The Bank has adopted strict internal procedures over time to prevent the risk of corruption and extortion. In addition to the Code of Ethics, the Group's Internal Code of Conduct and Compliance Model pursuant to Legislative Decree 231/2001 on the administrative liability of organisations, a detailed set of internal regulations is in place, which all personnel must be familiar with and adopt. These regulations outline corporate processes that may potentially lead to the commission of this type of offence. The Compliance and Internal Auditing Departments ensure that the principles of control and conduct in the Compliance Model concerning corruption are consistent with applicable internal regulations and that these regulations are complied with.

Focus on the prevention of corruption risks is very high in Group companies, both in Italy and at international level. Subsidiaries operating in countries without “anti-corruption” laws are required to adopt the Group's principles and to monitor areas most at risk. To further consolidate controls on the prevention of corruption, a specific “Anti-corruption Project” was started in 2016, covering two fundamental areas:

• “customers“ – to identify any possible risk aspects of customers' behaviour and thus ensure ongoing cooperation with the authorities and action, as part of controls already in place, to combat money laundering and the financing of terrorism;
• the “Bank” – to consolidate internal controls for preventing risk aspects in the Bank's conduct through its officers, top management, employees, external staff and suppliers. In this framework, Group Anti-Corruption Guidelines have been defined and issued to company bodies.

In March 2017, the Anti-Corruption Guidelines were approved as part of the Anti-corruption Project. The guidelines identify the principles, sensitive areas, roles, responsibilities and macro-processes for the Group to manage the risk of corruption and further consolidate existing regulations.