We therefore consider observance of the Code as a value in itself. At the same time, we expect those with whom we have dealings to act according to similar ethical principles and which are in any case consistent with universally accepted principles concerning human rights, work, the environment and commercial practices.

Relationship with other sources of regulation

The regulations of this Code do not replace, but are in addition to those adopted in relation to specific external regulations, whether they are of a compulsory or voluntary nature. Observance of them is therefore based on the assumption of respect for the courts and a constant commitment to working in full compliance, with the provisions of the law and the regulations of public authorities in force in the different countries and environments of UBI’s activities, with externally established voluntary codes and regulations which we observe or shall observe in future and  with internal procedures.

The Code of Ethics is an essential component of the model of organisation, management and control adopted by the Bank in accordance with and for the purposes of Legislative Decree No. 231/2001, because it adds to that model in terms of the expression and communication of the Bank’s values, principles and rules of behaviour and it also contributes to the implementation of the universal principles committed to by signing the Global Compact.

Distribution

The Code of Ethics is published on the Group website and may be consulted by personnel by viewing internal regulations on the corporate intranet. A copy is delivered to members of corporate bodies when they accept their appointment, to newly recruited personnel and to all those who do business with the Group under contract or who represent the Bank without being subordinate to it (e.g. business partners, agents, consultants, sales persons and other independent associates), when a relationship is established. Major suppliers are required to sign a declaration of acceptance as part of the respective contract documents.

We have planned an integrated programme of training and internal communication for the second quarter of 2011 in order to facilitate understanding and practical implementation of the Code. The programme consists of seminars for management, classroom training for the heads of operational units, remote training for employees in general and educational activity and the provision of specialist information on the corporate intranet and through the in house organ. 

Implementation

All the operational and management units of the Parent and of subsidiaries work to disseminate and promote knowledge and understanding of the Code and observance of it both internally and among their Stakeholders. In this context:

• the heads of each organisational unit - as persons responsible for first level controls - are required to perform their duties of supervision and control over the personnel for which they are responsible and this includes in relation to observance, in form and substance, of the rules of this Code and those it makes reference to;

• by means of monitoring and control activities conducted by organisational units as part of the system of internal control, the Bank verifies that its regulatory and organisational systems are consistent with the objective of preventing violation of the Code of Ethics and it ascertains the actual compliance of individual conduct and transactions performed with the ethical principles and general principles of conduct laid down (ethical auditing).

The Corporate Social Responsibility Staff unit of the Parent provides support and advice for training and communication activities and for the interpretation and implementation of the principles of the Code. It provides for adequate monitoring procedures and also identifies appropriate performance indicators. It co-operates in the implementation of corrective action concerning organisation in relation to violations detected or to potential difficulties that emerge from monitoring, compliance and ethical auditing activities and it formulates proposals for the amendment and update of the Code.

Violations

Reports of violations of the Code are sent in written and not anonymous form to:

UBI Banca

Responsabile Audit di Capogruppo e di Gruppo

Piazza Vittorio Veneto, 8

24122 Bergamo

or to the email address

codice.etico@ubibanca.it

The Parent and Group Audit unit will file the report and make a first assessment of it to determine its level of importance and will then forward it to bodies with operational functions and with control functions (Management Board, Supervisory Board, Internal Control Committee) and:?

• to the Supervisory Body, if the alleged violation is significant for the purposes of regulations pursuant to Legislative Decree No. 231/01;
• to the organisational unit that manages relations with the stakeholder who has committed the alleged violation, or to the relevant body in other cases.

Reports received are treated with strict confidentiality insofar as the Law allows. Persons making reports are protected against any form of retaliation, discrimination or penalisation, without prejudice to the right of the Bank to act to protect its reputation and personnel and to repair damages that may have been incurred as a consequence of reports made in bad faith.