Page 24 - Consolidated Non Financial Statement

Banca Ifis

| 2020 Consolidated Non-Financial Statement
of the audits are shared with the reference organisational unit and with the level two audit departments and then sent to
the Board of Statutory Auditors and the Control and Risks Committee. Internal Audit also reports back regularly to the
Corporate Bodies, also by presenting specific summary reports (Annual reports and Quarterly Dashboards) that, if
required, are also submitted to the Bank of Italy or Consob.

The value of ethics: Code of Ethics
[GRI 102-16]
Banca Ifis conforms to the purposes and guidelines of the Corporate Governance Code for Companies Listed on
the Italian Stock Exchange, and its governance system is aligned with the principles contained therein, the relevant
recommendations issued by Consob, and, in general, best practices, which are intended to ensure an appropriate
separation of responsibilities and powers by striking the right balance between operational and control functions.

Pursuant to Italian Legislative Decree no. 231/2001 on the “Rules for the administrative liability of legal entities,
companies and associations, including those without legal status”, the Banca Ifis Group makes the Code of Ethics and
the Supervisory Body's Regulations publicly available.

The Code of Ethics outlines the set of rights, duties and responsibilities of the Group's companies towards all the parties
it works with, establishing rules of conduct to be kept in mind during day-to-day operations as well as reference standards
and behavioural norms aimed at strengthening business decision-making processes and guiding the conduct of all
employees.

The Code of Ethics in force today was approved on 22 December 2016 and updated on 14 January 2021. The update
consists of the more schematic presentation of the Bank’s and Group companies’ principles and values (redefined during
the new growth strategy defined in 2020) and an update of the more strictly regulatory contents, with specific reference
to whistleblowing procedures.

In accordance with the principles laid down in the Code of Ethics, all Group employees must behave ethically in their
relationships with colleagues, customers, debtors, suppliers, competitors, and public institutions. Illegal or unethical
behaviour, including with reference to legal provisions, codes and regulations adopted by the Group, is not acceptable.
Business model

Banca Ifis seeks to ensure conditions of transparency and fairness in conducting its business, so as to safeguard its
institutional role and image as well as meet the expectations of shareholders and of those who work for and with the
Bank: to this end, it has decided to adopt the Organisational and Management Model as per Italian Legislative
Decree no. 231/2001.

This is a complex set of principles, rules, provisions, and organisational charts with the relevant duties and
responsibilities allowing to establish and duly manage a system to control and monitor sensitive operations in order to
prevent the risk of committing the offences set out in Italian Legislative Decree no. 231/2001. The Model – adopted in
2004 and constantly aligned with the latest regulatory changes – is part of a broader control system that consists
mainly of the Internal Control Systems and Corporate Governance rules of Banca Ifis. The Group's companies
adopt the same approach.

In addition, viewing its Model as a key company policy tool, Banca Ifis extends its internal organisational instruments to
its subsidiaries as applicable. To this end, the Parent's Organisation Unit provides specific methodological support
to all the Group's Supervisory Bodies in order to standardise the Models adopted by the subsidiaries, update or draft
the Regulations of Supervisory Bodies and guarantee, with the help of the Compliance Department, the monitoring of
any significant regulatory changes, as well as assist the Parent's Supervisory Body in providing guidance and
coordination on liability as per Italian Legislative Decree no. 231/2001 to the other companies of the Group.

Among other offences, the Model covers also crimes strictly related to non-financial topics, such as corporate offences
(corruption and bribery), crimes of manslaughter and negligently causing serious or grievous bodily harm committed with
breach of occupational health and safety regulations, as well as environmental offences and crimes associated with
human trafficking and exploitation and the employment of illegal immigrants and, since the last update, tax crimes.

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