emissions | |||
| GRI 305-1: Direct (Scope 1) GHG emissions | 218 | ||
| GRI 305-2: Energy indirect (Scope 2) GHG emissions | 219 | ||
| GRI 305-3: Other indirect (Scope 3) GHG emissions | 221 | related Category Data to consider only 11 BU Domestic performances' |
|
| GRI 305-4: GHG emissions intensity | 222 | ||
| GRI 305-5: Reduction of GHG emissions | 223 | ||
| Waste | |||
| GRI 306: Waste | |||
| GRI 306-1: Waste generation and significant waste-related impacts | 223 | ||
| GRI 306-2: Management of significant waste-related impacts | 223 | ||
| GRI 306-3: Waste generated | 224 | ||
| GRI 306-4: Waste diverted from disposal | 225 | ||
| GRI 306-5: Waste directed to disposal | 226 | ||
| Supplier Environmental Assessment | |||
| GRI 308: Supplier Environmental Assessment | |||
| GRI 308-1: New suppliers that were screened using environmental criteria | 258 | ||
| GRI 308-2: Negative environmental impacts in the supply chain and actions taken | 259 | ||
| EMPLOYEES | |||
| Employment | |||
| GRI 401: Employment | |||
| GRI 401-1: New employee hires and employee turnover | 233 | ||
| GRI 401-2: Benefits provided to full-time employees that are not provided to temporary or part-time employees |
234 | ||
| GRI 401-3: Parental leave | 235 |
| GRI Standard | Disclosure | Page | Omissions and description |
|---|---|---|---|
| Labor/Management Relations | |||
| GRI 402: Labor/Management Relations | |||
| GRI 402-1: Minimum notice periods regarding operational changes | 236 | ||
| Occupational Health and Safety | |||
| GRI 403: Occupational Health and Safety | |||
| GRI 403-1: Occupational health and safety management system | 237 | ||
| GRI 403-2: Hazard identification, risk assessment and incident investigation | 238 | ||
| GRI 403-3: Occupational health services | 240 | ||
| GRI 403-4: Worker participation, consultation and communication on occupational health and safety |
241 | ||
| GRI 403-5: Worker training on occupational health and safety | 242 | ||
| GRI 403-6: Promotion of worker health | 243 | ||
| GRI 403-7: Prevention and mitigation of occupational health and safety impacts directly linked by business relationships |
244 | ||
| GRI 403-8: Workers covered by an occupational health and safety management system | 245 | ||
| GRI 403-9: Work-related injuries | 246 | ||
| GRI 403-10: Work-related ill health | 248 | ||
| GRI 403-1/10 (workers who are not employees) | data related At present, workers that to are employees not are available, due not to complexity in data collection process. The TIM Group is committed in the coming initiate years to a process of data collection and reporting, starting with the significant categories most of non-employee workers (e.g., call and centers network enterprises). |
| GRI Standard | Disclosure | Page | Omissions and description |
|---|---|---|---|
| Training and Education | |||
| GRI 404: Training and Education | |||
| GRI 404-1: Average hours of training per year per employee | 249 | ||
| GRI 404-2: Programs for upgrading employee skills and transition assistance programs | 249 | ||
| GRI 404-3: Percentage of employees receiving regular performance and career development reviews |
251 | ||
| Diversity and Equal Opportunity | |||
| GRI 405: Diversity and Equal Opportunity | |||
| GRI 405-1: Diversity of governance bodies and employees | 252 | ||
| GRI 405-2: Ratio of basic salary and remuneration of women to men | 254 | ||
| HUMAN RIGHTS - DISCRIMINATION | |||
| Non-discrimination | |||
| GRI 406: Non-discrimination | |||
| GRI 406-1: Incidents of discrimination and corrective actions taken | 228 | ||
| EMPLOYEES/SUPPLIERS | |||
| Freedom of Association and Collective Bargaining |
|||
| GRI 407: Freedom of Association and Collective Bargaining |
|||
| GRI 407-1: Operations and suppliers in which the right to freedom of association and collective bargaining may be at risk |
260 | ||
| Child Labor | |||
| GRI 408: Child Labor | |||
| GRI 408-1: Operations and suppliers at significant risk for incidents of child labor | 261 | ||
| Forced or Compulsory Labor | |||
| GRI 409: Forced or Compulsory Labor | |||
| GRI 409-1: Operations and suppliers at significant risk for incidents of forced or compulsory labor |
261 |
| GRI Standard | Disclosure | Page | Omissions and description |
|---|---|---|---|
| Local Communities | |||
| GRI 413: Local Communities | |||
| GRI 413-2: Operations with significant actual and potential negative impacts on local communities |
283 | ||
| SUPPLIERS | |||
| Supplier Social Assessment | |||
| GRI 414: Supplier Social Assessment | |||
| GRI 414-1: New suppliers that were screened using social criteria | 258 | ||
| GRI 414-2: Negative social impacts in the supply chain and actions taken | 259 | ||
| CIVIL SOCIETY | |||
| Public Policy | |||
| GRI 415: Public Policy | |||
| GRI 415-1: Political contributions | 284 | ||
| CUSTOMERS | |||
| Customer Health and Safety | |||
| GRI 416: Customer Health and Safety | |||
| GRI 416-1: Assessment of the health and safety impacts of product and service categories | 264 | ||
| GRI 416-2: Incidents of non-compliance concerning the health and safety impacts of products and services |
265 | ||
| Marketing and Labeling | |||
| GRI 417: Marketing and Labeling | |||
| GRI 417-1: Requirements for product and service information and labeling | 266 | ||
| GRI 417-2: Incidents of non-compliance concerning product and service information and labeling | 268 | ||
| GRI 417-3: Incidents of non-compliance concerning marketing communications | 269 | ||
| Customer Privacy | |||
| GRI 418: Customer Privacy | |||
| GRI 418-1: Substantiated complaints concerning breaches of customer privacy and losses of customer data |
270 |
(Pursuant to Regulation 2020/852 of June 20, 2020 and Delegated Regulation 2021/2178 of July 6, 2021)
| The European Taxonomy | Calculation and reporting of economic KPIs |
|---|---|
| TIM Group's position | Turnover |
| How the TIM Group has implemented the European Taxonomy | CapEx |
| The perimeter of eligibility | CapEx type C |
| Climate change mitigation goal | OpEx |
| Activity 8.1 Data processing, hosting and related activities | Regulatory and contextual developments |
| Activity 8.2 Data-driven solutions for GHG emissions reductions | |
| of greenhouse gases | |
| Climate change adaptation goal | |
| Activity 8.3 Programming and broadcasting activities | |
| Activities outside the scope of eligibility | |
| The alignment perimeter | |
| Substantial contribution to change mitigation goal | |
| climate | |
| Analysis of substantial contribution for activity 8.1 | |
| Analysis of substantial contribution for activity 8.2 | |
| Substantial contribution to the goal of change adaptation | |
| climate | |
| Analysis of substantial contribution for activity 8.3 | |
| Verification of Do No Significant Harm (DNSH) Principles | |
| Adaptation to climate change | |
| Sustainable use and protection of water and marine resources | |
| Transition to a circular economy | |
| Minimum safeguards |
The European Taxonomy (EU 2020/852) is a classification system introduced as part of the European Green Deal as an enabling tool to achieve the environmental and climate goals set out in the Pact, particularly decarbonization by 2050. Through precise indications about economic activities that can be classified as eco-sustainable (provided through specific Delegated Acts), the Regulation aims to address the issue of transparency for investors, counter the phenomenon of so-called "greenwashing," while supporting corporate organizations in the process of energy transition and adoption of sustainable environmental policies. The European Taxonomy defines six environmental goals, of which the first two have been regulated to date: climate change mitigation and climate change adaptation. From a regulatory perspective, the Regulation introduces a new disclosure requirement aimed at large public interest entities that already prepare a Non-Financial Statement (NFS) in compliance with the application of Legislative Decree 254/2016.
