Whistleblowing
Whistleblowing
Intermonte, in line with the guiding principles of Generali Group, promotes and encourages the dissemination of a corporate culture of legality characterised by correct and proper behaviour, and ensures effective and efficient channels for the prevention, management and, if required, secure and confidential reporting (whistleblowing) of any irregularities or breaches of the rules governing corporate activities.
Intermonte encourages the reporting of any conduct which, in good faith, is considered illegitimate, to superiors and/or appropriate bodies within the company (line manager, the HR Department, etc.).
What can be reported
Whistleblowing reports must concern negligent, illegal, irregular or improper matters and conduct - in breach of the law, the Internal Code of Conduct (drawn up in line with the principles of the Generali Group Code of Conduct) or any other internal rules - about which reasonable suspicion has arisen or of which an individual has become aware in the course of their activities, including, by way of example and without limitation, such matters as: administrative, accounting or tax compliance irregularities; infringement of regulations to counter money laundering or the financing of terrorism; insider trading and/or market manipulation; irregularities in the provision of investment services and activities; breaches of privacy obligations; infringements of the Organizational and Management Model pursuant to Legislative Decree 231/2001; bullying and harassment; corruption; fraud.
How to report a matter of concern
A report may be made through the following channels, established pursuant to the Whistleblowing Policy (the "Policy"):
- the dedicated Whistleblowing Helpline, available online, or by calling +39 02 77115650;
- by letter under cover of envelope labelled as 'Private and Confidential' and sent to the attention of the "Head of Compliance & AFC, Intermonte Sim S.p.A., Galleria de Cristoforis, 7/8, 20122 Milano MI”;
- by calling +39 02 77115650 to request, with sufficient notice, a meeting with the Head of Compliance & AFC.
Who can report
The reporting channels are intended for use by:
- employees (regardless of the type of contract), interns and trainees;
- financial advisors;
- third parties who have lasting business relationships with Intermonte or the banking group (e.g. coordinated and ongoing working relationships, consultants working regularly with the company on the basis of time and material contracts, etc.);
- suppliers of goods and services;
- persons with administrative, managerial, control, supervisory or representative responsibilities;
- shareholders.
The reporting channels are overseen by the Head of the Compliance Department, with whom a meeting can be requested through the same channels.
The reporting channels are not intended for handling communications that fall outside the scope of whistleblowing (e.g. complaints and/or requests from third parties of a commercial nature), for which appropriate alternative channels are in place.
All whistleblowing reports are treated in the strictest confidence and the confidentiality and protection of the personal data of the person making the report (the whistleblower) and any person referred to in such report are guaranteed in all cases.
Whistleblowers acting in good faith are safeguarded and protected against any form of retaliation, discrimination or penalty, regardless of the individuals involved.
For any further details, please refer to the Whistleblowing Policy.
For those cases in which:
- a whistleblowing report has already been made and has not been followed up;
- the whistleblower has grounds to believe that if a whistleblowing report were made, it would not be effectively followed up or that the same report could give rise to a risk of retaliation;
- the whistleblower has grounds to believe that the infringement may constitute an imminent or clear threat to the public interest;
the body to which reports should be made, including from the private sector, is the National Anti-Corruption Authority (ANAC) (see Whistleblowing - www.anticorruzione.it).
