INSPECTION SERVICES AND ACTIVITIES 'OF SUPERVISION, DEPARTMENT OF DIRECTIVE 
Services inspection and surveillance activities
Directive of the Minister
MINISTER LABOR, HEALTH AND SOCIAL POLICY
Having regard to Article 8 of the Law of 14 February 2003, no 30;
VISA Legislative Decree April 23, 2004, No 124; CONSIDERING the decree law of 25 June 2008, n. 112, with amendments, with the Law of 6 August 2008
No 133; VIEW directive of the President of the Council of Ministers on 2 July 2002
inspection activities;
ADOPTED THIS DIRECTIVE
(ex art. 2, paragraph 2 of legislative decree No. 124 of 2004)
Purpose This Directive, inspired by the radical change of inspections and supervision
following the elimination of payroll and serial number and other statutory books and
of their replacement, with effect from 18 August 2008, with the book's unique work (Articles 39
and 40 of Decree Law of 25 June 2008, n. 112, converted with amendments by Law
6 August 2008, No. 133), aims to revive the philosophy of preventive and promotional literature referred to
Legislative Decree April 23, 2004, No 124 containing measures to rationalize the
tasks of inspection and supervision of social security and working
under Article 8 of the Law of 14 February 2003, no 30.
In this perspective, in order to initiate a renewed and constructive relationship with
traders and their advisers, which is essential to complete the process of modernization
labor market started with the 'Biagi law', it refers to the centrality
a vision of supervisory activities attentive to the quality and effectiveness of inspection measures.
Action to be that basically aims to prevent abuses and punishing irregularities
phenomena essentially abandoned, however, any residual setting
purely formal and bureaucratic, unnecessarily hampering the efficiency of production without bringing any
minimum tangible contribution to the protection of the person who works
.
inspection and supervisory personnel, ministerial and social security can not therefore be overlooked,
in the performance of institutional duties, the profiles related to verification and inspection
in the strict sense, but even those, which are also fundamental in the system of
Legislative Decree 124, 2004, prevention, promotion and information that it
have been entrusted by law. In today's labor markets, increasingly complex and diversified
, authority and credibility of the inspector in charge of the investigation will take
fact a decisive role not only in relation to the success of individual inspections, but also in
function of government assets and the overall control of the territory and, more generally,
the contribution that the inspection services will provide, within their respective jurisdiction and
consistent with the guidelines of the International Labour Organization on inspection, the implementation of policy - local, national but also
Community and international - to support growth balanced and socially sustainable.
Achieving such a goal will depend not only on technical competence and professionalism of the inspectors
faithfully applying laws and regulations, along the lines
guide and addresses provided by the central level, consistent with the approach of the Legislative Decree No
124, 2004, but also the ability to interpret modern and effective
the institutional role of the inspector. All in a service logic rather than mere
exercise of power, within the parameters of fairness, transparency and uniformity
entire national territory, which could usefully be enhanced as a function of experience,
of sensitivity and interpersonal skills of the individual inspector.
basic utilities and the construction of an innovative policy to inspect the work, however,
can not rely on a centralized view of security activities relating to employment and social security
. The Government of the inspection work, in fact, has become increasingly synergistic
summary of actions planned and implemented by different inspection bodies, so
coordinated in principle uniform across regions, even in light of specific conditions and the
characteristics of individual areas and the different districts
flights. The
planning activity is the defining moment in the formulation of an action
inspection wishing to be effectively and efficiently focused on concrete objectives and substantive
prevention and suppression of violations. In it, therefore,
holders of branch offices, with particular reference to the leaders of the local labor
must be sent through an accurate collection and analysis of the items
review helpful to outline the different features of reality in which they operate,
even under a more intense cooperation with trade unions and employers' associations with
, with employment experts, as well as with representatives of institutional
provincial and municipal governments, universities and research centers
, in order to acquire a better knowledge of the problems that characterize the individual
corporations, regional and various sectors, for a more appropriate and profitable
Address of supervision. In this perspective, however, should be taken into account,
provincial level, the findings of the statistical work carried out inspection on the territory
years earlier, in order to direct the operations
inspection so as not to leave areas of manufacturing facilities or areas completely escape the territorial
controls.
