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Exhibit 11

[TELESTET LOGO]

CODE OF ETHICS OF THE GROUP

In Agreement with the Code of Ethics
of the Telecom Italia Group





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[TELESTET SMALL LOGO]

CODE OF ETHICS OF THE GROUP

In agreement with the Code of Ethics of the Telecom Italia Group

Article 1  Premise



| |  | Both internally and externally, the activity of the
Telecom Italia Group is based on observance of the
principles set out in this Code, in the belief that
ethical business conduct is also a condition for a
firms success.
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| |  | Telecom Italia has accordingly adhered  and encourages
all the companies in the Group to adhere  to the Global
Compact promoted by the United Nations with regard to
human rights, the environment and labor standards.    

Article 2  Objectives and values



| |  | The primary objective of the companies belonging to the
Telecom Italia Group is to create value for their
shareholders. Industrial and financial strategies are
oriented to achieving this end, as is the consequent
conduct of operations, based in turn on the efficient
use of resources.
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| |  | Group companies:                                                                                                                                                                                                                                                                            

| |  |  | are committed, as active and responsible members of the community,
to observing the laws in force in the countries in which they operate
and the ethical principles commonly accepted in the conduct of
business: transparency, correctness and fairness;                                                                                                                                    
| |  | - | ---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
| |  |  | reject and stigmatize recourse to illegal and improper conduct
(vis-à-vis the community, public authorities, customers, workers,
investors and competitors) in order to achieve their business
objectives, which they pursue exclusively through the excellence of
their products and services in terms of quality and cost-effectiveness,
based on experience, customer care and innovation.
| |  |  | adopt organizational solutions serving to prevent violations of the
principles of legality, transparency, correctness and fairness by their
employees and collaborators and take steps to ensure they are applied
and complied with in practice;                                                                                                                                             
| |  |  | ensure, while safeguarding the competitive strengths of their
businesses, that the market, investors and the public are fully
informed about their actions;                                                                                                                                                                                                                                  
| |  |  | make every effort to promote fair competition, which they believe
to be in their own interest and in that of all the other firms
operating in the market, their customers and their stakeholders;                                                                                                                                                                                            
| |  |  | pursue excellence and competition in the market and provide their
customers with high quality services that meet their needs efficiently;                                                                                                                                                                                                                                                    
| |  |  | are aware of the strategic importance of the services they provide
for the well-being and growth of the communities in which they operate;                                                                                                                                                                                                                                                   
| |  |  | protect their human resources and enhance their quality;                                                                                                                                                                                                                                                                                                                                     
| |  |  | use material resources responsibly, with a view to achieving
sustainable growth that respects the environment and the rights of
future generations.                                                                                                                                                                                                                                          





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[TELESTET SMALL LOGO]

Article 3  Shareholders

Group companies are committed to ensuring equal treatment for all classes of
shareholders and avoiding biased behavior. The reciprocal advantages that come
from belonging to a group are pursued in accordance with the provisions of the
applicable law and without prejudice to the interest of each company in
creating value.

Article 4  Customers

The excellence of Group companies products and services is founded on the
attention paid to customers and the willingness to satisfy their requests. The
ultimate aim is to guarantee an immediate, capable and competent response to
customers needs, in a correct, courteous and helpful way.

Article 5  The community



| |  | Group companies aim to contribute to the economic
well-being and growth of the communities in which they
operate by providing efficient and technologically
advanced services.                                                                                                                                                                                                      
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| |  | Consistently with this objective and with their
responsibilities towards the various stakeholders,
Group companies consider that research and innovation
are essential to their growth and success.                                                                                                                                                                                 
| |  | Compatibly with their nature of commercial enterprises
and the consequent need for their operations to be
economically efficient, in their choices Group
companies consider the social importance of
telecommunications services and endeavour to meet the
needs of the entire community, including the weakest
members.                                                            
| |  | Aware of the importance of the services they provide
and the consequent responsibility towards society,
Group companies maintain relations with public
authorities at the local, national and international
levels based on full and active cooperation and
transparency, in conformity with their respective
roles and the economic objectives and the values set
out in this Code.
| |  | Group companies are well-disposed towards, and where
appropriate, provide support for social, cultural and
educational initiatives aimed at developing the person
and improving living standards.                                                                                                                                                                                   
| |  | Group companies do not make contributions of any kind
to political parties or trade unions or to their
representatives or candidates, subject to the
provisions of the applicable law.                                                                                                                                                                                              

Article 6  Human resources



| |  | The companies of the Telecom Italia Group recognize
the central role of human resources, in the belief
that the principal factor in the success of every firm
is the contribution made by those who work for it, in
a context of fairness and mutual trust.                                                     
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| |  | Group companies protect their employees safety and
health at the workplace and in the conduct of their
business consider respect for workers rights to be of
fundamental importance. Personnel management within
the Group aims to ensure equal opportunity and to
promote the development of each individual.





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[TELESTET SMALL LOGO]

Article 7  The environment



| |  | The companies of the Telecom Italia Group are
convinced of the need for sustainable growth at global
level, in the interest of all todays and tomorrows
stakeholders. Their investment and operating choices
therefore always take into account the need to protect
the environment and public health.                                     
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| |  | Subject to the specific provisions of the applicable
law, Group companies take environmental issues into
account in arriving at their decisions and, wherever
operationally and economically feasible, adopt
eco-friendly technologies and methods of production,
with the aim of reducing the impact of their
activities on the environment.

Article 8  Disclosure of information



| |  | Group companies are aware of the importance of correct
information about their activities for the market,
investors and the community as a whole.                                                                                                                                                      
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| |  | Subject to the need for confidentiality in running
their businesses, Group companies make transparency an
objective in their dealings with all stakeholders. In
particular, they disclose information to the market
and investors in accordance with criteria of
correctness, clarity and equal access.

Article 9  Compliance with the Code



| |  | The governing bodies of all Group companies, their
managements and all those who work for them are
required to observe this Code.                                                                                                                                                                                                                   
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| |  | The companies of the Telecom Italia Group are
committed to implementing the procedures, rules and
instructions serving to ensure that the values
embodied in the Code are reflected in the conduct of
each company and in that of its employees and
collaborators, with provision made, where appropriate,
for a system of sanctions for violations.