Company’s administrative responsibility

The Bank has an organisation and operating model in accordance with Legislative Decree 231/2001, and subsequent amendments and additions, on matters of the company’s administrative responsibility for crimes committed by its employees and collaborators, which is constantly updated in compliance with new standards issued as time goes by.

In accordance with the aforementioned decree, an Auditing Committee has also been set up – comprising  the Manager of Corporate Risk Management, the Coordinator of Staff Functions, the Manager of Compliance Function, the Manager of the Legal Advisory Office and an indipendent member of  proved professional and moral attitude.

The Bank’s “System of Internal Audits” (SIA) is made up of the system of rules, procedures and organisational structures which aim to ensure the observance of the business strategies as well as the effectiveness and efficiency of the processes, the defence of the value of the activities, the reliability and integrity of information and conformity to internal and external provisions. The SIA is summarised in an articulate document which is regularly updated and submitted in its entirety for approval by the Board of Directors every year. 

Over the years the Bank has complied with various codes of conduct, including the code of conduct of the Italian Banking Association of the banking and financial sector, the internal code of self-discipline on matters of financial dealing, the code of conduct in relationships between bank-business in difficulty, the code of conduct of mortgage loans.

The Bank also has a Code of Ethics emphasising its desire to confirm, with increasing effectiveness, the fundamental ethical principles which must permeate every operating process and every form of conduct of those who work with the Bank. The code has been disseminated on a widespread basis, through several channels, within the structure and among the suppliers/collaborators of the Bank. The Code of Ethics envisages instruments and supervision for its application, as well as sanctions for breaches of the provisions and principles contained within it. Confidentiality is classed as a vital principle for the Bank’s activity. The information acquired must remain strictly confidential and appropriately protected, and may not be used, communicated or divulged other than in observance of the legislative currently in force and the company procedures.

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