Whistleblowing
WHISTLEBLOWING
Banca Finnat promotes and encourages the dissemination of a corporate culture of lawfulness based on proper behaviour and guarantees the means to prevent, manage and, if necessary, report any wrongdoing or breach of the rules governing corporate activities, through secure and confidential channels. To that end, the Bank has adopted an internal reporting system (hereafter also called “Whistleblowing”) governing alleged breaches of Legislative Decree No. 231/2001 and of the national and European regulatory provisions applicable to the Bank’s activities. The internal reporting system uses IT and data encryption techniques to guarantee the confidentiality of the personal data of the whistleblower, the alleged perpetrator of the breach and other persons mentioned in the report; the Bank has also drawn up a dedicated Policy prohibiting retaliatory and/or discriminatory conduct against whistleblowers. The adopted system also allows for anonymous reporting. “Anonymous” reports, i.e. those submitted without identifying the whistleblower, are taken into account if they are adequately substantiated, i.e. if they are able to bring to light incidents and situations relating them to specific contexts.
Whistleblowers may be:
- employees and self-employed persons, as well as collaborators, freelancers and consultants working at the Bank, including during the trial period;
- shareholders and members of the administrative, management, supervisory or representative body;
- apprentices, including unpaid apprentices, and volunteers working at the Bank;
- workers or collaborators at contractors, subcontractors and suppliers, of any of the Bank’s companies;
- former employees;
- candidates for a role with the Bank, who have learned of breaches during the recruitment process or at other stages of pre-contractual negotiations, and who may be subject to retaliation.
Reports must be substantiated, comprehensive and thorough and may not be based on prejudice or preconception; they must contain the necessary information for verifying the reported incidents.
Breaches and/or wrongdoing relating to, but not limited to, the following issues may be reported:
- money laundering;
- breaching of financial sanctions regulations;
- breaching of investment services regulations;
- insider trading and/or market manipulation;
- improper use of confidential data belonging to clients or the Company;
- breaching of the Organisation Model pursuant to Leg. Dec. 231/01;
- harassment;
- fraud;
- corruption;
- breaching of the Code of Ethics.
Issues and incidents relating to, but not limited to, the following may not be reported:
- customer enquiries and complaints;
- information already in the public domain (e.g.: newspaper articles, public reports, etc.);
- complaints of a personal nature on the part of the whistleblower, claims/complaints falling within the governance of the employment relationship, or grievances related to relations with hierarchical superiors or colleagues.
Whistleblowing method
Reports can be submitted through the following channel:
The Bank provides whistleblowers with an IT reporting platform through which they can make written or oral reports, including anonymously. Through the same platform, the whistleblower may, if he/she deems it appropriate, request a one-to-one meeting with the Whistleblowing Officer.
The platform is accessed through the following link: https://digitalroom.bdo.it/BancaFinnat
The Whistleblowing Officer must send the following through the aforesaid IT platform:
- confirmation of receiving the report within 7 days of it being submitted;
- the outcome of the investigations conducted, within 3 months of confirming receipt of the report.
Given that under Legislative Decree 24/23 the Italian National Anti-Corruption Authority (ANAC) has been identified as the authority responsible for receiving and managing external reports, including anonymous reports, the whistleblower may make an external report to ANAC if, at the time of submission, one of the following conditions is met:
- the internal reporting channel is inactive or, if active, does not comply with that laid down in the law;
- an internal report was already submitted but was not followed up;
- there are reasonable grounds to believe that, if he/she were to submit an internal report, the report would not be effectively followed up or the report could lead to a risk of retaliation;
- there are reasonable grounds to believe that the breach may constitute an imminent or clear danger to the public interest.
The whistleblower may also contact ANAC to notify it of any retaliatory acts resulting from a report.
Reports to ANAC may be submitted as set out on its corporate website (https://www.anticorruzione.it/-/whistleblowing).
| Documenti | |
|---|---|
| Policy “Whistleblowing - Internal systems for reporting breaches" |  |
| Whistleblowing Privacy Notice | |
Banca Finnat is here to protect and support you along the way.
