The Internal Control Committee monitors the implementation of the Code of Ethics - the regulatory reference for the integration of social and environmental considerations in the corporate processes, practices and decisions - and reports to the Supervisory Board. The Committee receives periodic reports from the Corporate Social Responsibility (CSR) Unit on the outcome of control activities performed in line with provisions of the Group Compliance Guidelines and in reference to the UNI ISO 26000 standard. The control process of the Code of Ethics - integrated with the management processes underlying the Sustainability Report (stakeholder engagement and listening, definition of improvement objectives, monitoring implementation via KPIs and, lastly, reporting) - envisages an evaluation and a third-party assessment. The statement on the CSR governance level in the Intesa Sanpaolo Group provides an illustration of the method applied and the results, with separate assessment of respect for human rights. Following the controls, CSR also reports on the corrective measures implemented by the departments and on any serious non-compliance and anomalies, where necessary in agreement with the Compliance and Internal Auditing Head Office Departments.

The control process for the application of Italian Legislative Decree 231/2001 also envisages that the reporting of the crimes referred to in the Decree - including corruption, money laundering, terrorism-related crimes - must be (by employees) or can be (external staff: advisors, suppliers, trade partners) sent, also in anonymous format, directly to the e-mail address of the Supervisory Authority or via the Internal Auditing Department, both independent control bodies, thus implementing a complementary whistleblowing procedure to that for the Code of Ethics.

The management of reports of non-compliance with the Code of Ethics is regulated by company regulations and protects those who make the reports in good faith from any form of retaliation, discrimination or penalisation, ensuring the utmost confidentiality without prejudice to legal obligations. The CSR Unit receives and processes the reports, which can be submitted by any stakeholder and, after assessing them, takes action in collaboration with the departments affected by the reports.

In 2015, 66 reports of non-compliance with the Code of Ethics were received: 53 refer to Italy and 13 abroad. The absolute number has declined compared to the previous year, confirming the trend over the past three years that, by now, has seen this evidence category decrease. The majority of these reports (54) was from customers and the highest frequency of issues was associated with branch and service accessibility, often in relation to population ageing, and with the expected responsible conduct in the credit granting, management and recovery in subjective and fragile situations. In this regard, during the year a test was conducted on three particularly critical reports, encouraging further attention in maintaining the credit in the event of particular difficulties in the customer’s life. Every report was assessed in cooperation with the departments responsible to verify their accuracy and a response was provided to each one. All the formal complaints from employees received during 2015 were managed before the end of the year. Generally speaking, non-discrimination issues are constantly and carefully monitored. In 2015 the Code of Ethics mailbox received one report complaining of discrimination, as such attributable to the issue of human rights and concerning a case of alleged discrimination in the workplace. An in-depth study was conducted that excluded discriminatory intent, reaching a satisfactory conclusion for the interested parties. Through a message sent to the Code of Ethics mailbox, a request was received to adopt a responsible approach in assessing loans to companies that are not environmentally-friendly. In relation to environmental issues, no formal reports were received by the Code of Ethics mailbox.