Whistleblowing Systems

The Intesa Sanpaolo Assicurazioni Group (hereinafter the “Insurance Group”) has an internal system for reporting acts or facts that may constitute violations of banking regulations or other unlawful conduct (Whistleblowing).

In line with the provisions of Legislative Decree 24/2023, starting from 15 July 2023, the range of possible whistleblowers was expanded. the follow subjects can make a whistleblowing report:

• employees and self-employed workers who carry out or have carried out their work at the Insurance Group;
• holders of a professional collaboration relationship, as referred to in Article 409 of the Italian Civil Code (e.g. an agency relationship), and in Article 2 of Legislative Decree 81/15 (i.e. collaborations organised by the client);
• workers or collaborators who provide goods or services or who carry out works for the benefit of third parties and carry out or have carried out their work at the Insurance Group;
• freelancers and consultants who carry out or have carried out their work at the Insurance Group;
• volunteers and trainees (paid and unpaid);
• shareholders (natural persons);
• persons with administrative, control, supervisory or representative functions (hereinafter company officers).

 

The Whistleblowing process integrates the other reporting systems and processes active within the company. It allows for reporting with the utmost confidentiality of violations that harm public interest or the integrity of the insurance group companies, of which one has become aware in the context of work or on the basis of a legal or economic relationship with the insurance group. The process protects whistleblowers from possible retaliation or discrimination.

 

All reports are recorded and analysed initially to assess their relevance, after which they are assigned to the relevant department for investigation.

 

Following the in-depth analysis, any risk mitigation interventions or disciplinary measures are evaluated by the relevant departments (e.g. ICT, Organisation, Legal, HR). In the event of a significant incident, the relevant corporate bodies are promptly informed.

 

The whistleblower will receive an acknowledgement of receipt within seven days of sending the report, followed by a reply within three months of this acknowledgement.

 

Please note that the Whistleblowing Channel is not intended for customer complaints or operational/commercial requests, nor for disputes, claims or requests relating to personal interests or interpersonal matters.

It is possible to submit Whistleblowing reports, including anonymously, via the channels indicated below. These channels are available 24/7 and support both Italian and English. The report shall contain a detailed description of the facts and of the conduct considered to be in breach of the rules, indicating, where possible, also the documents, the rules which are considered to have been breached and any other evidence useful for conducting the investigation into the alleged facts. Finally, the whistleblower is required to declare whether they have a personal interest related to the report.

 

The Head of Internal Whistleblowing Systems, who is also the Audit Manager of the Insurance Group, is responsible for ensuring that the process is conducted properly and that the relevant reports are submitted to the corporate bodies.

The main channel is intended for all whistleblowers, except company officers, for whom a separate channel has been provided. A report can be made by the following methods:

 

In writing to:

• segnalazioni.violazioni@intesasanpaoloassicurazioni.com

 

Verbally, via a recorded voice messaging system (maximum recording time 3 minutes), to the following numbers:

• +39 024 1340 999 for reports in Italian;
• +39 024 1340 998 for reports in English.

 

Communications are managed through specific channels, which are separate and autonomous from ordinary ones.

 

Through the two channels indicated above, whistleblowers may also request a meeting with the purpose of making a report. The meeting will be scheduled within a reasonable time with the Head of Internal Whistleblowing Systems and possibly the Representative.

 

The Insurance Group Companies will process personal data and information as data controllers for purposes related to the management of reports. In compliance with the relevant legislation, personal data and information will be kept for no longer than five years from the final outcome of the procedure.

 

Whistleblowers are encouraged to use internal channels as a matter of priority. Subject to certain conditions, they may also make an external report directly to the competent authority.

 

In Italy, it is possible to make an external report to the National Anti-Corruption Authority (ANAC), if one of the following conditions applies at the time of submission:

• there is no provision for the mandatory activation of the internal reporting channel within the workplace the internal reporting channel is not active; even if the internal reporting channel is activated, it does not comply with external regulations;
• an internal report has already been made and has not been followed up. Follow-up means the action taken by the person entrusted with managing the reporting channel to assess the existence of the reported facts, the outcome of the investigation, and any measures taken;
• there are reasonable grounds to believe that an internal report would not be followed up effectively; there are reasonable grounds to believe that an internal report could result in retaliation;
• there are reasonable grounds to believe that the violation may pose an imminent or obvious danger to the public interest. External reporting to the ANAC may be made in the methods provided for on the institutional website of the institution.