The TIM Group has welcomed the introduction of the European Taxonomy, viewing the new regulatory framework as premises of a tool that can offer the investing world and all stakeholders a common and comparable benchmark. In addition to having immediately initiated all the necessary actions to adapt its reporting systems to the requirements of the new Regulations, the TIM Group actively participates in consultation processes, providing input through the industry associations in which the Group participates(1).
Based on the guidance contained in the Delegated Act on Climate Change Goals (published in its definite version in June 2021), a two-stage process was developed through which the applicability of the Taxonomy was first assessed through the analysis of the Group's entire business model and, subsequently, the reporting operations of potentially eligible activities were initiated. In view of the steps in the Regulation's implementation roadmap, the focus of the process in 2021 had been exclusively on climate change mitigation and adaptation objectives, considered under the eligibility criterion alone. At the close of the fiscal year, the TIM Group has in parallel begun the study of the process integrations necessary to meet the disclosure requirements envisaged as of fiscal year 2022, which require the application and verification of technical screening criteria for each of the eligible assets surveyed (alignment to Taxonomy).
(1) Among the most significant industry references The European Telecommunications Network Operators' Association - ETNO.
The alignment verification process was carried out by the TIM Group consistent with the provisions of the Taxonomy regulations, taking into consideration compliance with the following key requirements for each activity:
Subsequently, the three economic indicators required by the Regulation, representing the shares of revenues (Turnover), investments (CapEx) and operating expenses (OpEx) associated with economic activities considered ecosustainable were calculated.
It should be noted that the enactment and application of the technical screening criteria may result in possible changes on the perimeter of activities potentially aligned to the Taxonomy with a consequent downsizing of the associated performance indicators. For more details on how to report, see the section "Methodology for Calculating KPIs."
Finally, taking into account the recent application of the Regulation and the technical complexity posed by the requirements, the TIM Group's approach in identifying eligible and aligned activities has been guided by strict adherence to the guidelines of the Regulation, resulting in the exclusion of projects not included within the Delegated Acts of the Regulation.
An economic activity is eligible under the European Taxonomy if there is a corresponding description within the Delegated Acts, regardless of whether or not that activity meets the technical screening criteria reported within the latter. In order to determine which activities of the TIM Group can be traced back to those identified by the Taxonomy, the main business activities were mapped and analyzed, with a focus on commercial offerings and investment projects. As indicated by the Regulation, in carrying out this exercise, the TIM Group has taken into consideration the climate objectives it intends to pursue from the identified economic activities. In particular, this criterion has significant value for activities such as 8.1 (Data processing, hosting and related activities) which, having the same objective of the two regulated acts, can contribute to both targets.
Among the activities identified by the TIM Group, there are both economic activities eligible for the mitigation goal and the climate change adaptation goal, as shown in the table below:
| Economic activities |
Description | Objective |
|---|---|---|
| 8.1 Data processing, hosting and related activities |
Storage, manipulation, management, movement, control, display, switching, interchange, transmission or reception of a diversity of data across data centers, including edge computing. |
Mitigation |
| 8.2 Data-driven solutions for GHG emissions reductions |
Development or use of ICT solutions that are aimed at collecting, transmitting, storing data and at its modelling and use where those activities are predominantly aimed at the provision of data and analytics enabling GHG emission reductions. Such ICT solutions may include, inter alia, the use of decentralized technologies (i.e. distributed ledger technologies), Internet of Things (IoT), 5G and Artificial Intelligence. |
Mitigation |
| 8.3 Programming and broadcasting activities |
Programming and broadcasting activities include creating content or acquiring the right to distribute content and subsequently broadcasting that content, such as radio, television and data programs of entertainment, news, talk, and the like, including data broadcasting, typically integrated with radio or TV broadcasting. The broadcasting can be performed using different technologies, over-the-air, via satellite, via a cable network or via Internet. This also includes the production of programs that are typically narrowcast in nature (limited format, such as news, sports, education, and youth-oriented programming) on a subscription or fee basis, to a third party, for subsequent broadcasting to the public. |
Adaptation |
Economic activities not shown in the table above:
4.1 (Electricity generation by solar photovoltaic technology)
(mitigation/adaptation), that is, those activities involving the construction or operation of facilities in order to produce electricity using solar photovoltaic technology;
7.2 (Renovation of Existing Buildings) (mitigation and adaptation), which is the renovation of building and civil engineering works.
As can be seen from the descriptions provided in the Taxonomy, both economic activities cannot be considered core to the TIM Group's business. As a result, with the aim of taking the most precautionary approach, the TIM Group has considered proceeding with the detailed and in-depth analysis of core-business activities only. For more details, see the section "Type C CapEx" in this chapter.
