Page 39 - Consolidated Non Financial Statement

Banca Ifis

| 2020 Consolidated Non-Financial Statement
the audits performed, specific initiatives are then taken (e.g. training sessions on specific topics), so as to guarantee a high
quality standard and professionalism by the distribution network.

As regards the management of the Ifis Npl company call centre dedicated to phone collection, the organisation of internal
work has been optimised and instruments have been created for the constant monitoring and analysis of performance; the
aims of these measures include the limitation of the risk of “aggressive” conduct or unfair commercial practices
implemented by operators. The company Ifis Npl uses different methods to evaluate the effectiveness of the management
approach implemented:

• inquiries by the "monitoring" call centre - separate from the one dedicated to collection operations, which contacts
all customers that have successfully repaid their debts thanks to the proposed settlement plans, as well as a
sample of customers with whom an agreement has not been finalised, so as to ensure the members of the
network acted with fairness and integrity;
• requiring agents to prepare a "Meeting report" at the end of each visit with a customer describing what transpired
during the meeting and any agreements reached. This report must be signed by the customer, so as to keep a
transparent and objective record of any agreements reached;
• reviewing any rejected complaints on a quarterly basis to identify potential emerging problems or issues of
increasing interest to customers, so as to define the necessary corrective actions;
• constantly monitoring the Bank's social channels;
• interviewing customers that have successfully repaid their debts;
• constantly listening to the grievances and needs of network agents.

The Organisational, Management and Control Model as per Italian Legislative Decree no. 231/2001 of Banca Ifis covers
the following corruption-related offences:

• Bribery of office;
• Corruption for an act contrary to official duties;
• Corruption in judicial proceedings;
• Corruption of the person in charge of a public service;
• Bribery, undue inducement to give or promise money or other advantages and corruption;
• Corruption between private individuals;
• Solicitation to commit corruption between private individuals;
• Embezzlement, embezzlement by means of profiting from a third party error;
• Trafficking of unlawful influences;
• Abuse of office.

The Organisational, Management and Control Model as per Italian Legislative Decree no. 231/2001 of Banca Ifis
specifies that the structures responsible for monitoring the commission of potential corruption-related offences are
the second and third line of defence functions, the Supervisory Body, and the Board of Statutory Auditors.

[GRI 205-2]
The Board of Directors is briefed on the anti-corruption procedures at the time it approves the Group's Code of Ethics.
All employees are required to know and comply with anti-corruption rules, including with reference to the table attached
to the Model that specifically governs potential sensitive activities as well as the main structures and safeguards put into
place in terms of policies, internal rules, and control structures. In addition, all the Group's employees can access internal
regulations, and specifically the Code of Ethics, the Organisational, Management and Control Model pursuant to Italian
Legislative Decree no. 231/2001 and applicable protocols and procedures.

The Group makes sure that all employees receive suitable cyclical (and whenever the legislation is updated) training on
the anti-corruption policies and procedures as per the Organisation, Management and Control Model pursuant to Italian
Legislative Decree no. 231/01. More specifically, starting July 2020, the new edition has been published on the corporate
intranet of the mandatory training course on the “Administrative liability of Entities ed. 2020”. The table below provides
details of the number of employees who have completed at least one anti-corruption course.

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