The regulation has introduced for private entities the obligation to establish internal reporting channels for whistleblowing and the obligation to introduce instruments aimed to fully protecting whistleblowers.

Banca Profilo S.p.A. (hereinafter also referred to as “Bank” or “Company”) considers whistleblowing a useful tool to prevent illicit conduct and promote transparency and integrity within the work environment and, consequently, in compliance with the current regulation, the Bank has established an internal channel for reporting potentially illicit or harmful conduct that violates the (national or European) regulations governing the Bank’s activities.

What may be reported

Violations of national or European Union regulations that harm public interest or the integrity of the private entity, of which one has become aware within the work environment.

For example reports may concern:

  • illicit conduct under Legislative Decree 231/2001;
  • acts or facts that may constitute a violation of the rules relating to the activities carried out by financial intermediaries, as well as the EU Regulation on “Market Abuse”;
  • potential or actual violations of the provisions on the prevention of money laundering, fraud, financing of terrorism, conflicts of interest, insider information.

At the same time, the following cannot be reported through the whistleblowing channels:

  • complaints of a personal nature by the whistleblowers;
  • complaints regarding National Security and Defense;
  • complaints from third parties related to commercial relationships with the Bank.

Who may report

The following subjects can make a whistleblowing report:

  • company employees  (including former employees);
  • candidates and trainees of the Company;
  • freelancers and consultants who work for the Company;
  • persons with Administrative and Directive representative functions;
  • members of the of the Company’s Auditing Firm;
  • Company’s shareholders.

How to make an internal report

The framework activated by the Bank on whistleblowing consists of internal channels dedicated to this type of reporting along with external channels defined by the regulation.

Internal Channels

  1. Reporting via e-mail to the dedicated e-mail address: [email protected];
  2. Orally directly to the “Whistleblowing Champion” through:
    a. Telephone lines or voice messaging systems;
    b. In-person meeting;
  3. Through registered letter (following the procedure outlined in the Bank’s whistleblowing policy).

External Channels
This type of reporting can only be activated when the whistleblowers:

  1. has already made a report that has not been followed up;
  2. has reason to believe that an internal report may result in the risk of retaliation;
  3. has reason to believe that the violation may constitute an imminent or obvious danger to the public interest

If, at least, one of the above conditions occurs, the report can be made through:

  1. Electronic platform established by the National Anti-Corruption Authority (ANAC) following the operational procedures reported on the institutional website (https://www.anticorruzione.it/-/del.311.2023.linee.guida.whistleblowing);
  2. Public dissemination through press, mass media, or electronic means capable of reaching a large number of people (channel activatable only if internal and/or external reports have already been made).

How the Bank handles reports

Reports are managed according to the procedures mentioned in the Bank’s whistleblowing policy, and data privacy is protected according to the attached privacy policy.

The Bank is committed to protecting the Reporter from any acts of retaliation, even indirect ones.

Below are the documents that refer to:

Whistleblowing Policy

Privacy Policy Whistleblowing