Integrity in conduct

Integrity in corporate conduct

The Intesa Sanpaolo Group recognises that compliance with internal and external regulations and codes of conduct is of significant importance, also from a strategic point of view, and therefore it acts in the belief that compliance to the rulesand fairness in business (fighta against active and passive corruption, combating money laundering, compliance with tax regulations, protection of free competition, privacy protection and compliance with the rules governing employment relationships) are fundamental elements in in the performance of banking activities, which by nature are based on trust and transparency.


2022 Results

No significant disputes over labour matters
No significant reports in environmental, health and safety matters


Since 2016, a system has been in place for personnel to report actions or conduct that may constitute violations of banking regulations as well as internal company policies and/or procedures or conduct giving rise to conflicts of interest (whistle-blowing). The whistle-blowing management process ensures appropriate protection for whistle-blowers against any retaliatory or discriminatory conduct resulting from their reports. 

2022 Results

28 reports

4 deemed irrelevant

24 reports under investigation

Code of Ethics

The Code of Ethics is the self-regulatory document adopted by all the Group companies and it is an integral part of the Sustainability management model; it sets out the values and principles that govern relations with Stakeholders, referring, for some areas of particular relevance (e.g. human rights, labour protection, environmental protection, fight against corruption), to rules and principles that are consistent with the best international standards.

Among customers complaints, which are the majority, the categories with the greatest impact concern the difficulties in accessing branches or online services of disabled people (22 reports) and operational problems often related to communication problems with foreign customers (18 reports). No complaints were received from customers in relation to the Diversity and Inclusion Policy and regarding inclusion of disabled people.

Model for the management of administrative liability pursuant to Legislative Decree 231/01

Legislative Decree no. 231/01 establishes a system of administrative liability of Italian Companies for a set of specifically identified crimes or offences, committed in their interests or for their benefit. Intesa Sanpaolo has long been equipped with an Organisational, Management and Control Model that defines the principles of control and conduct to be adopted to reduce the risk of committing crimes and offences envisaged by the Decree, including corruption and environmental crimes.

In 2022, the Parent Company updated the Model in order to: (i) support specific initiatives with social and/or cultural purposes, (ii) align the eligibility requirements of the members of the Supervisory Board (SB) with Ministerial Decree 169/2020 , (iii) implement the regulatory changes, such as the inclusion of crimes relating to non-cash payment methods and those against cultural heritage as well as the extension of some unlawful conduct (money laundering, crimes against Public Administration, etc.). The Italian companies of the Group are currently in the process of updating the Model.