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 in monitoring the efficient implementation of the principles of monitoring, organisation and conduct envisaged by the Model. Also in this context, the Internal Auditing Department has launched a complex project to adapt structures and processes, which will ensure a further refinement of the overall management quality (I.A.T - Internal Audit Transformation project).
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. The subsidiaries operating in countries where national "anti-corruption" laws don't exist are in any event expected to apply the Parent Company principles 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 Model and Anti-money Laundering controls, in 2016 a specific "Anti-Corruption Project" was launched, covering two fundamental areas:
"customers" – to identify any possible risk aspects of customers' behaviour and thus ensure ongoing cooperation with the authorities and action, as part of controls already in place, to combat money laundering and the financing of terrorism;
the "Bank" – to consolidate internal controls for preventing risk aspects in the Bank's conduct through its officers, top management, employees, external staff and suppliers. In this framework, Group Anti-Corruption Guidelines have been defined and issued to company bodies.
Furthermore, Group's policies do not allow sponsorships or donations in favour of political parties and movements and their organizational structures.