Violation Reporting Systems – Whistleblowing

Intesa Sanpaolo Servitia has an internal system for reporting acts or facts that may constitute violations of rules governing financial sector or any illegal, unethical, or improper conduct that may occur in the course of its business.

Who can make a report

In accordance with the provisions of Law of May 16, 2023 transposing Directive (EU) 2019/1937 of the European Parliament and of the Council of October 23, 2019 on the protection of persons who report violations of Union law, the following subjects can make a whistleblowing report:

• Employees and self-employed workers who work or have worked for the Company;
• Freelancers and consultants who work or have worked for the Company;
• Shareholders and members of the administrative, management or supervisory body of a company, including non-executive members, as well as volunteers and paid or unpaid interns;
• Anyone working under the supervision and direction of contractors, subcontractors, and suppliers.

How to make a Whistleblowing report

Whistleblowing reports can be sent using the specific channels indicated below (available 24 hours a day, 7 days a week, in French, English, Luxembourgish and Italian):

• By email to whistleblowing@intesasanpaoloservitia.com;
• By calling our Whistleblowing voicemail: +352 22 37 56 583
• By sending an ordinary letter (even without signature and anonymously) to the “Intesa Sanpaolo Servitia’s Whistleblower” at the following address: 28, Bvd de Kockelscheuer, L-1821 Luxembourg.
  It is important to note that sending an anonymous letter may result in the forfeiture of the rights to receive feedback. We also remind you that anyone who deliberately reports false information or intentionally disseminates incorrect information will be subject to corrective and disciplinary and/or legal action.

The report must allow the identification of the whistleblower (if applicable) 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 the other findings useful for conducting the investigation of the disputed facts.

ISP Servitia recognizes the importance of protecting the confidentiality of whistleblowers. In the light of the above, ISP Servitia will take all reasonable steps to ensure that whistleblowers identities are not disclosed without their consent, except where required by law. The Whistleblower support group will take care of receiving the request and carry out the relevant investigation. In particular, they acknowledge the request within seven (7) days of receipt of the report. During the investigation, a diligent follow-up by the group will be sent within three (3) months from the expiration of the seven-day period following the report, if the whistleblower is identified or identifiable.

Anyone who deliberately reports false information or intentionally disseminates misinformation will be subject to corrective and disciplinary or/and legal action. Corrective or disciplinary action can range from criminal claims and damage compensation reclaims depending on the severity of the breach. Conversely, those who report reports suspected misconduct or participates in an investigation in good faith will be protected from any disciplinary action or negative repercussions.

Personal Data Protection

The personal data and information acquired by Intesa Sanpaolo Servitia to which the "Whistleblowing" report is sent will be processed by the same in its capacity as Data Controller for the related management and will be kept no later than 5 years after the ending of the procedure and has as its legal basis the fulfillment of an obligation by law. For further information please refer to the Personal Data Protection Portal.