Tangenziale Esterna SpA scrupulously complies with all laws. However, it also places great emphasis on sticking to the agreements – and related commitments – with Prefectures and trade associations. Such commitments relate to the Legality Protocol to combat infiltration by organized crime in tenders for works included in the Expo Dossier. The Legality Protocol was signed by TE, as the concession holder, and the general contractor (Consorzio Costruttori TEEM) on 31 July 2012 at the Milan Prefecture. The protocol is pursuant to the guidelines published in the Official Journal of the Republic of Italy by an Interior Ministry special committee for major works (Coordinamento per l’Alta Sorveglianza delle Grandi Opere). For TEEM, the following signed the Legality Protocol:

• Milan Prefecture;
• Lodi Prefecture;
• Monza and Brianza Prefecture;
• Concessioni Autostradali Lombarde S.p.A.;
• Tangenziale Esterna S.p.A.
• Consorzio Costruttori TEEM

All the signatories of the Legality Protocol related to TEEM are seeking to guarantee, throughout construction, compliance with current laws, transparency and open competition. This includes the comprehensive enactment of the monitoring and supervisory powers allocated by Law, especially to prevent, monitor and combat attempts by organized crime to infiltrate the management of tenders. The other primary goal of the Legality Protocol is to constantly verify safety in the workplace and to combat the problem of off-the-books work.

For TE, the day-to-day enforcement of the Legality Protocol involves acquiring a mafia check prior to signing, approving and authorizing any type of contract or agreement. If the information obtained indicates the company or companies in question have suffered prior attempts of mafia infiltration or have actually been infiltrated, then TE does not sign, approve or authorize the contracts or sub-contracts in question. In addition, for the same purpose, LE has invested substantial funds and hours to create a database – named Genesis – that uses the most advanced technologies. This database makes it possible to constantly monitor all the companies involved in building TEEM and to cross-reference the anti-mafia information with the details in the relevant IT systems of the competent Prefecture, inter-force group, Concessioni Autostradali Lombarde (CAL) and works management. As part of this, TE inputs a weekly report into Genesis (called “Settimanale di Cantiere” or “work site weekly report”) that contains detailed, useful information about the works to realize and the name of the company and the employees that, during the week in question, are working at the site along with anybody else who has access to the site.

Furthermore, a specific “Group to monitor the movements of labourers” has been established at the Milan Prefecture as part of the anti-mafia efforts. This working group includes not only TE, but also CAL (the entity granting the concession) and the local offshoot of the Ministry of Labour and Social Policies (Direzione Territoriale del Lavoro or DTL). Thus, it is a team effort to constantly monitor all the extremely delicate stages of the construction project to prevent any problems in the proper enactment of the most rigorous procedures for assigning work, granting contracts, determining tenders and sub-tenders, and deciding on suppliers. The monitoring obviously extends to all executive stages.