The Value of Ethics

We are committed to ensuring transparency and fairness in business management, promoting a corporate culture based on legality, ethics and integrity.

In managing our activities, we are committed to observing the fundamental principles of correctness and consistency, with a view to:

  • Create a corporate culture aimed at achieving the best economic result in compliance with ethical principles;
  • Meet the expectations of shareholders and all stakeholders;
  • Protect the reputation of Group companies.

Corporate integrity and the fight against corruption are a priority for us, and the top one in the Materiality analysis. Our commitment takes the form of Ifis Integrity , the first pillar of sustainability strategies.

Code of Ethics

The Code of Ethics represents the “manifesto” of the corporate culture of Banca Ifis and of the other Group companies, intended both for the information/training of collaborators and for the diffusion of this culture among all stakeholders.

The Code of Ethics, last updated on 14 January 2021, sets out the rights, duties and responsibilities of the Group companies with respect to all the subjects with which they enter into relations. It establishes rules of conduct for day-to-day operations as well as reference standards and behavioural norms aimed at strengthening business decision-making processes and guiding the conduct of all employees.

In accordance with the principles laid down in the Code of Ethics, all group employees must behave ethically in their relationships with colleagues, customers, debtors, suppliers, competitors, and public institutions. Illegal or unethical behaviour, including with reference to legal provisions, codes and internal regulations, is not acceptable.

Organisational, Management and Control Model

The Code of Ethics is an integral part of the Organisational, Management and Control Model set forth by Legislative Decree 231/2001, i.e. the set of principles, rules, provisions and organisational schemes that constitute a control and monitoring system for sensitive activities, in order to prevent the commission of the crimes envisaged by the aforementioned Legislative Decree (“Model 231”). We are convinced that the adoption of Model 231 can constitute a valid tool for raising awareness among employees and collaborators, promoting correct and linear conduct in the carrying out of activities.

Model 231 was adopted for the first time in 2004 and is constantly updated to take account of regulatory changes. In October 2020, the Parent Company’s Model 231 was updated in order to give relevance to the importance of reform of the Special Part and to proceed according to the ordinary guidelines that characterise the structuring of a Model 231, centred on the identification of existing processes and their formalisation, the mapping of the inherent risks and the preparation or improved explanation of the related safeguards.

Supervisory Board

The task of supervising the functioning of and compliance with the Model is entrusted to the Supervisory Body (“SB”). The SB also has the task of supervising compliance with and application of the Code of Ethics, taking any disciplinary action and promoting periodic review of the Code.

The Board of Directors has decided not to entrust the duties of the Supervisory Body to the Board of Statutory Auditors: the SB is composed of a Statutory Auditor, the Heads of the Internal Audit and Compliance departments and two independent directors, one of whom serves as President. The SBs of the Parent Company and of the subsidiaries have autonomous powers of initiative and control.


The Organisation, Management and Control Model and the Ethical Code also lay down the guidelines for preventing the risk of commission of the crimes of corruption and extortion.

The Code of Ethics sets forth that, in managing the relationships with the Public Administration, it is forbidden to promise or offer public officials or employees payments or goods to promote or advance the interests of the Group when stipulating and awarding contracts, granting and managing authorisations, collecting debts (also from the Treasury), and during inspections or controls or in the context of judicial proceedings.

All employees must know and comply with the rules on combatting corruption.

For further information on the training received by employees on anti-corruption policies and procedure.

Anti-Money Laundering

Preventing the risk of money laundering is key for protecting the Bank’s financial strength and, more generally, its reputation, and reflects our constant effort to actively co-operate with Supervisory Authorities.

We refuse to do business, either directly or indirectly, with individuals or companies that are known or suspected members of organisations engaging in criminal or illicit activities. This principle is translated into specific procedures and checks in the Leasing and Commercial Credit business areas, and in the NPL sector.

Training our resources on anti-money laundering is not just a legal requirement: it allows us to raise awareness and promote a culture among employees of preventing the risk of unwittingly involving the Bank in this kind of incidents.

Click here to download the Patriot Act Certification

Click here to download AML Questionnaire

Click here to download KYC/AML Questionnaire Correspondent Banking Form


We have set up an internal system to allow facts, actions and omissions that may constitute a violation of the law and of internal procedures to be reported, while guaranteeing the confidentiality of the personal data of the person doing the reporting and of the presumed perpetrator of the violation. The system aims to contribute towards guaranteeing a working environment in which staff may report behaviour they deem illegitimate with peace of mind, without the fear of reprisals or discrimination.

For further information on the procedure.

The reports may concern, for example, actions or omissions, committed or attempted, that may cause financial damage to the Group, harm the health or safety of staff or clients, or of the environment.

The reports are handled by the Head of Internal Audit, who performs the checks required to ascertain the truthfulness of the report, in full compliance with the principles of impartiality, privacy, dignity of the employee and protection of personal data.


Discover the Banca Ifis Group Whistleblowing platform.

Violation reporting system annual report

Read the Annual report about the correct functioning of the violation reporting system.