Table 8.

Company A’s map of activities to protect themselves against the risk of fraud

Activities carried out to protect against fraud risks
ActivityDescription
Enterprise risk management (ERM) – Fraud risk assessmentIdeation and implementation of a specific fraud risk assessment, seeking to identify potential areas of fraud risk and assess existing controls to prevent such risks, as part of the extension of the Enterprise Risk Management (ERM) project, in the following Terna core processes: Grid development, design and construction, plant Maintenance, regulatory Affairs
“Open and transparent site” portalDesign and implementation of the “open and transparent site” portal, dedicated entirely to job sites, which contains complete information on agreements, contracts and – for the first time – subcontracts relating to works in progress for the construction of large and small electricity infrastructure in Italy
“Subcontract Management” portalThe “subcontract management” portal is a centralised electronic tool for the continuous management, analysis and monitoring of subcontracts, used to control the outsourcing process during the implementation phase of contracted works with existing suppliers and to improve process efficiency, guaranteeing its compliance and traceability, reducing exposure to fraud risk, illegal behaviour and criminal infiltration and mitigating 231 risk. Since 1 February 2015, contractors have been able to access the portal and request authorisation to subcontract directly to the system, indicating – in relation to a specific procurement contract and in line with the indications given during the tender phase – which works they intend to subcontract, for what amount and to which firm, and attaching all the necessary documentation related to the subcontract
Source: Company A, p. 76

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