Integrity in corporate conduct

The Intesa Sanpaolo Group recognises that compliance with internal and external regulations and codes of conduct holds significant importance, including from a strategic viewpoint, and that the observance of rules and fairness in business (combating active and passive corruption, combating money laundering, compliance with tax regulations, protection of free competition, privacy protection and compliance with the rules governing labor relations) are essential elements in the conduct of banking, which by its very nature is based on trust and transparency and promotes the creation of a competitive economic environment and the protection of customer rights.

It also recognizes that the awareness and diffusion of the culture of ethics and human rights among the Group's people, its business partners and stakeholders can result into concrete contribution to the development of the territory and the community.

It has therefore adopted an internal regulatory framework based on the Code of Ethics, the Internal Code of Conduct for the Group and for the Group's Italian companies and the Organisation, Management and Control Model adopted pursuant to Legislative Decree 231/2001. 

UN SDGs SUPPORTED

The Code of Ethics is the voluntary self-discipline document adopted by all the Group entities and is an integral part of the Sustainability management model; it explains the values ​​and principles that regulate relationships with stakeholders, recalling, for some areas of particular relevance (e.g. human rights, protection of work, environmental protection, fight against corruption), rules and principles consistent with the best international standards.

It provides that corporate objectives are pursued with honesty, fairness and responsibility, in full and substantial compliance with the rules, professional ethics and the spirit of the agreements signed. To this end, the Group recognizes the strategic importance of the activity aimed at ensuring compliance with internal and external regulations and codes of conduct.

The implementation and governance mechanisms of the Code are based on the following key principles: self-responsibility of the structures, accountability through reporting, a solid governance system.

Compliance with the principles and values ​​of the Code of Ethics is strengthened by specific training and communication initiatives aimed at both Group personnel and external parties and is also monitored through audit activities that also consider aspects and implications of social and environmental responsibility.

The implementation and governance mechanism of the Code of Ethics can also leverage an independent analysis, conducted on the Italian and foreign perimeter of the Group with a detailed analysis of foreign banks (Privredna Banka Zagreb, Intesa Sanpaolo Bank Slovenia, Bank of Alexandria). The Code of Ethics provides for the possibility of reporting alleged non-compliance with its provisions.

The Code of Ethics provides for the possibility of reporting alleged non-compliance with its provisions. In 2024, 159 reports were received (116 in 2023). 153 were received in Italy and 6 from abroad. The largest number of reports came from customers (141), followed by those from employees (17). The category that has the greatest impact on customer complaints concerns communication problems with foreign customers (40 reports); 23 reports concern issues relating to access to counters or online services by people with disabilities. In 2024, issues relating to non-discrimination were also constantly and carefully monitored.

Since 2016, a system has been in place for staff to report acts or behaviors that may constitute violations of the regulations relating to banking activity, as well as internal company policies and/or procedures, or conduct that gives rise to conflicts of interest (whistleblowing). The system is active 24 hours a day through specific channels available on the Group website and intranet portal. It was updated in July 2023, following the entry into force of Legislative Decree 24/2023, strengthening the guarantee of appropriate protection for the whistleblower from any retaliatory or discriminatory conduct resulting from his report.