Since Activity 8.1(Data processing, hosting, and related activities) has the same description for both climate objectives, unlike for FY 2021, the TIM Group decided to carry out the analyses related only to the climate change mitigation objective, believing the nature of its activities to be more related to this objective and in order to avoid the risk of double-counting.
Included within this category are activities performed by data centers owned by the TIM Group, mainly related to housing and hosting services of IT facilities for storage and processing. This activity can be carried out through the following ways:
• The use of devices and infrastructure owned by the TIM Group;
Despite the different service delivery configurations, the activity is fully eligible under the Taxonomy.
However, a part of the TIM Group's Data Center is used only to carry out internal activities functional to the organization. This portion does not comply with the Regulation, thus being excluded from the eligibility scope of the Taxonomy.
Included within this category were IT solutions and services offered by TIM with the potential to reduce the impact of CO2 emissions to the atmosphere. In particular, given the number and variety of existing offerings, the TIM Group has adopted an analytical and granular approach, which has enabled it to analyze each individual service capable of providing significant benefit to its customers. Offerings include mainly smart services in domains such as mobility, home automation, public administration, and agriculture, based on IoT solutions that enable intelligent data management for automated and monitoring activities that contribute to the well-being of Society and the environment.
Also included were services that support the digitization and automation of an organization's operational activities, which are critical to reducing GHG emissions,
by managing information systems and data processing activities through IoT and Cloud solutions. These offerings are closely related to the implementation of software and communication technologies for efficient data management. Primarily, these are Private, Hybrid and Multi Cloud IaaS (Infrastructure as a Service) Cloud computing solutions, delivered on TIM, Google and other hyperscaler computational platforms, which are associated with the delivery of professional and managed services in support of businesses. Other offerings such as "Trusted services," on the other hand, consist of solutions for issuing digital certificates, invoicing, certified e-mail services, again delivered in the Cloud.
Ultimately, the integration and management of information flows through IoT solutions enables the digital transformation of services addressed to different sectors such as urban, industrial and healthcare.
According to what has been shared and approved in the technical working tables of the TELCO sector (such as ETNO), all activities suitable for the development of infrastructures for the delivery of ICT services (services on fixed network, mobile, 4G / 5G) will not be included in the perimeter of eligibility, although they represent a preponderant part of the business activities carried out by the TIM Group capable of delivering benefits in the process of digitization of telecommunications networks and, ultimately, mitigating the effects of climate change.
Included within this category are services and offerings related to content production and broadcasting activities carried out by the TIM Group through the TIMVision marketing solution. With this activity, the TIM Group is able to provide program schedules composed of its own and/or purchased third-party content, playing a potential role in disseminating and raising awareness with respect to the issues of climate change and its consequences.
Specifically, the TIM Group offers various packages that include for the viewer movies, TV series, cartoons, general entertainment, which, depending on the offer selected, may belong in different proportions both to TIM's own catalog and to the catalog of third-party operators.
According to the mapping and analysis of the activities carried out by the TIM Group, a portion is ineligible under the Taxonomy because it is not included within the Climate Act.
Specifically, the following activities are excluded:
• ICT service delivery infrastructure development services, which, as anticipated, are excluded from the scope of eligibility despite the fact that they are a key factor in the digital transition and the consequent reduction of GHG emissions impact;
However, it is important to note that the current scope of eligibility may change over time, in accordance with regulatory developments and the publications of Delegated Acts on the remaining four environmental objectives of the Taxonomy, which are currently still being finalized. The telecommunications sector, in fact, still sees itself partially represented by the current Regulations, and it is not ruled out that there may be additions that can further enhance the key role this sector can play within a path to the achievement of the six environmental goals. See the section "Regulatory and Contextual Developments" in this chapter for further considerations.
An economic activity is defined as aligned with the European Taxonomy when it contributes substantially to one of the six environmental objectives, does no significant harm to the other five objectives, and meets minimum safeguards. The TIM Group carried out the necessary investigations and analyses to verify compliance with the technical screening criteria established by the Regulation for each of the eligible economic activities identified for the first two environmental objectives.
As much as the organization intends to align its 8.1 activities with the climate change mitigation goal, for this first year of reporting it was unable to demonstrate compliance with this substantial contribution.
Within the perimeter of alignment analysis, it was decided to consider all Data Centers suitable for the performance of housing and hosting services, where the TIM Group has direct control over the provision of the service without the intermediation of third parties, and/or to services provided through subcontracting contracts, where the TIM Group acts as an "agent" commissioning the activity and not as a "principal."
Part of the Data Centers considered comply with the first requirement of substantial contribution, in line with the best management practices defined by the European Data Center Code of Conduct on Energy Efficiency. This code consists of a reference document for Data Center operators that identifies and collects a set of possible implementation measures to improve the energy efficiency of facilities. Precisely in order to ensure the standards subscribed to in the code of conduct, the TIM Group is required to submit an annual report detailing its progress in streamlining its technology infrastructure. Although this report is evaluated by a committee to determine the enrollment of Data Centers in the code of conduct, the implementation of the practices is currently not independently verified by an independent third party, as required by the substantial climate change mitigation contribution.
In addition, the TIM Group uses to date in its Data Centers different types of refrigerant gas having a global warming potential (abbreviated GWP, from Global Warming Potential) on average higher than the threshold established in the Taxonomy Delegated Regulation, defined for the purpose of limiting the use of potentially more impactful technologies in the event of any leakage into the atmosphere.
That said, a gradual process of replacing refrigerant gases having a very high GWP has been underway for several years in order to make Data Center cooling systems more efficient. What the Regulation requires further incentivizes the rapid implementation of this replacement process.
According to the requirements of the substantial contribution criterion, the technology under analysis must have the goal of substantially reducing GHG emissions and must represent the best alternative available on the market. In addition, the reduction in GHG emissions must be certified by an independent third party. Although at present it has not been possible to quantify and certify the reduction in emissions compared to the best market alternatives and thus demonstrate compliance with the substantial contribution, the TIM Group is considering developing the "Carbon-calculator" project internally.
The requirements of the Substantial Contribution to Climate Change Adaptation request that a robust climate risk and vulnerability assessment has been carried out, taking into consideration the physical climate risks outlined in Appendix A of Delegated Regulation 2021/2139(2). As a result, the expectation is that economic activity has implemented adaptation solutions that can substantially reduce the identified physical climate risks.
