Violation Reporting Systems
Whistleblowing

The Whistleblowing Reporting System (WRS) promotes corporate culture by encouraging the report of unlawful conduct by means of dedicated channels and protecting all the parties involved from any possible retaliation or discrimination.

Why make a report

BPER Factor promotes a corporate culture based on the principles of honesty, fairness and compliance with regulations, at all levels. These principles are a fundamental component for the creation and dissemination of value, also to protect from reputational risk exposure.

Reports may refer to:
- violations of regulations governing banking activities;
- violations of regulations governing financial activities;
- violations of Market Abuse regulations;
- violations of Anti -money laundering and financing of terrorism regulations;
- violations that may affect the truthfulness and/or correctness of financial information (intentional or unintentional errors);
- violations of antitrust laws;
- violations of anti-corruption regulations;
- violation of regulations concerning: public tenders; safety and conformity of products; protection of the environment; protection of consumers; protection of privacy, protection of personal data and security of IT networks and systems;
- unlawful conduct pursuant to Legislative Decree 231/01 or violations of the Organisation, Management and Control Models provided for by the same Decree;
- conduct, acts or omissions that consist in administrative, accounting, civil or criminal offences;
- violations of European Union acts or national acts implementing EU acts;
- fraud against one or more recipient companies or the Group as a whole.

Who can make a report?

The Whistleblowing process allows to report, under the assurance of the strictest confidentiality, any violations that damage the interest and/or the integrity of BPER and its Companies, which the whistleblower has become aware of in the context of his/her work-related activities, or on the basis of the existing legal-economic relationship the whistleblower has with the Group. The whistleblower is protected from any possible retaliatory or discriminatory behaviour.

The following subjects can make a whistleblowing report:
- employees on a permanent or fixed-term contract;
- agency-supplied temporary workers;
- interns and collaborators;
- advisors authorised to provide financial services off the bank premises;
- financial agents;
- debt collectors;
- suppliers;
- freelancers and consultants who work for the Group;
- shareholders;
- persons with administrative, control, supervisory or representative functions.

How to make a report

Internal reporting channels of the BPER Group

Reports can be made at this link.
This procedure will allow to make:
- a written report by filling out the required fields;
- a verbal request for a meeting in person with the Whistleblowing Officer.

The channel provided above cannot be used to lodge a complaint relating to the commercial relationship, but only to report unlawful conduct.

The report allows the identification of the whistleblower (name and surname, relationship with the company and contact details) and must contain a detailed description of the facts and conduct considered to be in conflict with the law, also indicating, where possible, the documents, the rules that are considered to have been violated and other findings useful for conducting the investigation of the disputed facts.

Finally, the whistleblower has the obligation to declare whether he/she has a personal interest in making the report. The Chief Audit Officer is the designated Whistleblowing Officer and reviews the whistleblowing reports in collaboration with the Internal Audit Function.

The personal data and information acquired by BPER Factor will be processed by the bank in its capacity as the Data Controller and stored for no longer than 5 years from the date of communication of the final outcome of the whistleblowing procedure.

The Whistleblowing Officer ensures your information is thoroughly examined and treated with absolute confidentiality.

External reporting channels

As a priority, whistleblowers are encouraged to use internal reporting channels. External reports may also be filed directly with the relevant Authorities, if certain conditions apply. An external report may be filed with the National Anti-Corruption Authority (ANAC), if at least one of the following conditions applies upon submission:

- the whistleblower has already addressed an internal report to the Whistleblowing Officer that was not followed up;
- the whistleblower has reasonable grounds to believe that an internal report would not be followed up or that the report might lead to a risk of retaliation;
- the whistleblower has reasonable grounds to believe that the breach may constitute an imminent or manifest danger to the public interest.