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 2020,  361.394 hours of training were provided on these issues, involving 75,511 people (86.9% of the total). 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 2020, 1,215,503 hours of training were provided on the topic and 59,434 employees were trained (69.3% of the total).


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 2020, 72,165 hours of privacy training were provided - involving 61,852 employees (72.2% of the total) - and 1,559,068 hours of training on the topic of consumer protection - involving 61,700 employees (72% of the total).

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 2020, 39 cases for violations of labour law were notified and around 188 cases were closed. The main types of pending litigation include the termination of employment relationships – sale of business line (Intrum), compensation for damages for deskilling and mobbing, higher job positions and appeals of disciplinary sanctions (in any event in 2020, no lawsuits were reported by current employees that related solely to cases of 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 206 Risk Areas identified in the planning phase were completed, with the completion of 251 audits (63 of which  "extraordinary", i.e. originating from specific requests of Corporate Bodies, Supervisory Authorities or from events/circumstances occurring after the completion of the annual planning) (*). In 2020, 91 audits were reported as significant for the purposes of Italian Legislative Decree 231/2001, and among these 9 concerned activities related to corruption risk. These latest audits involved 10 Governance Areas/Divisions (some interventions involved several Governance Areas/Divisions).

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 2020, the Group, in addition to indirect taxes of 1.017 million euro (including UBI's contribution, equal to 170 million), recorded accrued income taxes for the year of 1,360 million euro (including UBI's contribution, equal to 110 million), for the most part in Italy, where the majority of operating income was earned, as per the table below. 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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