Whistleblowing

Whistleblowing System

The Whistleblowing System is one of the ways we promote our corporate culture, encouraging the reporting of misconduct through a dedicated process that protects all parties involved.

AideXa, in accordance with applicable laws and regulations, has established an internal system for reporting acts or incidents that may constitute violations of banking regulations or other laws and regulations (Whistleblowing), ensuring the confidentiality of the personal data of the whistleblower, the alleged perpetrator of the violation, and any other individuals mentioned, while also protecting the whistleblower from retaliatory and/or discriminatory conduct.

Why submit a whistleblowing report?

AideXa promotes a corporate culture based on the principles of ethics, transparency, honesty, and compliance with regulations at all levels of the organization. Adherence to these principles is a key factor in creating and delivering value, as well as serving as a safeguard against reputational risk.

What can be reported?

Whistleblowing reports may concern:

• administrative, accounting, civil, or criminal offenses;

• unlawful conduct as defined by Legislative Decree No. 231 of June 8, 2001, or failure to comply with the control measures provided for in the 231 Model;

• offenses committed in violation of the European Union legislation listed in Annex 1 to Legislative Decree No. 24 of March 10, 2023, and all national provisions implementing it (even if the latter are not expressly listed in the aforementioned annex); by way of example and without limitation, these include offenses relating to the sectors of financial products and markets, the prevention of money laundering and terrorist financing, the protection of privacy, the protection of personal data, and the security of networks and information systems;

• acts or omissions that harm the financial interests of the European Union as identified in the regulations, directives, decisions, recommendations, and opinions of the European Union;

• acts or omissions concerning the internal market and the free movement of goods, persons, services, and capital;

• other acts or conduct that undermine the object or purpose of the provisions set forth in European Union acts;

• violations of Banca Aidexa’s Code of Ethics and violations of company regulations and internal procedures, with the exception of those concerning cases specifically listed among the exclusions;

• violations in the banking sector pursuant to Articles 52-bis and 52-ter of the Consolidated Banking Law (TUB) and Article 4-duodecies of the Consolidated Financial Law (TUF).

A whistleblowing report may also concern:

• information regarding conduct intended to conceal the violations mentioned above;

• illegal activities that have not yet been carried out but which the whistleblower reasonably believes may occur based on concrete, specific, and consistent evidence;

• well-founded suspicions.

The following, however, are excluded from the scope of the Reports:

• disputes, claims, or requests of a personal nature that relate exclusively to individual employment relationships or to relationships with superiors or colleagues; with regard to the latter, reference should be made to the provisions of the Workers’ Statute, as well as to the Code of Ethics and the relevant provisions and practices in force within the Company;

• violations for which national or Union law already provides for reporting procedures;

• violations related to national security and contracts pertaining to defense or national security;

• reports of issues of a purely operational or commercial nature.

Irrelevant reports will be closed, and the reporter will be notified.

Who can file a whistleblowing report?

The following individuals may file a whistleblowing report:

• employees, including:

  1) employees whose employment relationship is governed by Legislative Decree No. 81/2015. This includes, for example, part-time, intermittent, fixed-term, temporary agency, apprenticeship, and occasional employment relationships;

  2) workers who perform occasional work;

• self-employed individuals who carry out their work at the Bank;

• contractors, independent professionals, and consultants who provide services at the Bank;

• volunteers and interns, whether paid or unpaid, who work at the Bank;

• the Bank’s shareholders;

• persons holding administrative, managerial, supervisory, or representative positions at the Bank, even if such functions are exercised de facto.

The whistleblower is protected from any retaliatory or discriminatory conduct.

How do I submit a report through the internal channel?

You can submit a report by visiting the tool web Whistleblowing (available 24 hours a day, 7 days a week).

The tool will allow you to submit:

• written reports (by filling out the required fields);

• verbal reports.

The report must contain a detailed description of the facts and conduct deemed to be in violation of the regulations, indicating, where possible, the documents, the rules believed to have been violated, and any other evidence useful for verifying the disputed facts, as well as, if identifiable, the name of the person who engaged in the conduct being reported. In addition, the reporter is required to disclose whether they have a personal interest related to the report.

The Chief Audit Executive has been appointed Head of the Whistleblowing System.

With the support of tool web Whistleblowing:

• within 7 days of the date of the report, issues an acknowledgment of receipt of the report;

• within 3 months of the date of confirmation of the acknowledgment of receipt, provides a response to the report or, in the absence of such acknowledgment, within three months of the expiration of the seven-day period following the submission of the report.

The personal data and information collected by Banca AideXa will be processed by the bank in its capacity as Data Controller; it will be retained for no longer than 5 years following the final outcome of the procedure. The Whistleblowing System Manager guarantees that your information will be carefully reviewed and treated with absolute confidentiality.

How do I submit a report through an external channel?

As a matter of priority, whistleblowers are encouraged to use the internal channel; however, under certain circumstances, they may file a report through the external channels established by:

• National Anti-Corruption Authority (ANAC), in accordance with the procedures published on website if any of the following conditions apply at the time of submission:

  1) there is no requirement to use the internal reporting channel in the workplace, or the channel is not active, or, even if active, it does not comply with external regulations;

  2) the whistleblower has already filed a report through the internal channel without receiving a response;

  3) the whistleblower has reasonable grounds to believe that the internal report would not be followed up on or that the report itself could lead to a risk of retaliation;

  4) the whistleblower has reasonable grounds to believe that the violation may constitute an imminent or clear danger to the public interest;

• Banca d’Italia, in accordance with the procedures published on its website
  
  

Read the privacy policy

Before submitting any reports, please review the following documents.