System for reporting suspected misconduct "Whistleblowing"
UniCredit is committed to foster a corporate culture based on ethical behaviour and good corporate governance, creating an environment where employees are encouraged to report unacceptable or illegal conduct.
Therefore, UniCredit has specific channels, processes, and procedures in place to ensure confidentiality and protection against retaliation to persons who report suspected misconduct in good faith.
Suspected breaches and/or irregularities, related to issues governed by the attached whistleblowing policy and external legislation, may be reported, in particular as regards the following conduct:
1. Bribery and corruption
2. Money laundering, financing of terrorism or other types of financial crime
3. Breaches of financial sanctions rules
4. Violation of antitrust laws
5. Insider dealing and/or market manipulation
6. Harassment
7. Bullying
8. Fraud
9. Misuse of confidential data
10. Breach of the Code of Conduct
11. Violations of other laws and regulations applicable to UniCredit
Reports can be submitted through one of the following internal channels:
Sending a written report to:
UniCredit Banka Slovenija d.d.
DON'T OPEN – FOR: COMP, Head of Compliance
Ameriška ulica 2, 1000 Ljubljana, Slovenija
To the following address:
Request a physical meeting or call:
By sending a request to UniCredit Bank,
DON'T OPEN – FOR: Head of Compliance, Ameriška ulica 2, 1000 Ljubljana, Slovenija or by e-mail to: whistleblowing@unicreditgroup.si
Notice
These channels cannot be used to complaint regarding a business relationship, but only to report illegal behaviour.
The compliance function and a specially established working group (Working Party on Whistleblowers) ensure that your data is handled with due care and treated in complete confidentiality.
External reporting channels
UniCredit encourages employees to prioritize the use of internal channels.
The whistleblower may be reported to external authorities where one of the following conditions is met at the time of submission:
- in whistleblower’s work environment there is no provision on mandatory activation of internal reporting channel, or such channel is not active or even if it is active, however is not in line with the law;
- has already submitted an internal report and has not received, within three months of receipt of the report, any feedback of the merits of the report, of the measures proposed and implemented, of the outcome of the procedure, or of the status of the internal report procedure, if the remedial procedures have not been completed after three months;
- have reasonable grounds to believe that internal reporting would not be addressed effectively or that the reporting could create a risk of retaliation;
- has reasonable grounds to believe that the infringement could constitute a direct or obvious threat to the public interest.
In addition, the whistleblower may contact external authorities and inform them of retaliation received for his or hers report.
A whistleblower may also use public whistleblower disclosure where:
- he/she has previously submitted an internal and/or external report and has not received a response within three months of receipt of the report regarding the planned or taken measures to the reports;
- has reasonable grounds to believe that the infringement could constitute a direct or obvious threat to the public interest, in particular a danger to life, public health and safety, or if there is a risk of irreparable damage;
- has reasonable grounds to believe that the external reporting could create a risk of retaliation or it will not be effectively addressed due to the specific circumstances of the individual case, especially when the evidence could be hidden or destroyed, or when the external reporting authority colludes with the perpetrator of the violation or is involved in the violation.
