Integrity and fairness

To ensure the Bank conducts its operations transparently and fairly, thus preserving its institutional role and image as well as meeting the expectations of shareholders and stakeholders, Banca IFIS has adopted an Organisational and Management model pursuant to Italian Legislative Decree 231/2001.

This Model allows to raise the awareness of the Bank's employees about the need to act fairly and properly in the discharge of their duties so as to prevent the risk of committing the offences listed in Italian Legislative Decree 231/2001 (including – among other things – corruption between private persons, environmental crimes, and offences associated with the failure to comply with workplace health and safety regulations).

Code of Ethics

A key part of the Organisational Model is the Code of Ethics, which sets out the Bank's rights, duties and responsibilities relative to all parties it engages with (customers, suppliers, employees, shareholders, supervisory authorities, institutions).

The Code of Ethics establishes the rules of conduct that employees must observe in day-to-day operations in compliance with applicable laws and regulations in all Countries where the Bank operates.

The Code establishes reference standards and rules of conduct designed to reinforce corporate decision-making processes and guide the conduct of all employees, thus making it a tool for promoting “corporate business ethics”.

Therefore, adopting and effectively implementing the Model and all the instruments associated with it improves the Bank's Corporate Governance, limiting the risk of committing offences as well as of damaging its image and reputation by ensuring a responsible and conscientious attitude towards all counterparties.

Ensuring the Organisational Model and the Code of Ethics are effective requires promoting a “culture of control” among all employees and raising the awareness of all structures concerned. This is why the Group trains its staff on the content of the Organisational Model pursuant to Italian Legislative Decree 231/01 and the Code of Ethics.

Number and proportion of employees trained on the Organisational and Management Model pursuant to Italian Legislative Decree 231/01 and the Code of Ethics

    2015 2016
Total employees Num 704 1.313
Total employees trained, of which: Num 239 766
  % 34% 58%
- Senior managers Num 2 36
  % 8% 57%
- Middle managers Num 27 229
  % 17% 58%
- Clerical staff Num 210 501
  % 40% 59%

Hours of training on the Organisational and Management Model pursuant to Italian Legislative Decree 231/01 and the Code of Ethics

    2015 2016
Total training hours, of which: hh 417 1.599
- Senior managers hh 3 84
- Middle managers hh 29 495,5
- Clerical staff hh 385 1.019,5

In addition, in accordance with the “Supervisory provisions for banks” - Circular no. 285 of 17 December 2013, Banca IFIS has activated an internal reporting system to allow the employees of the Parent Company or Subsidiaries to report actions or events that potentially breach the regulations (both external and internal) governing the company's operations.

The reports can be submitted using different channels and are handled by the Internal Auditing Officer, 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 Internal Auditing Officer 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.

In December 2016, the Group updated its Reporting Policy to extend it also to Interbanca.


Environment and territory

Managing environmental impacts

The most significant direct environmental impacts of Banca IFIS's operations are the production of waste—mainly office waste (paper, empty toner cartridges, out-of-use equipment, etc.)—wastewater, the energy used for lighting and heating, and the emissions into the atmosphere. There are also additional impacts, such as the use and disposal of agrochemicals, associated with the maintenance of the Villa Fürstenberg garden—a 22-hectare green area that surrounds the company's historical headquarters (and the current head office) in Mestre, Venice.

As part of the implementation of the Organisational Model pursuant to Italian Legislative Decree 231/01 and in order to prevent environmental offences, Banca IFIS has prepared an “Integrated Safety and Environment Manual”. The Manual, approved by the Board of Directors and regularly updated, lists all procedures for managing environmental as well as health and safety impacts (in accordance with Italian Legislative Decree no. 152 of 3 April 2006). The Head Office is responsible for promoting the implementation of the Manual and regularly updating the Environmental Policy, while the Equipment and Safety/Environment Management Unit, which is part of the General Services Function, is responsible for ensuring environmental procedures are properly implemented.

The Manual, which includes the Group's Environmental Policy, is also the instrument the company uses to establish and inform all employees about the key principles and criteria for making decisions about protecting the environment. Banca IFIS endeavours to disseminate and consolidate a culture of environmental protection, raising awareness of environmental issues and promoting responsible practices among all employees. These are provided with adequate information and training, and they are required to report any deficiencies or failures to comply with applicable regulations in a timely manner.

The Group manages the impacts generated by its operations in accordance with the Integrated Manual and applicable laws.

Concerning the reduction in energy consumption, in 2016 the restructuring of the Florence office—housing the NPL (Non-Performing Loans) Area and the Fast Finance business area—was completed. The restructuring is environmentally friendly and will allow to reduce consumption through the energy generated with solar panels as well as the savings from Led lighting (see Figure 1 ).


Figure 1 – The new Florence office