The companies in the Banca Ifis Group have their own whistleblowing system for reporting any contraventions of the rules that are actually damaging, or could potentially damage, the public interest or the integrity of the companies themselves. The Head of Internal Audit is in charge of this system.
Whistleblowers can make use of any of the following channels:
When they use any of these channels, whistleblowers are guaranteed the following legal protection:
It should be noted that the reporting party will also receive protection before any legal relationship with the Bank has begun (if the report of wrongdoing is made during the selection process or at any stage prior to contract); or during their probationary period, or after the end of their legal relationship (if the report of wrongdoing was made during this relationship). This protection also extends to facilitators; to people working in the same setting as the reporting person; to people with whom they have a stable emotional bond or relatives within the fourth degree of relationship; to colleagues of the reporting person who work in the same setting and who have an on-going relationship with that person; to businesses owned by the Reporting Person or for whom any of the above persons work, as well as businesses that operate in the same context as the aforementioned persons.
The report may relate to any form of behaviour, action or omission on the part of a person working for the company, which violates the provisions of the law and which harms or may harm the public interest or the integrity of the Parent Company and/or its Subsidiaries. The report may concern both violations already committed and those not yet committed that the whistleblower has reasonable grounds for believing may well happen.
Such violations may relate to the provisions of both Italian and European Union legislation:
A report by a whistleblower should include the following:
The following annual report on the operation of the internal process is brought to the attention of all our staff. It contains aggregated data on the results of the actions carried out after reports were received: Annual report on the correct functioning of our violation reporting (Whistleblowing) system 2022
We should add that the reporting system also includes the following methods of communication, with the same guarantees of protection as stated above in relation to confidentiality, data processing and retaliation. These can be used under certain conditions, as specified below.
A report may be sent to the National Anti-Corruption Authority (“ANAC”) if one of the following conditions applies:
ANAC publishes methods for submitting reports on its website, accessible at the following link: https://www.anticorruzione.it/, which also provides the following information:
Where the report contains information about infringements outside its area of expertise (such as criminal or tax offences), ANAC will ensure that it is immediately sent on to the relative administrative or judicial authority, including the institutions, bodies, offices or agencies of the European Union.