The TIM Group has integrated a plan for risk management (Enterprise Risk Management) and, with the aim of achieving its goals with respect to climate change, starting in 2021 it began to structure a climate risk assessment following the recommendations of the TCFD(3) Framework with a particular focus on reducing CO2 emissions.
Physical risks identified based on those listed in Appendix A of Delegated Regulation 2021/2139 were considered in the assessment. Two scenarios(4) from those proposed by NGFS (Network for Greening the Financial System) were evaluated to set up the impact analysis of these risks (mainly hydrogeological risks). To limit potential damage, the TIM Group has adopted prevention and protection systems for its assets, as well as subscribing to an insurance program.
For the purposes of meeting the requirement of the Taxonomy, the analyses carried out for the development of the TIM Group's climate risk assessment reflect the characteristics required by Annex II of the Delegated Act, so the substantial contribution can be considered fulfilled.
In addition, the TIM Group is working steadily with the aim of integrating the methodology used to assess climate risks and related adaptation solutions, confirming the ambition of its climate strategy and targets set to actively contribute to the fight against climate change.
(2) Delegated Regulation 2021/2139 is a document supplementing Regulation (EU) 2020/852 that sets the technical screening criteria for determining the alignment of an activity.
(3) Task Force on Climate-Related Financial Disclosures.
(4) Orderly (Net Z ero); Disorderly (Divergent Net Zero); Hot House World (Current Policies).
There is a fifth verification point for Activity 8.3 (Programming and Transmission Activities), which can be considered an enabler under Art. 11(1)(b) of Regulation (EU) 2020/852, if it meets a specific criterion for substantial contribution that, through a climate risk assessment, the technology, service or product served is assumed to promote:
To verify this requirement, the TIM Group looked at the TIM Group's proprietary program schedule catalog, which contains the list of programs directly selected by the TIM Group, with the aim of identifying the amount of broadcasts meeting the climate change awareness requirement. With regard to content owned by thirdparty operators, which is the subject of re-broadcasting activities, the analyses aimed at verifying the requirement have not been conducted because the TIM Group does not exercise any choice over the type of content to be broadcast nor does it possess any visibility rights over the titles aired.
According to the findings of the analysis, it was possible to identify a share of programs dealing with issues related to climate change, particularly within educational broadcasts, aimed at a juvenile audience, and the documentary genre. For the purposes of the Taxonomy, it is therefore possible to consider the portion of revenues and investments related to these programs as aligned. However, the portion of Turnover and CapEx associated with them, and reportable for the purposes of the alignment exercise, has little material impact compared to the totality of economic values generated by the Group's business. Therefore, the TIM Group for this year considered it more appropriate and precautionary not to value this alignment percentage. For more details on the calculation methodology adopted, see the section "Calculation and reporting of economic KPIs."
Despite the fact that for this first year of reporting only one activity is found to positively meet the substantial contribution requirements related to the first two environmental objectives, the TIM Group has nevertheless carried out the necessary analyses in relation to compliance with the "Do No Significant Harm" principles which require that the activities under analysis do not cause significant harm to the remaining environmental objectives (Climate Change Mitigation, Climate Change Adaptation, Sustainable Use of Water and Protection of Marine Resources, Transition to a Circular Economy, Pollution Prevention and Reduction, and Protection and Restoration of Biodiversity and Ecosystems). For TIM Group activities, the DNSH criteria verifications provided are as follows:
| Economic activities | Climate change mitigation |
Adaptation to climate change |
Sustainable water use and protection of marine resources |
Transition to a circular economy |
Prevention and reduction of pollution |
Protection and restoration of biodiversity and ecosystems |
|---|---|---|---|---|---|---|
| Climate change mitigation goal | ||||||
| 8.1 Data processing, hosting and related activities |
N/A | Applicable | Applicable | Applicable | N/A | N/A |
| 8.2 Data-driven solutions for GHG emissions reductions |
N/A | Applicable | N/A | Applicable | N/A | N/A |
| Climate change adaptation goal | ||||||
| 8.3 Programming and broadcasting activities |
N/A | N/A | N/A | N/A | N/A | N/A |
To check the compliance of activities with the requirements, audits were conducted at the Group level and then proceeded with in-depth investigations at the business unit or individual activity level.
The following paragraphs detail the analyses carried out according to the above scheme.
The DNSH criterion regarding climate change adaptation applies to activities with climate change mitigation as their primary objective. Specifically, for both mitigation activities 8.1 (Data processing, hosting, and related activities) and 8.2 (Data-driven solutions for GHG emission reduction), the requirement includes compliance with Appendix A of the Delegated Regulation, in which a robust climate risk and vulnerability assessment and an assessment of adaptation solutions is required. The criteria of this DNSH, which almost completely mirror the requirements of the substantive contribution of this goal, can be considered outdated. For more details, please refer to the section "Substantial contribution to the climate change adaptation goal" in this chapter.
The requirements of this DNSH apply to activity 8.1 (Data processing, hosting,
and related activities), and are set out in Appendix B of the Delegated Climate Regulation, which requires that a water use and protection management plan has been implemented and, where applicable, that an environmental impact assessment (EIA) has been carried out in accordance with Directive 2011/92/ EU. The TIM Group has an ISO 14001-certified environmental management system for its data centers. As for EIA, this is a procedure regulated by Article 19 of Legislative Decree 152/2006, which, in listing the various types of projects for which environmental impact assessment is required, does not mention the activity of Data Centers. However, thermal power plants for electricity, steam and hot water production with a total thermal power output exceeding 150 MW are present. Since this threshold is not exceeded in the TIM Group Data Centers, the DNSH related to sustainable use and protection of water and marine resources is considered satisfied.
For mitigation activities 8.1 (Data processing, hosting and related activities) and 8.2 (Data-driven solutions for GHG emissions reductions), DNSH related to the transition to a circular economy has several requirements.
Eco-friendly design and energy-saving aspects required by Directive 2009/125/EC are verified by the TIM Group when purchasing electronic equipment for which compliance with specific energy efficiency standards is required, such as: the application of Power Management technology and the compliance of systems with international energy efficiency standards 80Plus Titanium and ETSI EN 300 019 -2-3 V2.4.1 Specification T3.1E.
As far as waste management is concerned, The TIM Group has in place a procedure that regulates its proper management and, in addition, has entered into targeted contracts with companies specializing in the management of used, broken down and end-of-life products, with the aim of enabling the recovery of components and raw materials, while obtaining tangible economic benefits from their valorization.
