Page 40 - Consolidated Non Financial Statement

Banca Ifis

| 2020 Consolidated Non-Financial Statement
2020 2019
15
Number and percentage of employees who received training
on the fight against corruption, No. 691 476
divided up by category
% 40,0% 27,2%
No. 14 8
Senior managers
% 17,9% 10,8%
No. 179 116
Middle managers
% 35,3% 22,7%

No. 498 352
Clerical staff
% 43,6% 30,1%

In October 2020, the members of the Parent Company's Board of Directors approved the update to the Organisation,
Management and Control Model pursuant to Italian Legislative Decree no. 231/2001, which also contains rules on the
prevention of the risk of the commitment of crimes of corruption and concussion.

Several precautions are taken to ensure debt collection agents and companies conduct themselves with integrity: among
other things, it requires them to abide by the Code of Ethics and the Model pursuant to Italian Legislative Decree no.
231/01, at the time of stipulating the contract. More specifically, following the update of the Model and Code of Ethics,
the new documentation has been sent out to the agents and suppliers of Banca Ifis by e-mail.

Finally, as regards the Bank’s stakeholders, the Code of Ethics and the “General Part” of the Organisation and
Management Model pursuant to Italian Legislative Decree no. 231/01 are published on the Group’s website.
[GRI 205-3]

As in the previous year, during 2020 there were no incidents of corruption or legal cases brought against the employees
of the Group or the external networks.

Anti-money laundering and terrorist financing
Preventing the risk of money laundering is key for protecting the Bank's financial strength and, more generally, its
reputation, and reflects its constant effort to actively co-operate with Supervisory Authorities. The Group refuses to do
business, either directly or indirectly, with individuals or companies that are known or suspected members of
organisations engaging in criminal or illicit activities. This principle translates into specific procedures and audits in
the various business areas:

• the Leasing segment examines negative press reports using an automated system integrated with the auto-
decision making procedure: if there are any matches, the position is put on hold and marked for a manual
assessment, involving also the Anti-Money Laundering function. Following these checks, the position is
assigned a risk profile that serves as the basis for activating an approval process at different hierarchical levels;
• as for the Trade Receivables and account products, the above checks are integrated with master data
management procedures. Also in this case, based on the matches found, the counterparty is assigned a
specific level of money laundering risk, and the decision of whether to open/maintain the relationship is left to
the appropriate hierarchical level;
• the Npl segment conducts a review at the time the receivables portfolio is acquired as well as subsequent
checks on individual counterparties when defining settlement plans.

15 The count considers employees who have completed at least one of these courses:
• E-learning course “The liability of entities ed. 2018"
• E-learning course “The liability of entities ed. 2020", made available starting October 2020
• One external training courses attended by one employee.

32