Page 64 - Consolidated Non Financial Statement

Banca Ifis

| 2020 Consolidated Non-Financial Statement

Debt collection company agents and employees monitoring model

The structure that manages the out-of-court networks and the monitoring structure have defined a debt collection and
agents monitoring model based on different types of KPIs:

• Quality KPIs, such as, by way of example, complaints upheld, disputes and anomalous conduct
• Quantity KPIs, such as, by way of example, processing time, quality of repayment plans defined in terms of
number and value, amount of outstanding collections

These KPIs are monitored monthly and, if applicable, a dialogue is activated with agents and debt collection companies to
launch any corrective actions.

And, in addition to the usual inspections run at the collection companies, specific inspections may be held or questionnaires
submitted with a view to verifying various aspects, including the adequacy of the collection processes adopted in respect
of the industry best practices.

Once a year, when the results of the above-described control activities have been processed, an overall assessment takes
place of the collectors and, depending on the outcome, the most appropriate action to be taken is decided, to protect the
interests of the Banca Ifis Group and its customers.

When faced with risk events, the internal structures duly inform the control organisation units and, in particular, Risk
Management, as responsible for handling operational and reputation risks.

To evaluate the effectiveness of the adopted management approach, the Business Areas that own each product or
service verify whether those comply with the Bank's sales processes to make sure the customer's needs are met
effectively, and the control functions can schedule and conduct reviews in accordance with the Bank's policy.

Specifically concerning the definition and introduction of new products and services:

• Compliance monitors the risk of non-compliance, for instance by assessing the adequacy of controls relative
to applicable laws or verifying the compliance of the proposed advertising campaign, and, in partnership with
the Human Resources function, evaluates the adequacy of employee training in raising awareness about the
risks inherent in the new product and how to mitigate them.
• Anti-Money Laundering helps evaluate the risk that the new initiative could pose to the Bank concerning the
potential for it to become involved in money-laundering and terrorist financing as a result of the new product.

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