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Whistleblowing

Banca Generali promotes and fosters the dissemination of a corporate culture of legality characterized by correct behavior and ensures effective and efficient means aimed at preventing, managing, and, if necessary, reporting any irregularities or violations of the rules governing corporate activities, through secure and confidential channels.

What Can Be Reported

eports must concern negligent, unlawful, irregular, or improper circumstances and conduct — in violation of the law, the Internal Code of Conduct (drawn up in line with the principles of the Generali Group Code of Conduct), or any other internal regulation — for which there is reasonable suspicion or of which one has become aware in the course of performing one’s duties. Examples include: Administrative, accounting, and tax irregularities; Violations of anti-money laundering and counter-terrorism financing regulations; Insider trading and/or market manipulation; Irregularities in the provision of services and investment activities; Irregularities in the distribution of insurance products; Privacy violations; Violations of the organizational and management model pursuant to Legislative Decree 231/2001; Violations of regulations on usury; Bullying and harassment; Corruption; Fraud. 

How to Make a Report

The Bank encourages the reporting, in good faith, of any conduct considered unlawful to internal contacts (one’s Manager, the HR function, contractual contacts, etc.).

It is also possible to submit a report through the institutional reporting channels established under the Whistleblowing Policy (“Policy”):

  • Dedicated IT platform, via web or by phone (+39 02 9475 1936);
  • Emailsegnalazioni.whistleblowing@bancagenerali.it;
  • Confidential and personal written communication sent to the "Head of Compliance Department" c/o Banca Generali S.p.A., Corso Cavour 5/a, 34132 Trieste;

Who Can Report

The reporting channels:

  • Are intended for Bank employees, self-employed workers/collaborators/freelancers/consultants/volunteers/interns working at the Bank, as well as shareholders and persons with administrative, management, and control functions within the Bank itself
  • Are overseen by the Head of the Chief Compliance Office, who may also be requested for a meeting through these channels

The reporting channels are not intended for handling communications that are not relevant, for which dedicated contact points have been established (e.g., complaints and/or requests from third parties of a commercial nature).

All reports are handled with the highest level of confidentiality, and the protection of the personal data of both the reporting person and the person reported is always guaranteed.

Reporters acting in good faith are guaranteed and protected against any form of retaliation, discrimination, or penalization, regardless of the parties involved.

For further details, please refer to the Whistleblowing Policy.

In cases where:

  • An internal report has already been made and has not been followed up
  • The reporting person has reasonable grounds to believe that, if an internal report were made, it would not be effectively followed up or could result in retaliation
  • The reporting person has reasonable grounds to believe that the violation may constitute an imminent or obvious danger to the public interest

The competent authority for reports, including in the private sector, is the National Anti-Corruption Authority (ANAC) (see Whistleblowing – www.anticorruzione.it).