As part of the ethical management of controversial sectors, the activities implemented by the BPER Group to reduce negative impacts and enhance positive social impact initiatives are described below.

Fight against compulsive gambling
We have implemented initiatives to inform, prevent and initiate actions to counter the practice of pathological gambling (GAP) and created two informative Vademecums to prevent and counter the risks associated with this pathology.

Policy on arms

The relationship between banks and operators in the military sector has been the subject of attention by Italian civil society for some time. For this reason, and in line with the principles of the Code of Ethics, starting from 2012, the Bank has adopted the “Linee Guida di Gruppo per la regolamentazione dei rapporti delle banche del Gruppo BPER con gli Operatori della difesa e le Imprese produttrici di armamenti”. With these guidelines, banks of the BPER Group have adopted a self-governance that regulates, more stringently than required by current legislation, their presence in this sector. In particular, in relation to transactions supporting the import/export of arms, Banks of the Group have decided to adopt internal rules that establish which transactions can be authorised and which cannot, without enforcing an absolute prohibition.

Therefore, Group banks may be included in the annual Reports drawn up by the Presidency of the Council of Ministers pursuant to Law 185/90 (which sets specific limits on the export, import and transit of specific types of weapons), in relation to transactions that, according to the Group, minimise the risk that the goods produced or services rendered be destined to parties other than those with democratic governments. Moreover, the Guidelines also govern other types of transactions, such as loans, for which the banks of the Group must report the key aspects of the relationship between the credit institute and defence operator. In fact, the Group’s banks agree to publish an annual statement highlighting the activities that the BPER Group has carried out with companies that operate in the defence sector. This annual report is published, along with the guidelines, on the Group’s website (sustainability section).

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Transactions in Physical Gold

Among the services offered to customers, the Bank offers Gold trading. BPER Bank trades only gold bars produced by refineries that hold international certifications attesting to compliance with due diligence practices on their suppliers and registered on the London Good Delivery list, recognized internationally as the market standard.

It is thus guaranteed that the metal being sold is Conflict Free and complies with the regulations and codes of conduct prepared by the main industry association bodies (LBMA, RJC) and international bodies (OECD); it is also ensured that suppliers are equipped with tools for the control and evaluation of gold purchasing chains, in order to combat possible forms of crime both geopolitical-financial (anti-money laundering, corruption, financing of terrorism) and related to human rights abuse, genocide, exploitation of child labor or crimes against the environment.

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