In organizing the inspection measures the leaders of the local Labour
must operate in a constant balance between the inspection initiative called "on demand", based on
identification of a specific territory or a specific production plant, and the
'inspection scheduled start. In particular, care is taken to prevent a
excessive discretion to inspect "visible" to the inspection staff recognized
can lead to the absence of the inspection system, combining, and then, a series of special operations to target
not individually identified with normal programming for individual companies
in a special order of service, as determined from time to time
manager or person responsible for the inspection service, which will not be able
waived except for compelling and urgent reasons, of which the inspectors must give immediate notice
. In particular, the plan of inspections will be fixed by the directors of the provincial directorates
work, based on the criteria to be established by the Directorate General for
The audit at the end of a regular organization of supervision evenly throughout
and under clear lines of priority.
It will then be the leaders of the Regional Directorate of Labour plays a fundamental role
Coordination provincial evidence, in order to make clear strategy on
inspection throughout the region and report to the Directorate General for Inspections and, for the
through this, the Central Commission for the Coordination of surveillance activities.
While on a statistical information and the relevant Regional Directorate for Labour, in connecting
phase of spatial data, and the Directorate General for Inspections should monitor
bi-monthly, the evolution of consciousness. Condition
unfailing planning of inspections and also the
coordination with all other bodies responsible for overseeing
expertise in matters within the Ministry of Labour, Health and Welfare, to be implemented with
mutual exchange of information in three levels (central, regional and local), according to
specific provisions of Articles 3, 4 and 5 of Legislative Decree No 124, 2004.
In this sense, be extremely careful in developing software technologies that enable it to overcome
known issues, such as the overlapping
inspection operations, directing the surveillance activities on sensitive targets, of particular relevance and analytical result of actions intelligence related to the development of objective indicators
risk. It will
, Finally, the Directorate General for Inspections, in exercise of his duties
its management and coordination of supervisory activities, provide
on the basis of directives issued by the Minister, specific operational guidelines, with the dual purpose of ensuring the
'operating unit of inspection activity and consistency of behavior
different supervisors, the only effective guarantee of an effective labor inspection and
credible that affect the actual behavior of economic agents and their
consultants, real assurance of compliance' balance, played by the rules of law, including the need for competitiveness
business and the essential demands of personal protection that works
.
In its direction and coordinating the work of the Directorate General for
inspection activities must take account, in order to optimize the resources available, the presence of
forms of social control (such as bilateral bodies) or forms of institutional control
alternatives (such as locations for certification of employment contracts and procurement), paying particular attention to
situations that are totally free of control or verification prior
.
Finally, in terms of planning, care must be the administrators of
inspection procedure before starting the investigation be entrusted to a careful preparation of
itself, according to the provisions of article 6 of the Code of Conduct '
approved by Decree of 20 April 2006, according to specific indications given by the head of the inspection service
work of the Swiss Provincial affiliation or business unit managers by
supervision to which they are assigned.
Requests for assistance and conciliation monocratic
particularly delicate, precisely because of a careful and coherent planning
inspection activity, is the evaluation of requests for assistance from one or more workers or by an organization
trade union against a specific reality
company. In this regard, also in order to avoid exploitation of the role of the inspector,
you think you do not have to respond to anonymous requests submitted by mail, e-mail, fax or phone
. As a rule, and subject to limited exceptions that emerge with clear and incontrovertible evidence
the severity and credibility of the allegations, even when
or detailed assessment, the anonymous complaint can not and should not be taken into account for programming
inspection because of actions contrary to the principles of fairness and transparency of action
of public administration.
always the load of requests for assistance and complaints received by the Provincial Labour Directorate
, often unfounded or instrumental, is a hindrance to the rest
more effective supervision of initiative and a real obstacle to the implementation of an efficient scheduling of inspections
labor, especially in certain territorial
marked by significant quantitative, in terms of density of production plants.
Just on this figure must be based full and effective implementation of the institution of conciliation
monocratic prior Article 11 of Legislative Decree No
124, 2004, paying attention to requests from privileged action to be taken to
cue for the start of an attempt at conciliation between the employee and the complainant's employer.
