Whistleblowing

Our system for reporting illegitimate behaviors - "Whistleblowing"

UniCredit S.p.A. is committed to promoting a corporate culture based on ethical behavior and good corporate governance, thus fostering an environment in which People are encouraged to report unacceptable conduct within the Group.

For this reason, specific channels, processes and procedures are in place at UniCredit to ensure confidentiality and the absence of retaliatory acts to people who report illegitimate conduct.

Violations and/or irregularities related to the issues governed by the attached Whistleblowing Policy and external regulations may be reported.

More specifically, but not limited to:

• Bribery and corruption;
• Money Laundering;
• Violation of Financial Sanctions regulations;
• Violation of antitrust laws;
• Insider trading and/or market manipulation;
• Harassment;
• Bullying;
• Fraud;
• Misuse of confidential customer and Company data;
• Violation of the Code of Ethics and/or Code of Conduct;
• Violations of the Organization and Management Model pursuant to Legislative Decree 231/01.

Reports should be submitted through the use of one of the following channels:

The channels mentioned cannot be used to propose a complaint regarding the business relationship, but only to report illegitimate behavior.

The Compliance function and the specifically established Working Group (Whistleblowing Working Group) ensure that your information will be carefully considered and treated with absolute confidentiality.

External reporting channels

UniCredit Group encourages employees to use internal channels as a priority.

It should be noted that in Italy, in implementation of Legislative Decree n. 24/2023, the National Anti Corruption Authority (ANAC) has been identified as the authority responsible for receiving and handling external reports, also anonymously.

The Whistleblower may therefore make an external report to ANAC if, at the time of its submission, one of the following conditions is satisfied:

• there is no provision within his or her work context for the mandatory activation of the internal reporting channel, or this channel, even if mandatory, is not active or, even if activated, does not comply with the provisions of the law;
• has already made an internal report and it has not been followed up;
• has reasonable grounds to believe that, if it were to make an internal report, it would not be effectively followed up or that the same report could lead to a risk of retaliation;
• has reasonable grounds to believe that the violation may constitute an imminent or evident danger to the public interest.

In addition, the Whistleblower may also contact ANAC to notify any retaliatory acts resulting from a report.

External reports to ANAC may be made in the manner provided on the institutional website of the entity.

Attachments:

• Privacy Information notice

• Procedure for managing reports of misconduct - Whistleblowing 

• SpeakUp® Information and FAQ

• Global Policy on Whistleblowing