Specific tools for the management and prevention of the risk of corruption have long been in place within the Bank. The internal regulatory sources that enable to mitigate this risk may be traced back to:
the Intesa Sanpaolo Group’s Code of Ethics
the Group's Internal Code of Conduct
the Organisation, Management and Control Model pursuant to Legislative Decree 231/01
In addition to these documents, an internal regulatory framework is provided which regulates in detail the business processes potentially instrumental to the commission of crimes of corruption.
The Compliance Department, with general reference to the subject of the Company’s administrative liability introduced by Legislative Decree 231/01, is responsible for guaranteeing the long-term existence of operating rules, procedures and practices to effectively prevent the risk of committing the offences provided for by the same Decree (so-called "predicate offences") by employees; it also provides support to the Surveillance Body/Control Committee in monitoring the efficient implementation of the principles of monitoring, organisation and conduct envisaged by the Model.
The Internal Audit Department conducts a further inspection activity within the same scope and in compliance with its mission of assessing the overall system of internalcontrols, with special emphasis on the observance of the 231 Model by the company organisational units and employees. It also monitors the activities associated with regulatory updating and alignment, as well as the activities performed to check compliance with the principles of conduct set forth by the Model, the dissemination of knowledge with regards to the content of the Model, and the correct activation of the information flows directed at the Surveillance Body for the purpose of ensuring the effectiveness of the model itself.
Great attention is paid to risks connected with corruption within all the Group companies, not only in the Italian ones, but also in the International Subsidiary Banks, particularly where specific national “anti-corruption” laws exist. 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. Completing and further strengthening the measures in order to prevent corruption, that are already in place as part of the 231/01 Model and Anti-money Laundering controls, in 2016 a specific "Anti-Corruption Project" was launched.
At the end of 2015 a policy was issued, that - in compliance with the requirements of Banca d’Italia - implements a "system of reporting by the staff of acts or facts that could constitute violations of banking regulations (the so-called whistleblowing)". The Internal Auditing Department is the body identified as responsible for evaluating and managing reports.
In the second half of 2015, an e-learning course focused on the culture of risk management and controls was made available to all employees, bearing witness to the Group's constant attention to prevention and training on this matter.
Finally, with regard to Legislative Decree 231/01, in December 2014 the offense of "self-laundering" was introduced into Italian law, which was included within the scope of the Decree 231/2001 "predicate offences", whose commission by an employee involves administrative responsibility for his company. Consequently during 2015 the Model 231/01 was adapted.
Furthermore, Group's policies do not allow sponsorships or donations in favour of political parties and movements and their organizational structures.