The Group's governance system to combat money laundering and the financing of terrorism is based on Guidelines that constitute a systematic and functional framework, with active collaboration by the Group in preventing these illegal activities. Specific processes and procedures have been established on customer due diligence, the reporting of suspicious transactions, registration of relations and transactions, retention of documents, risk assessment and management, internal control and compliance with all relevant provisions to prevent and stop the completion of transactions connected to money laundering or the financing of terrorism. The guidelines and standards defined by the Parent Company are based on and implemented for individual entities, in proportion to the type and complexity of activities carried out and size and structure of the organisation, in compliance with local laws and ensuring that information is shared at a consolidated level.

Procedures have been in place for some now to automatically control Group records and transactions in order to mitigate the risk of having customers registered in black lists subject to restrictions or the freezing of assets. The Group has also adopted a more rigorous approach to legal requirements, with enhanced due diligence for credit and reputational profiles, to prevent its involvement, for any reason whatsoever, in transactions with parties or countries subject to embargoes, even when the transaction is permitted under restrictions issued by international authorities.

Specialised training to prevent Corruption and Money Laundering in 2016

No. of employees trained 22,914 14,355 37,269
Training hours 116,960 47,366 164,326
% of employees trained 35.7 58.4 42.0

Relations with political parties and movements

According to internal policies, donations or sponsorships for political parties or movements or their organised branches/units etc. are not permitted. Specific rules state that the only type of funding possible for political parties, secondary associations and individual candidates, to be decided by the Board of Directors, is an annual advance of the “2x1000 contribution” (voluntary tax donation) on sums due to parties for this type of contribution, to be notified in accordance with law. In 2016, funding was not given to political parties or movements.