This DNSH criterion also requires that no substances, either in their pure state or within mixtures or articles, listed in Annex II of Directive 2011/65/EU be used. Substances in this annex include lead, cadmium and mercury, which are present in the batteries installed at all Fixed Network locations in Italy. In addition, mercury is found within the power systems of certain equipment.
In addition, in the purchasing processes of devices used by the TIM Group, while submitting specific sustainability requirements to potential suppliers, no specifications are reported regarding the substances within the electronic equipment.
According to DNSH's latest requirement, at the end of its life cycle, equipment must be subjected to preparation for reuse, recovery or recycling, or appropriate treatment in accordance with Annex VII of Directive 2012/19/EU. This directive was implemented in Italy by Legislative Decree 49/2014. Compliance with this requirement is met through the TIM Group's declaration of the management of the disposal of electrical and electronic equipment in accordance with the R.A.E.E. Regulations, which in turn are regulated by Legislative Decree 49/2014.
Despite the numerous management and oversight activities carried out by the TIM Group with respect to the issues covered by the DNSH requirements, it is concluded that some criteria are still only partially met.
Finally, for this first year of reporting, it was not possible to verify compliance with the requirements of this DNSH for activity 8.2 (Data-driven solutions for GHG emissions reductions) because it is an activity that includes many different IT services and solutions.
In line with the requirements of Article 3(c) of Regulation 2020/852, the TIM Group conducts its business activities in compliance with the minimum safeguards specified in Article 18 of the Regulation, i.e., in accordance with the OECD Guidelines for Multinational Enterprises and the United Nations Guiding Principles on Business and Human Rights, including the principles and rights set forth in the eight core conventions identified in the International Labor Organization's Declaration on Fundamental Principles and Rights at Work and the International Bill of Human Rights.
The TIM Group affirms its commitment to respect for human rights within its Code of Ethics and Conduct and monitors relevant aspects of it through a dedicated policy that has application at the Group level and across the entire value chain, to protect all workers, collaborators outside the TIM Group and customers in general. The policy has been drafted on the basis of recognized international references (such as UN Universal Declaration of Human Rights, International Labor Organization, OECD, Guidelines for Multinational Enterprises, etc.) and is supported in its application by additional internal references (by way of example: the 231 Organizational Model, Social Responsibility, Supplier Relations in the Purchasing process, etc.). All the activities recommended by the policy are subject to a periodic internal due diligence process (carried out by sending out a self-assessment questionnaire), with the aim of identifying and mapping the Human Rights risks arising from the Group's operational activities, monitoring the effectiveness of the safeguards in place for each of the relevant issues and, in particular, defining a path of increasing stakeholder engagement with respect to these issues.
To ensure compliance with the policy and monitoring of related issues across the entire value chain, the TIM Group subjects its suppliers to an evaluation questionnaire and conducts periodic audits. For the latter, specifically, The TIM Group refers to the expectations on the requirements being audited agreed upon and formalized by key TELCO stakeholders in the Joint Audit Cooperation (JAC), an industry initiative, of which the TIM Group is one of the founders, that aims to raise standards on Human Rights.
Finally, the TIM Group recently joined Open-Es, a platform for sharing data and information on companies' sustainability performance. As of January 1, 2021, all active suppliers of the TIM Group have been asked to join the platform with the aim of establishing a transparent and cooperative relationship for a common path of improvement.
The TIM Group's tax governance is guided by the principles contained in its Code of Ethics and Conduct, and the approach for its management is defined in the Group's Tax Strategy and Tax Policy. According to these documents, the TIM Group is committed to establishing fully transparent relations with the Tax Authorities. It is also stipulated that tax-related risks are identified and managed through an internal control system (Tax Control Framework).
In order to prevent possible corruption incidents, the Parent Company TIM S.p.A. and TIM Brasil have implemented an ISO 37001 certified management system. In particular, the Group has various procedures such as the Code of Ethics, Organizational Model 231 and the Anti-Corruption Policy to confirm its commitment.
Fair competition is promoted by the TIM Group, which is actively engaged and participates in running technical tables and initiatives in collaboration with competitors. The TIM Group's sensitivity to the issue is also supported by the Code of Ethics and Conduct, in which it refers to the principles of transparency, fairness and loyalty, which are observed whenever a service is provided or an activity is conducted. Indeed, fair competition is recognized as serving the interest of each market player, customers and more generally all stakeholders. In addition, the TIM Group regularly provides adequate and appropriate training/information to corporate bodies and its employees.
The TIM Group has not received any final convictions for violations of fundamental and constitutionally guaranteed rights in the area of labor, such as freedom of association, discrimination due to union membership or human rights violations, or for corruption.
In addition, the TIM Group has not received any definitive legal charges for tax violations.
Finally, with regard to FY 2022, it is reported that there are 2 ongoing proceedings regarding the agreements with DAZN and A556, related to the CONSIP tender for mobile phone services. In any case, the TIM Group is highly sensitive to these issues, as evidenced by the initiatives and activities undertaken with market competitors, as well as ongoing discussions with industry associations and authorities (e.g., Communications Guarantee Authority-AGCOM-, Ministry of Economic Development). In fact, over the years, the TIM Group has developed a comprehensive compliance program through various initiatives such as the provision of antitrust training or antitrust compliance audit on Mergers & Acquisitions transactions, with the aim of analyzing and mapping risk, involving and making its employees more aware, and preparing and implementing internal procedures.
For each of the activities considered eligible and aligned, non-financial enterprises are required to report three economic performance indicators (hereinafter also referred to as "KPIs," from the English Key Performance Indicator) namely, the Turnover KPI, the Capital Expenditure KPI (CapEx) and the Operating Expenditure KPI (OpEx).
Within Annex II of the Article 8 Delegated Regulations, templates through which to report these data are made available.
As this is the first year of reporting on the alignment, comparative data with the previous period are not available and therefore will not be represented.
The percentage of the Group's economic activities eligible and aligned with the Taxonomy with respect to Turnover, CapEx, and OpEx was calculated in accordance with legal requirements and according to the accounting criteria specified within Annex I of the Delegated Regulation on Article 8. However, due to the variety of services offered belonging to the different economic activities surveyed by the TIM Group, in order to carry out a correct assessment of economic activities and calculation of KPIs, the Group needed to develop and use special estimates to identify the correct percentage of eligible and aligned economic activities, but also to exclude costs (CapEx/OpEx) or revenues that cannot be attributed entirely and exclusively to the single economic activity surveyed.