The correct and general implementation of the conciliation monocratic in its preventive services
allow inspection of the work of the local work
reorganize itself, in terms of scheduling of inspections, confirming the initiative
inspection at the request of intervention only to requests for intervention
characterized by the complaint of serious irregularities, such as those of criminal law, or
those affecting other workers in addition to the complainant, or those involving
phenomena avoidance is particularly widespread in the territory, also in view of the fact that
inspection at the request of intervention
typically follows a moment of "rupture" of interpersonal relations between the complainant and complained, so much to put in pre-alarm
the employer employed, compared to an inspection which, therefore, not
will ever have the same effect as the inspection scheduled start.
In order to better target the work inspection criteria programming of assistance,
according to the principles of efficiency, effectiveness and economy of administrative action, it
specifies that the mere presentation to a request for help
a hypothesis is not attributable to in Article 2, paragraph 1, of Law 241, 1990, and therefore in itself
not involve the administration must make the necessary course
verification inspection, unless the allegations are not criminal in nature, so there is always this obligation
. Therefore, in the case of requests for action that, while
signed by the complainant, but not the character of the reliability of objective facts and
the concrete possibility to prove that he was reported, the office can take no action in
On Site , which can be stored, if not reach the office
new elements at the end of the year following the submission of the request
intervention itself, prior written notice to the complainant. It is believed that this provision is particularly relevant especially in
territorial
that record a significant number of requests to speak to the resources available to inspection.
In this perspective, a balanced balance between the inspection of the initiative and
on request, allow the offices of the Ministry to initiate rounds of inspections focused on
individual territories or on the various sectors that can promote the emergence
of undeclared work and, above all with the use of the instrument of formal
mandatory (under Article 13 of Legislative Decree No. 124 of 2004), to boot
business to a "emergence Wizard", which has devastating effects on not easy keeping
local economic initiatives, ensuring, thus, protection
overall employment levels, not just the individual worker. Access
inspection and verbalization
To properly set up access in the company must now consider, first,
the radical change of inspections and supervision, following the elimination of books and serial
pay and other statutory books and they are replaced, with effect from August 18
2008, with the only book of the work (Articles 39 and 40 of Decree Law of 25 June 2008, n. 112).
In view of the new features of the book's unique work, the labor inspection
will have access to rapid decline a systematic inspection program aimed at making
noticeable presence on the territory of the supervisory board and to combat undeclared work
, detected on the basis of failure prior notice required -
employment relationships subject to that regime - and the lack of any other written,
documentation or communication, encouraging and promoting the emergence legality,
also taking the preventive measures and promotion of Article 8 of Decree Law No
124, 2004.
On the other hand, not only access to inspection in itself but even more delicate phase
acquisition by workers of the statements requires a peculiar attitude by the inspector
, radically different from that generally held to date. The inspector will have to
behavior and attitudes toward the worker as one who asks a
constructive collaboration: If it is true that the inspector may require and expect, to the powers conferred to him
Information workers employed and found him at work, however
attitude with regard to the employee issuing the statement, especially in the case
situations of illegal or undeclared, it must be lived on the contrary, in the sense of
"ask for help" to the employee and not to address him as someone who needs help
.
This is, as you might guess, to establish a positive psychological climate and collaborative
allows the employee to feel safe and not in awe. In this sense, care is taken to acquire
the statements in such a way that preserves the "respectability" in respect of its
colleagues and employer, and that allows the consumer to understand the utility of
inspection of its condition of life and the characteristics of its
work of their colleagues, and the same company.
This cooperative atmosphere will also put in place, always in a logic of service and
transparency of public administration, also against employers
inspected, making sure, in this regard, to distinguish the offender or the offender
occasional and episodic, drawings by the man who pursues elusive crime or large-scale
while in the second case (to be repressed at every level and with full cooperation between
various agencies and bodies) will presumably encountered a particular strength,
also technical and legal, and scientific and systematic concealment of evidence of irregularities in the first case
can help an attitude - even in the timely prosecution of violations found
- is not particularly fierce. In this sense it may be useful
research collaboration of the employment counselor or other professionals and professional entities
, particularly to understand the limits to the employer and the qualifications
offense, often rooted in micro and small enterprises , more superficial attitudes or lack of awareness that
in a real and persistent desire elusive. In this perspective, it is desirable
pose of supervision for purposes of prevention, strengthening and
identification of positive behaviors, or even more knowledge and attention to the problems
firm (for example, on the side of safety).
