Page 41 - Consolidated Non Financial Statement

Banca Ifis

| 2020 Consolidated Non-Financial Statement

If a relationship with a customer classified as high risk is activated, the position is subject to stricter and more frequent
reviews in terms of updates and monitoring operations, and any decision is escalated to higher levels.

Besides being required by law, training is key for raising awareness and promoting a culture among employees of
preventing the risk of unwittingly involving the Bank in this kind of incidents.

Anti-Money Laundering helps define the contents of mandatory anti-money laundering training, especially for those
employees that are in direct contact with customers. In 2020, training on anti-money laundering was delivered through
virtual courses and the e-learning course “Anti-money laundering regulations, ed. 2020”, activated on the Ifis Talent
platform. During the year, a total of 4.217 hours of training on anti-money laundering measures was delivered
(approximately 2.366 in 2019) with the attendance of at least one course on the matter by 60,8% of the company
population (38% in 2019).

Whistleblowing
As the Parent company, Banca Ifis, in accordance with industry regulations and best practices, has established an
internal system allowing to report actions, events or omissions potentially in violation of laws and internal procedures
governing the operations of the Parent and its Subsidiaries with the guarantee that the personal data of the complainant
and the alleged offender will remain confidential. The whistleblowing system is governed by the Group
Whistleblowing Policy, which is part of Banca Ifis's Organisational Model and adopted by the Group companies. The
Banca Ifis Group's employees, its collaborators, and licensed independent contractors working with the Group on a
regular basis can file a report.

This report may concern any action or omission in breach of the rules governing the Group's operations that causes or
could cause harm to the Banca Ifis Group. This includes, for instance, actions or omissions, either committed or
attempted, which can cause pecuniary damage to the Group, endanger the health or safety of staff or customers or
damage the environment.

The reports can be submitted using different channels and are handled by the Head of Internal Audit, who examines
and investigates them based on the principles of impartiality, privacy, dignity of the employee and protection of personal
data.

After completing the investigation, the Head of Internal Audit formally submits his or her assessment to the Chief
Executive Officer and the General Manager (or the Chairman of the Board of Statutory Auditors in the event of potential
incompatibilities), who will decide what corrective actions need to be carried out. Internal Audit prepares an annual report
on the proper implementation of the process, including aggregate information on the findings of the audits carried out
based on the complaints received, that is approved by the Board of Directors and made available to employees.

In 2020, as for the previous year, no reports were filed through the Whistleblowing system.

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