Monitoring against corruption

The ways that risks of corruption are handled and the prevention measures taken are to be found in Intesa Sanpaolo’s Organisational, management and control model pursuant to Legislative Decree 231/01.
In reference to the risk of administrative liability introduced by the decree, the Compliance Department is responsible for guaranteeing the long-term existence of operating rules, procedures and practices to prevent effectively the violation or infringement of regulations in force. It also provides support to the Surveillance Body in monitoring the effectiveness of the Model with regard to rules and principles of conduct to prevent sensitive offences. Should any non-compliance occur, the Compliance Department provides support and cooperation to the business unit affected to ensure that action required to bridge organisational and procedural gaps is identified and implemented.
Again with regard to the risk of administrative liability introduced by the decree, the Audit Department operates across the board, in particular with regard to:

  • monitoring observance of the Model;
  • monitoring and participating in reviews and updates of the Model;
  • preparing information flows to the internal Surveillance Body on the effectiveness and observance of the Model;
  • recommending corrective action as necessary.

In 2009, the Internal Audit’s assessments, conducted on behalf of the Surveillance Body, covered various areas/processes of the Bank, including the following topics which are particularly 'sensitive' to Legislative Decree 231/01: control systems in the pawn activities, financing of related parties, management of government funds for research and development, management of the 'dormant accounts', the process of issuing certifications and communications for Meetings, Tax Refunds process on behalf of Financial Institutions category customers, management of corporate fiscal duties, management of criminal, administrative and bankruptcy litigations, management of the Consolidated Financial Statements, treasury services for Public bodies, money laundering compliance.
The Bodies Administrative Responsibility Office of the Compliance Department also carried out intervention aimed at determining the ability to oversee and govern risks on the matter.

Great attention is paid to risk connected with corruption within all the Group companies and, for the Italian companies, the organisational and surveillance models under the terms of Legislative Decree 231/01 have been adopted. Likewise, high-level monitoring of corruption-related risk is also applied in the International Subsidiary Banks, especially where specific national laws exists on the matter. In countries without such regulations, the subsidiaries are in any event expected to apply the Parent Company guidelines and perform controls in areas of greater risk.