Page 38 - Consolidated Non Financial Statement

Banca Ifis

| 2020 Consolidated Non-Financial Statement

The Code of Ethics specifies that, when dealing with the Italian Public Administration, it is prohibited to promise or
offer government officials or employees payments or benefits to promote or advance the interests of the Group when
finalising agreements, for the purposes of the award or management of authorisations, when collecting receivables—
including due from tax authorities—during inspections or audits, or as part of judicial proceedings.

Anyone either asked for or offered benefits by government officials shall immediately consult with their supervisor and
the Supervisory Body.

Anti-corruption
In order to prevent the risk of committing corruption and bribery, the Group has adopted the Organisational, Management
and Control Model as per Italian Legislative Decree no. 231/2001, as well as the guidelines set out in the Code of Ethics.

In October 2020, the Parent Company’s Organisation, Management and Control Model was updated to assign
particular relevance to the reform of the Special Part of the Model and proceed according to the routine directives
characterising the document structure, namely: the recording of existing processes and their formalisation, the mapping
of inherent risks and the preparation or better presentation of the related measures.

Part of the intervention was aimed at identifying risk areas, in a more detailed, concrete manner than in the previous
version of the Model, so as to direct the action of managers, employees and collaborators of the Bank and, consequently,
in order to assure an effective Model in accordance with Art. 6 of Italian Legislative Decree no. 231/01.

The offences dedicated greater, priority attention in the context of the update of the Banks’ Organisational Model were,
for example: money laundering, corporate offences, market abuse and tax crime.

The integrity of the conduct of Group agents

In addition to establishing rules of conduct for its staff, the Banca Ifis Group considers it essential to assure the integrity
of conduct of the Leasing area agents too, as well as those of the company Cap.Ital.Fin. and the agents and collection
companies of Ifis Npl.
For instance, several precautions are taken to ensure the integrity of the behaviour of debt collection agents and
companies, including:

• ensuring observance of the Code of Ethics and Organisational Model envisaged by Decree no. 231/01 when
stipulating the contract;
• controlling the number of mandates: agents can have up to three mandates, and only for
non-competing activities;
• adopting an incentive scheme that discourages agents from engaging in inappropriate
or persistent behaviour.
• Observation of the “Code of Conduct” drafted by forumUnirec - Consumer Associations

With reference to the distribution network of Cap.Ital.Fin., the Control Functions carry out regular audits on compliance
with reference legislation governing transparency and money laundering. On the basis of the evidence that emerges from

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