In pursuing its growth objectives, Banca Generali remains faithful to the fundamental principles that characterize its ethics, such as transparency, fairness and impartiality. These principles are reiterated in the Internal Code of Conduct of the Bank, which is in line with the rules of conduct reported in the Generali Groups Code of Conduct.
The Internal Code of Conduct defines the minimum rules of conduct to be observed in dealings between colleagues, as well as with customers, competitors, suppliers and the Groups other stakeholders and contains specific provisions governing the promotion of diversity and inclusion, protection of company assets, conflicts of interest, bribery, financial information and the processing of insider information, the prevention of money laundering, financing for terrorism and international sanctions.
The Code is applied to all Group personnel, including members of administrative bodies. In addition, the Group expects that third parties (consultants, suppliers, etc.) adhere to the principles enunciated in the Code when they act on the Groups account.
The Code shall be published on the companys Intranet in order to ensure it is duly circulated among all recipients concerned.
Formulation of the Code implies the existence of further specific codes, regulations, guidance procedures and company policies issued to deal with any industry regulatory requirements or for any Bank decisions to comply with best practices for the sector. These include, for example:
- the Whistleblowing Procedure that defines and formalises the principles and criteria adopted by Banca Generali regarding the reporting by Bank employees of deeds or actions that could constitute a breach of rules governing banking activity and the resultant handling of such reports;
- the Policy for managing money-laundering and financing of terrorism designed to regulate the manner in which obligations relating to anti-money laundering and anti-terrorism legislation are managed through the adoption of suitable organisational control mechanisms;
- the Conflict of Interest Policy, adopted by Banca Generali in 2007 following the entry into force of the Italian legislation adopting MiFID into national law, the most recent update to which has been in effect since 12 May 2016. That Policy lays down the approach taken to identify actual and potential conflicts of interest, describes circumstances that may give rise to conflicts of interest, defines the measures to be used to manage such circumstances and specifies the organisational model for managing conflicts of interest, the purpose of which is to ensure that conflicts are managed efficiently over time. The Conflict of Interest Policy has been approved by the Board of Directors;
- the Code of Ethics for the Generali Groups suppliers, adopted by Banca Generali, which lays down the principles of conduct and the resulting behaviour expected of its contractual partners (consultants, suppliers, etc.) when they act on the Groups account.