The Bank has adopted strict internal procedures over time to prevent the risk of corruption and extortion. In addition to what is specifically envisaged by the Code of Ethics, the Group's Internal Code of Conduct and by the Organisation, Management and Control Model pursuant to Legislative Decree 231/2001 on the administrative liability of entities, there is a detailed set of internal regulations - which all personnel must know and comply with - which outline the corporate processes potentially leading to the committing of this type of crime. The Compliance, Audit and Internal Control Departments must ensure ongoing consistency between the control and conduct principles set out by the 231 Model in terms of corruption and the internal regulations in force, also ensuring compliance with said principles.
Attention to the prevention of corruption risks is very high across all Group companies, both in Italy and at the International Subsidiary Banks, particularly those operating in countries that have specific “anti-corruption” laws. In countries without such regulations, the subsidiaries are in any event expected to apply the Parent Company guidelines and perform controls in areas of greater risk.
Lastly, with regard to Legislative Decree 231/01, the new crime of “self-laundering” was introduced into Italian law in December 2014. This new crime was included within the scope of “assumed” crimes the perpetration of which by an employee results in administrative liability for the employee's company as well. Therefore, the necessity to adapt the 231/01 Model will be assessed in 2015, identifying any processes “at risk” and envisaging, if applicable, specific control and conduct principles valid for all employees.
Moreover, the Group's policies do not allow sponsorships or donations to political parties and movements and their organisations.