Why this issue is significant 

The Intesa Sanpaolo Group recognises the strategic importance of activities to ensure compliance with internal and external regulations and codes of conduct, in the belief that respecting standards and fairness in business are essential elements in carrying out banking operations, which by nature are based on trust. We believe that compliance with standards encourages the creation and maintenance of a soundly competitive economic context, in which merit can be measured and shared value can be created, contributing to the area and community development. Intesa Sanpaolo aims to be a reliable, qualified contact for the regulators, relating with these in a transparent manner and helping to develop the regulatory context through the identification of common objectives for banks and stakeholders. The Group actively supports the United Nations’ Global Compact principles that envisage the development of activities to combat corruption and to protect rights in the global context.

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Results achieved

Anti-money laundering has been further enhanced, aligning company regulations with the control and conduct principles envisaged by the 231 Model, now even stricter as a result of the provisions of Italian Law (Law 190/2012). New monitoring aspects have been introduced for money laundering and tax risk to which the Group is exposed on entering new markets, and new tax risk management and monitoring rules have been defined in relation to transactions executed with customers resident for tax purposes in other countries.

How it is managed 

We pursue the respect for rules through synergic operations between all company departments. The operating and business units are required to abide by company processes and procedures, verifying their application with suitable controls, with a view to full compliance with applicable regulations and standards of conduct. We promote a corporate culture founded on integrity (honesty, fairness and responsibility) and substantial compliance with regulations, and we disseminate a management culture aware of the risks and individual responsibilities, also through numerous employee training initiatives. The Compliance Guidelines provide a detailed description of the compliance risk management processes. Rules to prevent corruption form an integral part of the internal regulatory sources: Code of Ethics, Internal Code of Conduct, Organisational and Control Model pursuant to Italian Legislative Decree 231/01; company processes potentially instrumental to committing corruption-related crimes are identified and specifically regulated. The Compliance and Audit departments constantly verify the consistency between the control and conduct principles stated in the 231 Model, including those relating to corruption, and the internal regulations in force, and guarantee compliance with these.

Departments/Functions in charge

The Parent Company Corporate Bodies are responsible, each to the extent of their own duties and prerogatives, for ensuring suitable monitoring of compliance risk to which the Group is or could be exposed. In Intesa Sanpaolo the duties assigned by Regulators to the compliance function are handled by the Compliance Head Office Department, a permanent and independent department with its own resources and duties that reports directly to the Corporate Bodies. For specific regulatory areas the risk monitoring activities are assigned to Specialised Functions, required to adopt the methods envisaged in the Compliance Guidelines. The Antitrust Affairs and Strategic Support Service, the Safety and Protection Unit, the Anti-money Laundering Service, the Administration and Tax Department and the Employment Policy Department operate to guarantee the correct application of antitrust, privacy, occupational safety, anti-money laundering, tax and employment regulations. For all areas, the Internal Auditing Department performs controls on the regular nature of operations and on monitoring adequacy and efficiency, proposing any corrective action required.

Performance indicators and objectives achieved

Indicators 2014 progress status
Specialist training to prevent corruption and money laundering
  • 53,504 employees trained (Italy 43,495; abroad 10,009)
  • 60.2% of employees trained (Italy 67.2; abroad 41.4)
Associated risks Opportunities
  • the process and procedural changes to adapt to regulatory requirements could cause discontinuity that has a potential impact on service to customers;
  • the impact of regulatory changes can force an increase in operating costs
  • cases of non-compliance and failure to adapt can result in fines and penalties  
  • thorough advocacy activity, by interacting with authorities and regulators, helps to identify common objectives for the Group and for stakeholders
  • adaptation to all consumer protection requirements guarantees that our processes are designed to deal with our customers honestly and fairly, supporting our ability to acquire and retain them.