Being the second year of eligibility reporting, the TIM Group has been able to
refine the methodology of data collection and calculation, returning increasingly timely eligibility percentage values with respect to the activities conducted in FY 2022 by the Group.
The scope of 2022 reporting includes Group companies where the analysis has identified business activities that are compatible with the categories envisaged by the eligibility criteria of the regulations, while maintaining a precautionary and prudential approach regarding the reporting of such data. The values shown result from the aggregation of items related to TIM S.p.A., TI Sparkle Group, Noovle S.p.A. and Olivetti Group. With regard to TIM S.A., the Group's Brazilian subsidiary, the analysis conducted in 2022, although more punctual than last year, is not yet sufficiently thorough to be able to determine with certainty that the items included are consistent with those established by the Regulation.
The share of turnover aligned with Taxonomy Regulation results from the ratio of net revenues from aligned activities (numerator) to total net revenues (denominator). The denominator of KPI turnover refers to the item "revenue" in the Consolidated Statement of Comprehensive Income to 2022, consolidated in accordance with IAS 1.82(a). In particular, the value can be reconciled with the TIM Group's annual financial report with reference to Note 26 of the Consolidated Financial Statements.
The numerator of KPI Turnover is the net revenues associated with the Group's
products related to eligible and/or aligned activities. The allocation of net revenues to the numerator was made possible by the Group's accounting system, which allowed for the identification of eligible services and projects.
Regarding the alignment of revenues generated by Activity 8.3 (Programming and broadcasting activities), as anticipated, the TIM Group took into account only the portion attributable to content meeting the requirement to raise awareness of climate change issues. For this purpose, the aligned percentage was then derived by running a ratio between the programs meeting the criterion and the entire program schedule for FY 2022.
The proportion of taxonomy-aligned capital expenditure (CapEx) corresponds to the proportion of CapEx related to eligible and aligned activities (numerator) to total CapEx (denominator). The denominator should include additions to tangible and intangible assets during the year considered before depreciation, depletion, and any revaluation, including those resulting from restatements and reductions in value, for the year in question, and excluding changes in fair value. The denominator should also include increases to tangible and intangible assets resulting from business combinations. This value can be reconciled with the TIM Group's annual financial report, with reference to Notes 6, 7 and 8 of the Consolidated Financial Statements.
The eligible and aligned CapEx percentage includes:
Regarding the alignment of investments allocated on Activity 8.3 (Programming and broadcasting activities), the TIM Group considered only the portion corresponding to the percentage of aligned turnover, identified as described in the previous paragraph.
Like last year, the TIM Group counts among the projects pertaining to the Taxonomy investments that can be classified in Type C CapEx, respectively, in activities 7.2 (Renovation of Existing Buildings) and 4.1 (Generation of Electricity by Solar Photovoltaic Technology) of the Climate Act.
Although these activities are compatible in terms of eligibility, the TIM Group has decided to deepen alignment analysis on core business activities, partly because of the materiality of the former and the inherent variability in terms of capitalization in previous and future reporting years. Finally, this decision is further endorsed by the adoption of a precautionary approach that does not include the aforementioned activities performed on TIM's behalf by third-partysuppliers .
The share of taxonomy-aligned operating expenses (OpEx) results from the proportion of eligible OpEx aligned by the direct non-capitalized costs for research and development, building renovation, short-term rent, maintenance and repair, and any other direct expenses related to the day-to-day maintenance of property, plant, and equipment (numerator) to the total OpEx related to the above categories (denominator). This value was calculated from the total value of operating expenses within the TIM Group's annual financial report with reference to Notes 28 and 44 of the Consolidated Financial Statements.
The percentage of eligible and aligned OpEx includes operating expenses related to assets and processes associated with economic activities aligned with the Taxonomy. Operating expenses were defined as eligible/aligned in case they were directly related to economic activities eligible/aligned to the Taxonomy in order to avoid double-counting.
| TURNOVER | Substantial contribution criteria | DNSH Criteria | ||||||||||||||||||
|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|
| Economic activities | Codes | Absolute turnover | Share of turnover | mate change mitigation Cli |
mate change adaptation Cli |
marine resources Water and |
my Circular Econo |
Pollution | Biodiversity and ms ecosyste |
mate change Mitigation of cli |
Adaptation to the mate change cli |
marine resources Water and |
my Circular Econo |
Pollution | Biodiversity and ms ecosyste |
m safeguards mu Mini |
Share of turnover aligned my, 2022 to Taxono |
Share of turnover aligned my, 2021 to Taxono |
Category (activity enabling o) |
Category (activity transitional) |
| k€ | % | % | % | % | % | % | % | Y/N | Y/N | Y/N | Y/N | Y/N | Y/N | Y/N | % | % | A | T | ||
| A. TAXONOMY-ELIGIBLE ACTIVITIES | ||||||||||||||||||||
| A.1 ENVIRONMENTALLY SUSTAINABLE ACTIVITIES (ALIGNED WITH TAXONOMY) | ||||||||||||||||||||
| 8.3 Programming and broadcasting activities | 44 0.0003% | N/A | 100% | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | S 0.0003% | N/A | A | ||||
| Turnover of environmentally sustainable activities (aligned with taxonomy) (A.1) |
44 0.0003% | 0% | 100% | N/A | N/A | N/A | N/A | 0.0003% | N/A | |||||||||||
| A.2 ACTIVITIES ELIGIBLE FOR THE TAXONOMY BUT NOT ENVIRONMENTALLY SUSTAINABLE (ACTIVITIES NOT ALIGNED WITH THE TAXONOMY) | ||||||||||||||||||||
