The companies in the Banca Ifis Group have their own whistleblowing system for reporting any breaches. The Head of Internal Audit of Banca Ifis S.p.A. is in charge of this system.
Whistleblowers can make use of any of the following channels:
When they use any of these channels, whistleblowers are guaranteed the following legal protection under the Act on the Protection of Whistleblowers, dated June 14, 2024:
It should be noted that the reporting party will also receive protection before any legal relationship with the Bank has begun (if the report of wrongdoing is made during the selection process or at any stage prior to contract); or during their probationary period, or after the end of their legal relationship (if the report of wrongdoing was made during this relationship). This protection also extends to facilitators; to people working in the same setting as the reporting person; to people with whom they have a stable emotional bond or relatives within the fourth degree of relationship; to colleagues of the reporting person who work in the same setting and who have an on-going relationship with that person; to businesses owned by the reporting person or for whom any of the above persons work, as well as businesses that operate in the same context as the aforementioned persons.
The report may relate to any form of behaviour, action or omission on the part of a person belonging to Ifis Finance sp. z o.o. business organization, which breaches Polish or European Union law and which damages or may damage the public interest or the integrity of the Parent Company and/or its Subsidiaries. The report may concern both violations already committed and those not yet committed that the whistleblower has reasonable grounds for believing may well happen.
By way of example but not limited to, the report may concern conduct, actions or omissions consisting of:
A report by a whistleblower should include the following:
The following annual report on the operation of the internal process is brought to the attention of all our staff. It contains aggregated data on the results of the actions carried out after reports were received: Annual report on the correct functioning of our violation reporting (Whistleblowing) system 2023
We should add that the reporting system also includes the following methods of communication in relation to legal breaches (external and public reporting). In these cases whistleblowers – under certain conditions – enjoy the same guarantees of protection as stated above in relation to confidentiality and data processing.
An external report is the transmission of information about a breach of law to:
External reports may be anonymous or identify the reporter. External reporting may be made orally or in paper or electronic form.
Oral reporting may be made:
External report in documentary form may be made:
The competent public authority shall establish a procedure for receiving external reports and following up on them, which shall determine, in particular, the procedure for handling information on violations of the law reported anonymously.
With regard to external whistleblowing reports which are sent on to the relevant authorities, whistleblowers will receive the protections already described in terms of confidentiality, data processing and retaliation.
Whistleblowers may decide to make public disclosure about a legal breach of which they have become aware. They may do so through the press, electronic means or other means of disclosure that will reach a large number of people, if one of the following conditions is met:
If a whistleblower decides to make public disclosure about legal breaches of which he or she has become aware, regardless of the professional secrecy standards applied by journalists to news sources, the whistleblower will benefit from the protections already set forth regarding confidentiality, data processing and retaliation.