The Internal Control Committee monitors the implementation of the Code of Ethics - the broader regulatory reference due to the integration of social and environmental considerations in the corporate processes, practices and decisions - and reports to the Supervisory Board. The Committee receives periodic reports from the Corporate Social Responsibility (CSR) Unit on the outcome of control activities performed in line with provisions of the Group Compliance Guidelines and in reference to the UNI ISO 26000 standard. The control process of the Code of Ethics - integrated with the management processes underlying the Sustainability Report (stakeholder engagement and listening, definition of improvement objectives, monitoring implementation via KPIs and, lastly, reporting) - envisages a self-assessment by the department heads and a subsequent third-party assessment which, following onsite verification of the self-assessment results, issues a statement on the CSR governance level in the Intesa Sanpaolo Group that provides a transparent illustration of the method applied and the results, with separate assessment of respect for human rights. Following the controls, CSR also reports on the corrective measures implemented by the departments and on any serious non-compliance and anomalies, where necessary in agreement with the Compliance and Internal Auditing Head Office Departments.
The process for managing non-compliance with the Code of Ethics is encoded in corporate policy, protects those who make the reports in good faith from any form of retaliation, discrimination or penalisation, ensuring the utmost confidentiality without prejudice to legal obligations. The CSR Unit receives and processes the reports, which can be submitted by any stakeholder and, after assessing them, takes action in collaboration with the departments affected by the reports, always under the supervision of the Internal Control Committee.
The control process for the application of Italian Legislative Decree 231/2001 also envisages that the reporting of the crimes referred to in the Decree - including corruption, money laundering, terrorism-related crimes - must (by employees) or can (by external staff: advisors, suppliers, trade partners) be sent, also in anonymous format, directly to the e-mail address of the Supervisory Authority or via the Internal Auditing Department, both independent control bodies, thus setting up a complementary whistleblowing procedure to that described above for the Code of Ethics. In 2014, 67 reports of non-compliance with the Code of Ethics were received:
Reports of non-compliance with the Code of Ethics
60 refer to Italy and 7 abroad. The absolute number has declined compared to the previous year, confirming the trend over the past three years that has seen this evidence category decrease. The majority of these reports (59) was from customers and the highest frequency of issues was associated with branch and service accessibility and with the expected responsible conduct in the credit granting, management and recovery in subjective and fragile situations. Every report was assessed in cooperation with the departments responsible to verify their accuracy and a response was provided to each one. All the formal complaints from employees received during 2014 were managed before the end of the year. Generally speaking, non-discrimination issues are constantly and carefully monitored. In 2014 the Code of Ethics mailbox received 2 reports complaining of discrimination, as such attributable to the issue of human rights - one complaining of nationality-related discrimination in access to credit, and the other of alleged discrimination in the workplace. In both cases, in-depth study was conducted that excluded discriminatory intent, with both situations reaching a satisfactory conclusion for the interested parties. One area of potential discrimination, arising in relation to non-recognition of paid leave, also for same-sex marriages, was avoided by the issue of rules targeting an inclusive approach. Through a message sent to the Code of Ethics mailbox, a request was received to take a responsible approach in assessing loans to companies adopting business plans with a heavy social impact on workers and the local area. In relation to environmental issues, no formal reports were received by the Code of Ethics mailbox.