| 8.1 Data processing, hosting and related activities | 509,437 | 3.2% | 100% | 0% | N/A | N/A | N/A | N/A | N/A | S | S | N | N/A | N/A | S | |||||
| 8.2 Data-driven solutions for GHG emissions reductions | 185,242 | 1.2% | 100% | 0% | N/A | N/A | N/A | N/A | N/A | S | N/A | N | N/A | N/A | S | |||||
| 8.3 Programming and broadcasting activities | 2,813 | 0.018% | 0% | 100% | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | S | |||||
| Turnover of activities eligible for the taxonomy but not environmentally sustainable (activities not aligned with the taxonomy) (A.2) |
697,494 | 4.4% | ||||||||||||||||||
| Turnover of activities eligible for the taxonomy (A.1 + A.2) (A) (A.1 + A.2) (A) |
697,538 | 4.4% | 99.6% | 0.40% | N/A | N/A | N/A | N/A | 0.0003% | N/A 0.0003% | ||||||||||
| B. TAXONOMY-NON-ELIGIBLE ACTIVITIES | ||||||||||||||||||||
| Turnover of activities not eligible for taxonomy (B) | 15,090,461 | 95.6% | ||||||||||||||||||
| Total (A + B) | 15,788,000 | 100% |
| CAPEX | Substantial contribution criteria | DNSH Criteria | ||||||||||||||||||
|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|
| Economic activities | Codes | Absolute Capex | Proportion of CapEx | mate change mitigation Cli |
mate change adaptation Cli |
marine resources Water and |
my Circular Econo |
Pollution | ms Biodiversity and ecosyste |
mate change Mitigation of cli |
mate change Adaptation to cli |
marine resources Water and |
my Circular Econo |
Pollution | ms Biodiversity and ecosyste |
m safeguards mu Mini |
Share of turnover aligned my, 2022 to Taxono |
Share of turnover aligned my, 2021 to Taxono |
Category (activity enabling o) |
Category (activity of transition) |
| k€ | % | % | % | % | % | % | % | Y/N | Y/N | Y/N | Y/N | Y/N | Y/N | Y/N | % | % | A | T | ||
| A. TAXONOMY-ELIGIBLE ACTIVITIES | ||||||||||||||||||||
| A.1 ENVIRONMENTALLY SUSTAINABLE ACTIVITIES (ALIGNED WITH TAXONOMY) | ||||||||||||||||||||
| 8.3 Programming and broadcasting activities | 635 0.013% | N/A | 100% | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | 0.013% | N/A | A | ||||
| Capital expenditures of environmentally sustainable activities (aligned with taxonomy) (A.1) |
635 0.013% | 0% | 100% | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | 0.013% | N/A | 0.013% | |||
| A.2 ACTIVITIES ELIGIBLE FOR THE TAXONOMY BUT NOT ENVIRONMENTALLY SUSTAINABLE (ACTIVITIES NOT ALIGNED WITH THE TAXONOMY) | ||||||||||||||||||||
| 8.1 Data processing, hosting and related activities | 228,207 | 4.6% | 100% | 0% | N/A | N/A | N/A | N/A | N/A | S | S | N | N/A | N/A | S | |||||
| 8.2 Data-driven solutions for GHG emissions reductions | 135,552 | 2.8% | 100% | 0% | N/A | N/A | N/A | N/A | N/A | S | N/A | N | N/A | N/A | S | |||||
| 8.3 Programming and broadcasting activities | 41,090 | 0.8% | 0% | 100% | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | S | |||||
| 7.2 Renovation of existing buildings | 59,654 | 1.2% | 100% | 0% | N/A | N/A | N/A | N/A | ||||||||||||
| 4.1 Power generation by solar photovoltaic technology | 5,673 | 0.1% | 100% | 0% | N/A | N/A | N/A | N/A | ||||||||||||
| Capital expenditures of activities eligible for the taxonomy but not environmentally sustainable (activities not aligned with the taxonomy) (A.2) |
470,179 | 9.6% | ||||||||||||||||||
| Total capital expenditure eligible for Taxonomy (A.1 + A.2) (A) |
470,814 | 9.6% | 77.3% | 8.7% | N/A | N/A | N/A | N/A | 0.013% | N/A | 0.013% | |||||||||
| B. TAXONOMY-NON-ELIGIBLE ACTIVITIES | ||||||||||||||||||||
| Capital expenditures of activities not eligible for taxonomy (B) |
4,438,185 | 90.4% | ||||||||||||||||||
| Total (A + B) | 4,909,000 | 100% |
| OPEX | Substantial contribution criteria | DNSH Criteria | ||||||||||||||||||
|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|
| Economic activities | Codes | Absolute OpEx | Proportion of OpEx | mate change mitigation Cli |
mate change adaptation Cli |
marine resources Water and |
my Circular Econo |
Pollution | Biodiversity and ms ecosyste |
mate change Mitigation of cli |
Adaptation to the mate change cli |
marine resources Water and |
my Circular Econo |
Pollution | Biodiversity and ms ecosyste |
m safeguards mu Mini |
Share of turnover aligned my, 2022 to Taxono |
Share of turnover aligned my, 2021 to Taxono |
Category (activity enabling o) |
Category (activity of transition) |
| k€ | % | % | % | % | % | % | % | Y/N | Y/N | Y/N | Y/N | Y/N | Y/N | Y/N | % | % | A | T | ||
| A. TAXONOMY-ELIGIBLE ACTIVITIES | ||||||||||||||||||||
| A.1 ENVIRONMENTALLY SUSTAINABLE ACTIVITIES (ALIGNED WITH TAXONOMY) | ||||||||||||||||||||
| 8.3 Programming and broadcasting activities | 0.00% | 0% | 100% | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | 0.00% | N/A | A | ||||
| Operating expenses of environmentally sustainable activities (aligned with taxonomy) (A.1) |
- | 0.00% | 0% | 100% | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | 0.00% | N/A | A | ||
| A.2 ACTIVITIES ELIGIBLE FOR THE TAXONOMY BUT NOT ENVIRONMENTALLY SUSTAINABLE (ACTIVITIES NOT ALIGNED WITH THE TAXONOMY) | ||||||||||||||||||||
| 8.1 Data processing, hosting and related activities | 150,243 | 11.0% | 100% | 0% | N/A | N/A | N/A | N/A | N/A | S | S | N | N/A | N/A | S | |||||
| 8.2 Data-driven solutions for GHG emissions reductions | 0.3 | 0.0% | 100% | 0% | N/A | N/A | N/A | N/A | N/A | S | N/A | N | N/A | N/A | S | |||||
| 8.3 Programming and broadcasting activities | - | 0.0% | 0% | 100% | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | S | |||||
| Operating expenses of activities eligible for the taxonomy but not environmentally sustainable (activities not aligned with the taxonomy) (A.2) |
150,243 | 11.0% | ||||||||||||||||||
| Total operating expenses eligible for Taxonomy (A.1 + A.2) (A) |
150,243 | 11.0% | 100.0% | 0.0% | N/A | N/A | N/A | N/A | N/A | N/A | A | |||||||||
| B. TAXONOMY-NON-ELIGIBLE ACTIVITIES | ||||||||||||||||||||
| Operating expenses of activities not eligible for taxonomy (B) |
1,214,756 | 89.0% | ||||||||||||||||||
| Total (A + B) | 1,365,000 | 100% |
In view of the fact that the Europe Taxonomy is an evolving Regulation (consider the future publication of Delegated Acts on the remaining environmental objectives), the TIM Group has adopted an approach as transparent and prudent as possibile, interpreting and applying what is required by the Regulation as rigorously as possible.
