The Bank has adopted strict internal procedures over time to prevent the risk of corruption and extortion. In addition to what is specifically envisaged by the Code of Ethics, the Group's Internal Code of Conduct and by the Organisation, Management and Control Model pursuant to Legislative Decree 231/2001 on the administrative liability of entities, there is a detailed set of internal regulations - which all personnel must know and comply with - which outline the corporate processes potentially leading to the commission of this type of crime. The Compliance, Audit and Internal Control Departments ensure ongoing consistency between the control and conduct principles set out by the 231 Model in terms of corruption and the internal regulations in force, also ensuring compliance with said principles.
The required attention to the prevention of corruption risks is very high across all Group companies, both in Italy and in the International Subsidiary Banks, particularly those operating in countries that have specific "anti-corruption" laws. In countries without such regulations, the subsidiaries are in any event expected to apply the Parent Company guidelines and perform controls in areas of greater risk. To complement and further strengthen the measures for prevention of corruption already in place as part of the Model 231/2001 and anti-money laundering safeguards, a specific "Anti-Corruption Project" was launched in 2016.
A regulatory document was issued at the end of 2015 which puts in place a "reporting system by the Personnel of actions or circumstances that could constitute violations of the rules governing the banking business (so-called whistleblowing)”. The Internal Auditing Department is the entity appointed to evaluate and manage the reports.
In the second half of 2015, as evidence of the Group's constant attention towards prevention and training activities on the matter, employees were given the opportunity to participate in an e-learning course focused on the culture of risk and controls.
Finally, during 2015, the Model 231/2001 was adjusted following the introduction into Italian law of the new "self-laundering" offence which was included within the scope of "predicate" offences, the commission of which by an employee entails administrative liability also on the part of the relevant company.