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Whistleblowing
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Whistleblowing

Banca Generali promotes and encourages the dissemination of a corporate culture of legality characterized by correct behavior and guarantees effective and efficient means aimed at preventing, managing, and possibly reporting any irregularities or violations of the rules governing corporate activities, through secure and confidential channels.

The Bank encourages the reporting of any behavior that, in good faith, is considered illegal, to its internal contacts (their Manager, the HR Function, contractual contacts, ...).

It is also possible to send a report through the following reporting channels established pursuant to the Whistleblowing Policy (the "Policy"):

  • Dedicated IT platform, via web or by phone (+39 02 9475 1936);
  • Email: segnalazioni.whistleblowing@bancagenerali.it;
  • Confidential and personal written communication sent to the "Head of Compliance and Anti Financial Crime Department" c/o Banca Generali S.p.A., Piazza Tre Torri 1, 20145 Milan;

These channels:

  • are aimed at the Bank's employees, self-employed workers/collaborators/freelancers/consultants/volunteers/interns who work at the Bank and shareholders/persons with administrative, management, and control functions at the Bank itself;
  • are overseen by the Head of the Compliance and Anti Financial Crime Department, who can also be requested for a meeting through the same channels.

The reporting channels are not intended for the management of non-relevant communications for which the relevant dedicated contact points are established (e.g., complaints and/or requests from third parties of a commercial nature).

Reports must concern negligent, illegal, irregular, or incorrect circumstances and conduct - in violation of the law, the Internal Code of Conduct (drawn up in line with the principles of the Generali Group Code of Conduct) or any other internal regulation - for which there is reasonable suspicion or of which one has become aware in the performance of their duties, for example relating to: administrative irregularities and accounting and tax compliance, violation of anti-money laundering and counter-terrorism financing regulations; insider trading and/or market manipulation; irregularities in the provision of investment services and activities; irregularities in the distribution of insurance products; privacy violations; violations of the organizational and management model pursuant to Legislative Decree 231/2001; violation of usury regulations; bullying and harassment; corruption; fraud.

All reports are treated with the highest level of confidentiality and the confidentiality and protection of the personal data of the reporting person and the person possibly reported are guaranteed in any case.

Good faith reporters are guaranteed and protected against any form of retaliation, discrimination, or penalization, regardless of the persons involved.

For any other more detailed aspect, please refer to the "Whistleblowing Policy".

In cases where:

  • an internal report has already been made and it has not been followed up;
  • the reporting person has reasonable grounds to believe that, if an internal report were made, it would not be effectively followed up or that the same report could pose a risk of retaliation;
  • the reporting person has reasonable grounds to believe that the violation may constitute an imminent or obvious danger to the public interest,

the competent authority for reports, including in the private sector, is the National Anti-Corruption Authority (ANAC) (see Whistleblowing - www.anticorruzione.it).