The Code of Ethics, which sets out voluntary commitments for managing relations with all entities both in and outside the Group, is the regulatory tool that includes social and environmental issues in company processes, practices and decisions. The Code specifically provides the basis for company culture and reference values for the conduct to adopt with stakeholders and is therefore a document that follows developments in the Bank's operating context, guaranteeing the utmost transparency and consistency in relationships of trust with stakeholders. The Code of Ethics was revised, with approval given in December 2016 by the Board of Directors. The revision concerned the corporate governance model and:
- customer relations, also as regards financial inclusion and project finance, specifying the standards and guidelines adopted;
- supplier relations, with information about awareness of sustainability issues and equality;
- relations with the community, with information about empowering, safeguarding and promoting historic, artistic and cultural heritage.
The revision also indicated the model implementing the Code, clarifying the role of the CSR Sub-Department in activities implementing and governing the Code, with specific reference to monitoring the consistency of company decisions and involvement in developing actions to disseminate a culture of sustainability. In this framework, the Sustainability Report provides an overview of the consistency of actions in relation to the Code's principles.
Compliance with the principles and values in the Code of Ethics is also monitored with the assistance of the Internal Auditing Head Office Department, to report annually to the Management Control Committee and Supervisory Authority pursuant to Legislative Decree No. 231/2001. The Compliance and Auditing functions monitor activities concerning the Bank's ethical and social responsibility commitments. The process to monitor the Code of Ethics – integrated with Sustainability Report management processes – includes an audit and relative certification by an independent body on the level of implementation of the Code's principles within the Group, pursuant to the principles and contents in the Guidelines as of ISO 26000. The certification indicates the methodology adopted and results, separately assessing activities concerning respect for human rights.
As regards alleged infringements of the Code of Ethics, based on provisions in the Code and in company regulations, the CSR Sub-Department receives, processes and checks complaints which may be sent by any stakeholder, and then replies, together with the units involved, guaranteeing that persons reporting information are protected from any type of retaliation, discrimination or penalisation and ensuring the utmost confidentiality, save for legal obligations.
Reports of non-compilance with the Code of Ethics
In 2016, 82 reports of non-compliance with the Code of Ethics were received: 70 refer to Italy and 12 abroad. The total number of reports increased from the previous year, due to the complex ongoing economic situation and stakeholders' new awareness of engagement with the Bank. Most of the reports (67) were from customers. A recurrent theme is the accessibility of branches and services (10 reports), and in particular new problems due to the ageing of the population in relation to new technologies. Moreover, responsible conduct in credit management, in the case of particularly delicate situations, was also an issue that was raised (17 reports). In this regard, the Proactive Credit Unit reviewed seven reports with a positive outcome for four customers in particular difficulty. First-time reports from customers who have immigrated (5 reports) suggest the need for the Bank to adopt new approaches more focussed on cultural diversity. As regards information reported about people, two reports were received from trade unions concerning alleged pressure on branch personnel to achieve business results. One report concerned the smoking ban on company premises, with new signs and procedures now in place. Issues concerning non-discrimination were carefully monitored.
As part of a global campaign, numerous complaints were received about Intesa Sanpaolo's involvement in project finance in the pool of banks funding the DAPL (Dakota Access Pipeline): this pipeline will transport crude oil in the United States, from North Dakota to Texas, and is opposed by the Standing Rock Sioux Tribe. The funding was screened using Equator Principles and given an A risk rating (see the website [i]).