Page 37 - Consolidated Non Financial Statement

Banca Ifis

| 2020 Consolidated Non-Financial Statement
3.1 Corporate integrity and anti-corruption

Policies and other reference documentation
• Code of Ethics (Banca Ifis)
• Organisational, Management and Control Model as per Italian Legislative Decree no. 231/2001
• Group Whistleblowing Policy (Banca Ifis)
• Group Anti-Money Laundering Policy
• Self-assessment of the risks of money laundering and terrorist financing
• Group guidelines on the Internal Control System
• Organisational Procedure for Due diligence and customer profiling by risk class - onboarding phase (Banca
Ifis)
• Organisational Procedure for Due diligence and Npl customer profiling by risk class (Ifis Npl Investing, Ifis Npl
Servicing)
• Organisational Procedure Due diligence and customer profiling by risk class - hereinafter
• Organisational Procedure for Managing tax receivables (Banca Ifis)
• Organisational Procedure for the Management of the Rendimax Current Account (Banca Ifis)
• Organisational Procedure for the Management of the Rendimax Deposit Accounts (Banca Ifis)
• Organisational Procedure for the Management of the Ifis Current Accounts (Banca Ifis)
• Organisational Procedure for the Management of distressed loan non-judicial collector network (Ifis Npl
Investing, Ifis Npl Servicing)
• Organisational Procedure - Due diligence, customer profiling and the reporting of suspicious operations (Ifis
Npl Servicing)
• Organisational Procedure for Suspicious Transaction Reports (Banca Ifis, Ifis Npl)
• Parent Company Anti-Money Laundering Manual (Banca Ifis)
• Anti-Money Laundering Manual Cap.Ital.Fin.
• Credifarma Anti-Terrorism and Anti-Money Laundering Manual
• Operating manual on Embargo and anti-terrorism: Checks on incoming and outgoing bank transfers (Banca
Ifis)
• Operating manual Certification of Positions on Negative Lists
• Distribution Policy (Cap.Ital.Fin)

The Code of Ethics, an integral part of the Organisational and Management Model envisaged by Italian Legislative
Decree no. 231/2001, is the “manifesto” of the corporate culture of Banca Ifis and the other Group companies. It is
intended to provide information/training to Employees as well as promote said culture among all stakeholders. Making
sure that the Organisational Model and the Code of Ethics are effective requires promoting a “culture of control” among
all employees and raising the awareness of all structures concerned. This is why the Group trains employees on the
contents of the Organisational Model pursuant to Italian Legislative Decree no. 231/01 and the Code of Ethics.

As far as the Code of Ethics is concerned, the Supervisory Body is responsible for, among other things, monitoring
compliance with it and its implementation, taking disciplinary action if required, coordinating the drafting of rules and
procedures to implement it, promoting a regular review of the Code and its implementation mechanisms, and reporting
to the Board of Directors on the work carried out and the problems concerning the implementation of the Code of Ethics.

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