a) that it has effectively and efficiently adopted an internal control model aimed at preventing the commission of the offences in question
b) that it has established an independent entity with the power to act and control, and assigned the task of verifying compliance with the Model and its operational effectiveness and updating.

Following changes in the corporate structure, the Organisational and Operating Model was updated and approved by Weather’s Board of Directors on 19 July 2006.
Wind’s Board of Directors also approved the Model on 3 August 2006 and confirmed assignment of the role of Compliance Officer (CO) to the Head of Wind’s Internal Audit Department. This person has the following specific responsibilities:

• to monitor the Model’s effectiveness and the need for updates
• to promote diffusion of the Model
• to activate control procedures and carry out periodic checks involving activities at risk
• to receive any reports regarding offences committed, as defined by the Decree, and carry out appropriate checks
• to draw up periodic reports on implementation of the Model
• to coordinate the CO’s activities in subsidiaries.

For any information on the Model and its application in Wind, contact the following e-mail address: ServizioCOWind@mail.wind.it
The Model is divided into a General Part (containing the provisions of the Legislative Decree, the functions and aims of the Model, internal control functions, etc.) and two Special Parts – concerning offences against public entities (Special Part A) and corporate offences (Special Part B) - listing the specific types of offence provided for in the Legislative Decree, and the internal rules to be followed in order to prevent the risk of these offences being committed.