The Group's governance system to combat money laundering and the financing of terrorism is based on Guidelines that constitute a systematic and functional reference framework, with active collaboration by the Group in preventing said illegal activities. Specific and appropriate processes and procedures have been drawn up and are in place in terms of obligations of adequate verification of customers, reporting of suspicious transactions, recording of relations and transactions, storage of documents, assessment and management of risk, internal control and guarantee of compliance with all of the relevant provisions to prevent and impede the completion of transactions connected to money laundering or financing of terrorism. The global approach to money laundering risk at Group level, which is at the basis of its assessment and subsequent mitigation, involves the adoption of general standards and principles by the parent company for identification of and information on customers, which must be adopted and implemented by the individual companies in proportion to the characteristics and complexity of the activity carried out, size and organisational structure. Therefore, without prejudice to specific provisions of the host countries, the individual Group companies (secondary offices and branches) must respect the set standards, ensuring that information is shared at the consolidated level, with the sole limitation of any existing privacy restrictions and banking confidentiality at the local level.

Moreover, procedures that provide automatic checks on the Group's register and transactions have been active for some time now, in order to mitigate the risk of having among its customers individuals or identities included in the list of entities (black list) subject to restrictions or freezing of assets. Lastly, the Group has envisaged broader policies of a general and overall nature, beyond mere compliance with the regulations, envisaging more detailed assessments under the credit and reputational aspects that prevent the Group's involvement, in any capacity, in transactions with counterparties or countries under embargo, even if the transaction is among those permitted by the restrictive provisions issued by the international authorities.

Specialised training to prevent Corruption and Money Laundering in 2015

No. of employees trained 31,234 7,572 38,806
Training hours 128,170 29,829 157,999
% of employees trained 48.6 32.3 44.3