statements acquired by workers aided inspection activity only in the valley, in
phase of the investigation, while the immediate opening of the inquiry, the test queen, a foundation for subsequent
any errors found and identified, will only
verbalization first access. The minutes of the first access inspection becomes, therefore, is not it
and its obligation for the inspection staff who access the company, which should take care to specify exactly
, in this first verbalization
be delivered in the original inspection, the facts under investigation , with particular regard to
workers found him at work, places of work, the situations that occurred in the presence of inspectors
. Particular emphasis will acquire
evidence, including the continuation of the investigation, besides
for any administrative and judicial phases of litigation, the exact identification of
workers (when possible through the presentation of a document identity), the
accurate description of the work activities carried out by workers identified at the time of access
inspection (including work-related clothing, cards or identification
equipment or machines used).
than the minutes of the first well-drafted will allow the inspectors access
Administration to defend every seat in the outcome of inspections. On the other hand, only
verbalization that the employer will know the facts on which will be fully investigated to ensure complete
of his constitutional right to defense.
Also in the inspection report must first access find out requests
documentary, with special attention to the book's unique work, moving
supervision or employment counselor or professional service or assisting him or
service center of the trade association which has entrusted.
Finally, the first verbalization must make an express reservation of objection and notification
administrative offenses occurred only after the investigation and after formal notice
mandatory where applicable.
In the new organization of inspection services, however, the simplification
legislation also requires a reduction of red tape related to the inspection process. The Directorate
General for Inspections will take care of the special forms
formalize a simplified, unified and unique, ensuring, in compliance with Law November 24, 1981, No
689 and of the aforementioned Legislative Decree 124, 2004, the obligation for officials to draw up
inspection (and for the inspection of being notified) a single measure
sanctions, the statement, and notification, which will be followed by the minutes of the first
access and which contains the outcome of the investigation and, simultaneously, the ability to settle the wrongful
through compliance with the notice and payment of the penalty for violations
very small or do not doubt through conciliation and administrative
the reduced payment, and the indication of additional tools
defense and bodies on which it is possible to appeal, with appropriate specification
terms of its appeal.
still remain, of course, any judicial police measures (compulsory requirement under Article 15 of Legislative Decree No. 124 of 2004) or the possible
to suspension of business activities (Article 14 of Legislative Decree 9 April 2008
, No. 81, as amended by Decree Law No. 112 of 2008), which will add to
simplified administrative sanctions.
regard to suspension of business activities, however, it seems appropriate to recall
the opportunity to take this serious action, criminal penalties in case of non-compliance with the penalty
arrest up to six months, so as not to create
intolerable discrimination, but also so as not to punish maddeningly microenterprises.
In this perspective, the inspector's discretion in the adoption of
measure shall be restricted solely to the verification of compliance with the condition
law and terms of actual risk over a range of protection and prevention
health and safety of workers. It is believed, therefore, that the suspension can be
normally adopted with effect from 12 am the next day or
access inspection, construction and agriculture, the cessation of ongoing activities that can not be usefully
stopped, unless there is a danger imminent or serious risk to the health of workers
or third parties, in which case the order of suspension should be given
with immediate effect. On the other hand, as regards the percentage of workers "
black", it is considered that found in micro-enterprises with one employee illegally occupied
are not normally subsisting protection of the essential requirements referred to
Legislative Decree No 81 of 2008 such as to lead to suspension. The mode of assessment
ascertainment of violations, criminal and administrative
found during the inspection staff of the supervisory activities should take care to maintain the attitude shown above
throughout the inspection. Duties of the labor are, in fact,
both the protection of the employee, as the guarantee of fair competition between businesses
, which are combined with the timely indeed penal, but also and perhaps especially
, with the prevention of self and the promotion of
more widespread and deeply rooted culture of legality.
The profound changes and simplifications introduced by Decree-Law 112 of 2008, ratified by Law No
133, 2008, in the field of formal requirements, suggest
as a prerogative of inspections for the detection of substantial violations.
In this sense it may be useful in the process of inspection access, enhancing the experience and sensitivity
inspector and his knowledge of the business (even
field on which to develop specific training activities). In this way, the actors of supervisors must be able to perceive and grasp
, with careful observation and immediate peculiar aspects of the functioning of the organization
business on which to perform and direct the next
findings, also in documentary.
