Whistleblowing

Banca Sistema S.p.A. is committed to conducting its business in accordance with the principles of honesty and integrity and, likewise, expects its employees to adhere to the highest standards. For this reason, the Company encourages employees to report any violations whenever they observe improper, unlawful, or negligent conduct in the workplace, ensuring they feel comfortable doing so without fear of repercussions of any kind. Banca Sistema S.p.A. supports all reports made in good faith with the aim of upholding the ethical principles to which it is committed. Violations and/or irregularities related to the matters governed by the attached Whistleblowing Policy and external regulations may be reported. By way of example, and without limitation, the following may be reported:

• any action related to money laundering or terrorist financing;
• any misconduct, fraud, or active or passive corruption;
• any act or omission committed in the course of work that impacts such work, or that causes or may cause harm or damage—even if only to the Bank’s reputation—to the Bank and/or its employees;
• unlawful conduct in the exercise of delegated authority;
• violation of confidentiality obligations;
• conduct that is not in line with internal company policies;
• a threat to the safety or health of an individual;
• discrimination of any kind involving the Bank or its employees;
• any other unlawful act whose commission may affect the Bank’s activities and/or its reputation. Reports may be submitted using one of the following methods provided for by Legislative Decree No. 24/2023:

Web Channel

Through the IntegrityLog platform, which allows you to submit a report in writing, ensuring a high level of security and confidentiality:

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Regular Mail

By sending a written report via “registered” mail to the following address:

Banca Sistema S.p.A. Att.ne del Presidente del CCIGR Largo Augusto, 1/a ang. Via Verziere, 13 20122 Milano

The report must contain a detailed description of the reported incident and any other information known about it (e.g., names of those responsible for the incident, other individuals involved or aware of the event, the time period during which the described events took place, etc.), and must include any supporting files (documents, photos, etc.).

Please note that the Whistleblowing channel cannot be used to submit a complaint regarding a business relationship, but only to report unlawful conduct.

Furthermore, the reporter may always contact the National Anti-Corruption Authority (ANAC, www.anac.it) as appropriate and in accordance with the procedures specified by ANAC.