WHISTLEBLOWER’S PROTECTION
A) WEB PLATFORM
- Provider: Unione Fiduciaria S.p.A., an independent third party, who provides the web platform, on an external domain, where reports are entered and stored, ensuring proper protection and confidentiality.
It was founded in 1958 by eight Popular Banks. Over the following decades, the founding banks were joined and succeeded by other banks, forming the current social structure (20 popular banks).
- “No-log” policy: access to the portal is managed in no-log mode, in order to prevent the identification of the whistleblower who intends to remain anonymous; this means that the supplier’s and company’s computer systems are unable to identify the access point to the portal (IP address), even if access is made from a device connected to the company network.
B) RECIPIENTS OF REPORTS (“REPORTING OFFICERS”)
- Access to information: only the companies’ Supervisory Bodies and the Group Compliance Officer have access to the information collected through the platform.
- Independence: the aforementioned individuals report respectively to: Board of Directors and Dr. Mario Carlo Arvedi Caldonazzo and they are therefore independent of the corporate operational management of the individual Companies.
C) PROTECTION OF WHISTLEBLOWER’S IDENTITY
- Assurance of anonymity: the reporting process can be activated and monitored by the whistleblower without declaring their identity. This is done in the web platform through codes automatically assigned to each report.
- Insights and dialogue with the recipients of reports (“Reporting Officers”): i) through the platform it is possible, always anonymously, to send and receive communications with the Reporting Officers; ii) through e-mails to the Reporting Officers it is also possible to request in-person meetings, which will always be carried out, protecting anonymity from other subjects of the company’s operational management in the individual Companies.
- Conducting investigations: during the various stages of the investigation, the Reporting Officers will ensure that the whistleblower will not be directly or indirectly involved in the audits.
