Home Page / Whistleblowing

Whistleblowing

The CA Auto Bank Group (the “Group“) is committed to ensuring that all its activities comply with applicable regulations and are guided by the values of integrity, trust, responsibility, transparency, respect for diversity, commitment, professionalism and confidentiality.

Adherence to these values is paramount for the Bank’s image and reputation based on trust and reliability.

Accordingly, to encourage ethical behavior, the Group has established an internal reporting system (“Whistleblowing“) for alleged anomalies, suspicious behavior, business misconduct, acts or facts that may constitute violations of banking regulations or other illegal conduct, as well as of the principles and rules of conduct contained in the Company’s Code of Conduct.

 

WHO CAN MAKE A REPORT?

Parties who may submit a whistleblowing report include, but are not limited to:

  • employees and independent contractors who work or have worked for the Group;
  • employees or contractors who provide goods or services or perform work on behalf of third parties and who work or have worked for the Group;
  • freelancers and consultants who work or have worked for the Group;
  • volunteers and interns (paid and unpaid);
  • shareholders (natural persons);
  • persons with management, control, supervisory or representation functions.

This system enables reporting parties to submit, with the utmost guarantee of confidentiality, violations that harm the public interest ,or the integrity of CA Auto Bank S.p.A. and Group Companies, and that have come to their attention in the course of their work activity or on the basis of any business or legal relationships with the Group, protecting such reporting parties from possible retaliation or discrimination.

The Compliance, Supervisory Relations & Data Protection Department of CA Auto Bank is responsible for ensuring that the process is carried out correctly.

 

HOW TO MAKE A REPORT

Whistleblowing reports can be submitted through the following specific channels.

  • CA Auto Bank Group internal channels

The Group employs an internal platform (“BKMS”) provided by the Crédit Agricole Group for making reports.

Reports can be submitted, including anonymously, after reading the privacy notice in accordance with the GDPR (General Data Protection Regulation – EU Regulation 2016/679):

  • through the BKMS platform via the provided link or through the corporate intranet of the CA Auto Bank hub in the “Code of Conduct” section. The platform ensures the confidentiality of the reporting party, the facts, and the individuals involved in the report, as well as the Group entity to which the report refers;
  • by email to whistleblowing@ca-autobank.com;
  • orally or in writing, with communication to the Head of Compliance, Supervisory Relations & Data Protection.

As a priority, whistleblowers are encouraged to use the Group’s internal channels. In certain circumstances, they may make an external report directly to the relevant authorities.

  • Channels outside the CA Auto Bank Group

For Italy, reporting parties may submit an external report to the National Anti-Corruption Authority (ANAC), if any of the following conditions are met:

  • there is no provision in the work context for the mandatory activation of the internal reporting channel, or such channel is not active or, even if activated, it does not comply with external regulations;
  • the reporting party has previously made an internal report that has not been followed up on;
  • the reporting party has reasonable grounds to believe that an internal report would not be effectively followed up on, or that such report may result in a risk of retaliation;
  • the reporting party has reasonable grounds to believe that the violation may constitute an imminent or manifest danger to the public interest.

Reports may be made outside ANAC in the manner established by ANAC .

 

Please note that whistleblowing is not the appropriate channel for reporting matters of a commercial nature. Customers wishing to report problems in their relationship with the Bank may file a complaint in accordance with the prescribed procedures.