The CA Auto Bank Group has adopted an internal system for reporting acts or facts that may constitute violations of banking regulations or also other breaches of law (“Whistleblowing”).
Who can make a report?
Possible whistleblowers who can make a report are
- employees and self-employed workers who work or have worked for the Group;
- workers or collaborators who provide goods or services or perform work for third parties and who work or have worked for the Group;
- self-employed professionals and consultants who work or have worked for the Group;
- volunteers and trainees (paid and unpaid);
- shareholders (natural persons);
- persons with administrative, control, supervisory or representative functions (hereinafter referred to as “representatives”).
Through this system, it is possible to report, with the utmost guarantee of confidentiality, violations that harm the public interest or the integrity of CA Auto Bank and Group companies, which may have come to one’s attention in the course of one’s work, or on the basis of one’s legal-economic relationship with the Group, protecting the reporter from possible retaliatory or discriminatory behaviour.
The content of the report
The report may be anonymous, but the reporter may identify himself, if he so wishes. The report must contain a circumstantiated description of the facts and conduct considered to be in breach of the rules, indicating, where possible, also the documents, the rules that are considered to have been breached and any other evidence useful for conducting the investigation into the alleged facts. Finally, the whistleblower is obliged to declare whether he has a personal interest related to the report.
CA Auto Bank’s Compliance, Supervisory Relations & Data Protection Department is the structure in charge of ensuring that the process runs smoothly.
How to make a report
Whistleblowing reports can be submitted using the specific channels indicated below.
- CA Auto Bank Group internal channels
The CA Auto Bank Group uses an internal platform, “BKMS”, provided by the Credit Agricole Group, through which whistleblowing can be reported.
Reports can therefore be made, also anonymously, and can be:
- Written, by accessing BKMS through the following channels:
- on CA Auto Bank hub in the “Code of Conduct” section
- by e-mail to the following address: firstname.lastname@example.org
- Oral, by notifying the Head of Compliance, Supervisory Relations & Data Protection
- Channels outside the CA Auto Bank Group
As a matter of priority, whistleblowers are encouraged to use internal channels and, under certain conditions, may make an external report directly to the competent authorities.
For Italy, It is possible to make an external report to the National Anti-Corruption Authority (ANAC), if one of the following conditions is met at the time of submission
- the mandatory activation of the internal reporting channel is not envisaged within the work context, or it is not active or, even if activated, does not comply with external regulations
- he/she has already made an internal report and it has not been followed up, where follow up means the action taken by the person entrusted with the management of the reporting channel to assess the existence of the facts reported, the outcome of the investigation and any measures taken;
- has reasonable grounds to believe that, if it were to make an internal report, the report would not be effectively followed up or that the same report might give rise to the risk of retaliation;
- has reasonable grounds to believe that the breach may constitute an imminent or obvious danger to the public interest.
External reports to ANAC may be made in accordance with the procedures established by ANAC.