In this perspective, abandoning any formalistic logic of the past, based on
number of violations found and the formal nature of them, one must also
enhance the quality of supervision and inspection activities in the strict sense, starting from methods of completing
investigations in certain sensitive areas.
checks on coordinated and continuous collaboration and joint ventures with contributions of work. With regard to contracts of continuous and coordinated collaboration in
any way even after the project, and joint ventures with contributions of work
to focus exclusively on the inspection finding those who were not already
vetted by a committee of the certification referred to in Article 76 of Decree No legislative
276, 2003, certified as a positive or still under evaluation,
unless it emerges with no immediate evidence and questionable
the apparent inconsistency between the contract certificate and the practical arrangements for implementing the employment relationship.
contracts in respect of the uncertified labor inspector shall acquire, by comparing the contents
program negotiated with the statements made by the employee concerned and the
others who may have the same work together, all the elements to assess the correct
qualification of employment, in line with what is stated in Circular No.
No 1 of 2004 and 17 of 2006 (without regard to the listing of assets and foreclosures
contained in Circular No. 4 of 2008, a total believed to be inconsistent with
the plant and the aims of the "Biagi Law"), specifically highlighting them in the record
detection and notification by which it fails to the autonomous nature of the relationship
investigated, thereby countering the fraudulent use of contract collaboration. Collaborations
coordinates will be certified only after the audit request
intervention of the worker concerned and so far have failed prior attempt at conciliation
single judge. Checks on flexible employment relationships. Even under the supervision on
flexible work contracts (fixed-term employment, part-time, intermittent, occasional)
the attention of the inspectors will have to focus only on non-certified contracts. The
checks should be aimed at countering the misuse of contractual institutions in
topic, especially as regards the use of worker outside the system of contracted
flexibility and consistency with the guidelines and interpretation guidelines provided by the Ministry
. Contracts certificates may be subject to audit only after
a claim of the worker and after a failed attempt at reconciliation
single judge. Checks on the organization of work. The utmost caution should guide officials
inspection approach to supervision in the field of organization of working time arrangements
. The intervention of the legislature by Decree Law No. 112 of 2008, enacted with
changes, with the Law 133, 2008, marked a secure extension
flexibility in the arrangements of the time, in line with the EU directives in force, in
compared with a reduction of penalties for violations.
In this perspective, the team shall consider the regulatory framework in the next collective bargaining
, including business, in order to legitimately contest the violations found
respect to the legal regime in force in the company. Controls on illegal contracts. The contracts and subcontracts shall be subject to
specific and careful examination by inspectors of the work, not only in the context of
construction industry, but in every productive sector of goods and services. The activity investigation, however,
will focus on contracts that were not subject to certification. Objective
absolute contrast to the illegal and fraudulent interposition, by verifying the existence of
criteria of authenticity under Article 29 of Legislative Decree No 276, 2003. Supervision of disadvantaged groups and occasional work accessories. Will not be forgotten that the
special vigilance with regard to that fundamental social legislation which is given by
all the labor laws protecting the disabled, minors and foreigners as well
of women with particular reference to women in a state of pregnancy and the phenomenon of so-called
blank resignations. In this perspective, it appears appropriate that a special
organizational structure of the inspectorate of the provincial work
each be devoted to supervision and inspection efforts in these matters. Similarly, you will have to pay attention to
promotion and accompanying regulatory institutions
contrast to undeclared work, as in the case of an occasional accessory, making
then followed closely the operations supervisor who repress the unlawful conduct of those who do not
seizes the opportunity to start and use regular forms of casual work
through the use of so-called good work. Watch for the protection of health and safety at work. Finally, special attention
will devote themselves to matters of health and safety at work. Pending further guidance,
the light of the confrontation started on with the Regions and the social partners, it is noted from now
that, as the powers of inspection services of the Ministry are limited to only
some areas, inspectors work can not be exempt from reporting to the company
local health authority, in a logic pro-active and sincere cooperation
institutional situations of doubtful regularity in which appalesano
during a regular inspection on finding work in companies operating
in sectors and activities outside those specified in Article 13, paragraph 2, of Legislative Decree No 81, 2008. Beware
established
From another perspective, it drew the attention of the inspection staff to the adequate
the formal adoption of the instrument established for capital credits
the worker referred to in Article 12 of Legislative Decree No 124, 2004. It is, in fact, a power
extraordinary importance given to the inspectors the work that can contribute to recognize the
worker satisfaction faster monetary claims receivable
against the employer as a result of the employment relationship. Grants &
public benefits
The development of a transparent and inclusive labor market requires careful control
not only on the enforcement of regulatory constraints, but also the use of (scarce) public resources
to their optimum and correct usage in favor of vulnerable groups and categories of workers
truly disadvantaged. In this perspective, the labor inspector
becomes a judge of the legality of the labor market at 360 degrees, working with
particular attention to the effectiveness of training and employability plans
economic incentives (such as the contract of apprenticeship or
contract work placement), but also with regard to workers who enjoy the benefits
arising from the implementation of social safety nets, in order to avoid unfairness to
treatment and to apply the basic rule of liability, introduced by Legislative Decree No
276 of 2003, who wants sanctioned with the loss of benefits or indemnity from
the worker who receives treatment or waste an opportunity to
fair job or a training and retraining. Similarly
must operate with absolute strictness in the inspection, even compared to the relief of the underlying assumptions
of crime in respect of workers receiving health care treatment, or insurance
allow themselves to take up pension 'black' conniving with employers.