Along with the constant analysis of the publications released by the Platform on Sustainable Finance, the TIM Group has been openly discussing with its peers in the TELCO sector in order to share and gather different points of view in interpreting, in the best possible way, the complexity of technical requirements.
Similar to other challenges that the TIM Group has taken up and is facing, the European Taxonomy presents itself as an opportunity that can motivate and lead toward an increasing refinement of the business model and performance of activities in relation to and with respect to the surrounding environment, becoming a fundamental tool for achieving radical and unprecedented change.
In particular, the digital solutions provided by the TIM Group actively contribute to accelerating digital transformation, a key element in reducing GHG emissions, and have cross-cutting application in multiple sectors of the economy that are also included within the annexes to the Delegated Regulation (including manufacturing or transportation).
The impact and role of telecommunications is therefore very broad in achieving climate goals. Aware of this, the TIM Group pursues specific goals for improvement (such as the certification of Data Centers in line with the European Code of Conduct), and integration of technological services on the transmission network (think of the continuous modernization of network infrastructure).
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| Independent auditor's report on the consolidated disclosure of non- financial information in accordance with Article 3, par. 10, of Legislative Decree 254/2016 and with Article 5 of CONSOB Regulation adopted with Resolution n. 20267 of 18 January 2018 |
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| (Translation from the original Italian text) | ||
| To the Board of Directors of TIM S.p.A. |
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| Directors on March 15, 2023 (hereinafter "DNF"). | We have been appointed to perform a limited assurance engagement pursuant to Article 3, paragraph 10, of Legislative Decree December 30, 2016, n. 254 (hereinatter "Decree") and article 5 of CONSOB Regulation adopted with Resolution 20267/2018, on the consolidated disclosure of non-financial information of TIM S.p.A. and its subsidiaries (hereinafter the "Group" or "TIM Group") for the year ended December 31, 2022 in accordance with article 4 of the Decree and approved by the Board of Our limited assurance engagement does not cover the information included in the paragraph "European Taxonomy' of the DNF, that are required by article 8 of the European Regulation 2020/852. |
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| Responsibilities of Directors and Board of Statutory Auditors for the DNF | ||
| reporting standard. | The Directors are responsible for the preparation of the DNF in accordance with the requirements of articles 3 and 4 of the Decree and the "Global Reporting Initiative Sustainability Reporting Standards" defined by GRI - Global Reporting Initiative (hereinafter "GRI Standards"), identified by them as a |
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| The Directors are also responsible, within the terms provided by law, for that part of internal control that they consider necessary in order to allow the preparation of the DNF that is free from material misstatements caused by fraud or not intentional behaviors or events. |
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| results and its impact. | The Directors are also responsible for identifying the contents of the DNF within the matters mentioned in article 3, par. 1, of the Decree, considering the business and the characteristics of the Group and to the extent deemed necessary to ensure the understanding of the Group's business, its performance, its |
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| The Directors are also responsible for defining the Group's management and organization business model, as well as with reference to the matters identified and reported in the DNF, for the policies applied by the Group and for identifying and managing the risks generated or incurred by the Group. |
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| compliance with the requirements of the Decree. | The Board of Statutory Auditors is responsible, within the terms provided by the law, for overseeing the | |
| Auditor's independence and quality control | ||
| We are independent in accordance with the ethics and independence principles of the International Code of Ethics for Professional Accountants (including International Independence Standards) (IESBA Code) |
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| FV S P & A le Legale: Via Meravigli, 12 - 20123 Milan Sede Secondaria: Via Lombardia, 31 - 00187 Roma Capitale Sociale Euro 2.525.000.00 I.v. Iscritta all'Albo Speciale delle società di revision Consob al progressivo n. 2 delibera n.10831 del 16/7/1997 |
lscritta alla S.O. del Registro delle Imprese presso la CCIAA di Millano Monza Brianza Lod Codice fiscale e numero di Iscrizione 00434000584 - numero R.E.A. di Milano 606158 - P.IVA 00891231003 lscritta al Registro Revisori Legall al n. 70945 Pubblicato sulla G.U. Suppl. 13 - IV Serie Speciale del 17/2/1998 |
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| A member firm of Emst & Young Global Limited |
| working world | Building a better |
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| and with the personnel of TIM S.p.A. and we have performed limited documentary evidence procedures, in order to collect information about the processes and procedures that support the collection, aggregation, processing and transmission of non-financial data and information to the management responsible for the preparation of the DNF. |
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| Furthermore, for significant information, considering the Group activities and characteristics: | |
| at Group level | |
| a) with reference to the qualitative information included in the DNF, and in particular to the business model, policies implemented and main risks, we carried out inquiries and acquired supporting documentation to verify its consistency with the available evidences: |
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| b) with reference to quantitative information, we have performed both analytical procedures and limited assurance procedures to ascertain on a sample basis the correct aggregation of data. |
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| - For the Group entities TIM S.p.A. and TIM S.A., that we have selected based on their activities, relevance to the consolidated performance indicators and location, we have carried out remote interviews during which we have had discussions with management and have obtained evidence about the appropriate application of the procedures and the calculation methods used to determine the indicators. |
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| Conclusion | |
| Standards. | Based on the procedures performed, nothing has come to our attention that causes us to believe that the DNF of the TIM Group for the year ended on December 31, 2022 has not been prepared, in all material aspects, in accordance with the requirements of articles 3 and 4 of the Decree and the GRI |
| 2020/852. | Our conclusion on the DNF of the TIM Group do not refer to the information included in the paragraph "European Taxonomy" of the DNF itself, that are required by article 8 of the European Regulation |
| Torino, March 30, 2023 | |
| EY S.p.A. | Signed by: Ettore Abate, Auditor |
| readers. | This report has been translated into the English language solely for the convenience of international |

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