Inappropriate conduct reporting systems - Whistleblowing
A whistleblowing system has been in place since 2016 as a channel to directly report, under the assurance of the strictest confidentiality, any inappropriate conduct held within the BPER Group and BPER Banca.
The reports can refer to:
- violations of banking regulations;
- violations of financial regulations;
- violations of the Market Abuse Directive;
- violations of anti-money laundering and terrorist financing regulations;
- breaches that may affect the truthfulness and/or correctness of financial information (intentional or unintentional errors);
- violations of antitrust laws;
- violations of anti-corruption laws;
- violations of regulations concerning: public tenders; safety and conformity of products; protection of the environment; protection of consumers; protection of privacy, protection of personal data and security of IT networks and systems;
- fraud against one or more recipient companies or the Group as a whole.
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Who can make a report
The Whistleblowing process - complementing other reporting processes in use within the BPER Group - allows to report, under the assurance of the strictest confidentiality, any violations that damage the interest and/or the integrity of the Group and its Companies, which the whistleblower has become aware of in the context of his/her work-related activities, or on the basis of the existing legal-economic relationship the whistleblower has with the Group.
The whistleblower is protected from any possible retaliatory or discriminatory behaviour.
The following subjects can make a whistleblowing report:
- employees on a permanent or fixed-term contract;
- agency-supplied temporary workers;
- interns and associates;
- advisors authorised to provide financial services off the bank premises;
- financial agents;
- debt collectors;
- suppliers;
- freelancers and consultants who work for the Group;
- shareholders;
- persons with administrative, management, control, supervisory or representative functions.
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How to make a report
The report can be made by sending a written communication to the following e-mail address: whistleblowing@bper.it
The report must allow the identification of the whistleblower (name and surname, relationship with the company and contact details) and must contain a detailed description of the facts and conduct considered to be in conflict with the law, also indicating, where possible, the documents, the rules that are considered to have been violated and other findings useful for conducting the investigation of the disputed facts. Finally, the whistleblower has the obligation to declare whether he/she has a personal interest in making the report.
The Chief Audit Officer is the designated Whistleblowing Officer and reviews the whistleblowing reports in collaboration with the Internal Audit Function.
Internal reporting channels
The personal data and information acquired by BPER Banca will be processed by the bank in its capacity as the Data Controller and stored for no longer than 5 years from the final outcome of the whistleblowing procedure.
External reporting channels
As a priority, whistleblowers are encouraged to use internal reporting channels. External reports may also be filed directly with the relevant Authorities, if certain conditions apply.
An external report may be filed with the National Anti-Corruption Authority (ANAC), if at least one of the following conditions applies upon submission:
- the whistleblower has already sent an internal report to the Whistleblowing Officer that was not followed up;
- the whistleblower has reasonable grounds to believe that an internal report would not be followed up or that the report might lead to a risk of retaliation;
- the whistleblower has reasonable grounds to believe that the violation may constitute an imminent or manifest danger to the public interest.
External reports to ANAC may be made in accordance with the procedures set out on ANAC's website https://www.anticorruzione.it/