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Integrity in corporate conduct

Intesa Sanpaolo recognises that compliance with internal and external regulations and codes of conduct is of significant importance, also from a strategic viewpoint, and therefore it acts in the belief that respecting standards and fairness in business are essential elements in carrying out banking operations, which by nature are based on trust and transparency.

Fighting against corruption and combating money laundering

Intesa Sanpaolo has defined the Group Anti-Corruption Guidelines, approved by the Board, and the Model of Organization, Management and Control adopted pursuant to D.Lgs. 231/2001 which, together with the Code of Ethics, define the commitment to comply with the regulatory provisions aimed at combating active and passive corruption in all its forms.  Special attention is paid to complying with national and international legislation on money laundering and terrorist financing, including through processes and procedures relating to the obligations of appropriate customer verification, reporting of suspicious operations and risk assessment and management. 
In 2019, 306,937 hours of training were provided on these issues, involving 77,383 people. In addition, there were no dismissals for corruption or disciplinary sanctions for corruption against employees.

Protection of free competition

Intesa Sanpaolo constantly oversees and promotes free competition and spreads the culture of compliance to antitrust legislation also through the establishment of a specific internal team aimed at overseeing compliance with antitrust rules, the adoption of a Policy and a training and information program. In 2019, 1,149,496 hours of training were provided on the topic and 54,748 employees were trained.

 

Privacy and consumer protection

The bank is committed to implementing regulatory, organizational and technological interventions to adequately meet privacy protection needs under the new General Data Protection Regulation -GDPR. These interventions, coordinated by the Data Protection Officer, meet the principles of the Group Code of Ethics that commit the Bank to adopt criteria of absolute transparency in informing customers and employees about their rights in the matter and how that their personal information is processed. 
In 2019, 81,510 hours of privacy training were provided - involving 62,828 employees - and 1,213,215 hours of training on the topic of consumer protection - involving 48,131 employees.

Compliance with labour laws

The Group works to ensure that its working environment is permeated by mutual trust, loyalty and enriched by the contribution of each person, in accordance with the rules and agreements related to national and second level bargaining (Group). In 2019, 34 cases were reported for violations of labour laws against 42 closed cases and no cause for mobbing.

Audit activities

In order to ensure that its actions are aligned with principles of integrity, the bank has designed a system of controls aimed at maintaining a constant safeguard in the identification, governance and control of the risks associated with the activities carried out and in this regard it carries out audit activities on a fixed basis in relation to the nature and intensity of the risks. Audit activities were conducted on 230 Risk Areas in 2019, 90 of which were reported to be relevant to D. Lgs. 231/2001. In addition, 15 audit activities were carried out which directly or indirectly also covered aspects related to social and environmental policies

Compliance with tax regulations and tax contribution

The Intesa Sanpaolo Group complies with tax regulations in the belief that compliance is a fundamental contribution of citizenry supporting the community in which it operates. Intesa Sanpaolo's positive impact in this respect is confirmed by the disclosed forecast in the Business Plan of a total contribution from 2018 to 2021 of approximately 13 billion euro, an amount comparable to a budgetary stability law.

During 2019, the Group, in addition to indirect taxes of 895 million euro, recorded accrued direct taxes of 1,838 million euro, for the most part in Italy, where the majority of operating income was earned.

The Group has strengthened the internal control system for tax risk, known as the Tax Control Framework, to make it capable of covering the strategically important area of tax risk and meeting the requirements for access to the collaborative compliance scheme introduced in Italy, in accordance with Legislative Decree 128/2015.

In December 2017, the Intesa Sanpaolo Group adopted its Principles of conduct on fiscal matters, in order to ensure compliance over time with the tax and fiscal rules of the countries where it operates and to guarantee the financial and reputational integrity of all the Group companies. Guidelines were also approved for the management of tax risk within the system of collaborative compliance with the Revenue Agency, which govern the criteria and processes that Intesa Sanpaolo must adopt to ensure the adequacy and effectiveness of its Tax Control Framework and related Rules.

In compliance with applicable laws, Intesa Sanpaolo publishes a "Country by Country" report, with the following information for each country (according to rules established by the Bank of Italy): the gross income; the number of employees; profit or loss before taxes; taxes on profit or loss. The report is available at this link.

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