Inspection bodies are therefore required to give full and complete implementation of Circular No.
5 of 22 February 2006, whose implementation is a fundamental prerequisite for the modernization of the Italian welfare system in a logic of workfare. In order to avoid possible loss of revenue and
evasive behavior refers to the need to check with particular attention
agencies accredited or otherwise authorized to work
administration of Articles 4, 5, 6 and 7 of Legislative Decree No 276 of 2003, we promptly notified
INPS and service for the use of local
authority cases where workers have rejected an offer, or work
reintegration into the labor market under Article 13 of Legislative Decree No 276 of 2003 and Article 1 of Decree-Law-d 5 October 2004, No 249,
ratified with amendments by Law No 291, 2004.
Prevention, promotion and transparency of the audit action
The effectiveness of inspection measures in a given province, is measured in
account of the estimate of undeclared work in that same area is eliminated, and the situations
regular management reports work that you find.
To this end, it seems essential to a serious and continuing investment by the provincial directorates
work in direct coordination with the competent Regional Directorate and
with the Directorate General for Inspections, in the actions of prevention and promotion of
Article 8, paragraph 1, of Legislative Decree No 124, 2004. These actions will result in
special initiatives at least once a month, even at
category associations or individual employers, with reference to matters and issues of relevance
general in order to guarantee and ensure full compliance with legislation
on work and welfare or to disseminate the correct application of new institutions in accordance with the legislative
interpretative guidance from the administration. If
instead of the inspector participate in seminars or conferences initiatives for reasons not
institutional care or service will have to specify (and ask that you specify in
on posters and promotional brochures) that the intervention is carried out under
staff and that the views expressed do not necessarily represent those of the institution to which they belong.
Also in this perspective points to the importance of proper use and dissemination of a wide
Institute of interpellation, and the possibility for Directions regional
the Provincial Directorates of Labour and social security institutions, also in agreement with each other, to carry out information and update
to institutions, employers associations and
at the expense of the same pursuant to the provisions of Article 8, paragraph 3, of Legislative Decree No
124, 2004. Nor, on the other hand, can be neglected
the centrality of training for all inspection personnel, ministerial and social security, against which
it is for the Directorate General for Inspections, using the Research Center established its Inspection Activities
internal training initiatives to ensure
at least every three months, all aimed at the inspection staff, including through electronic instrumentation to
distance, taking into account new legislation, practice and jurisprudence.
Particularly important is the involvement of other agencies and institutions in social security
achievement of these educational opportunities.
Maximum confidentiality and transparency of action of individual inspectors - and bodies
managers in particular - is finally a profile of key importance. The
trust and credibility that the inspection services will benefit from the fact
category are the most valuable resources for the efficiency and effectiveness of surveillance activities.
To achieve this goal of transparency require that those responsible for inspection
operate with maximum transparency and fairness, not only in strict compliance with the Code of conduct
"approved by Decree of 20 April 2006 and the provisions of the Decree of
President of the Council of Ministers of 28 November 2000, but also by adopting
with all stakeholders and interested groups to conduct a comprehensive inspection
suited to the role and functions covered in any case to avoid any suspicion of partiality and indulgence
, want to enterprises and their advisers, either to the workers and their representatives
unions.
Rome, 18 September 2008 Maurizio Sacconi
