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SECOND LEVEL OF CONTROLS
- Compliance and Anti-money laundering – Dott.ssa Giulia Sala
- Risk management – Dott. Luca Coppola
THIRD LEVEL OF CONTROLS
- Internal audit – Marcello Fumagalli, BDO Italia S.p.A.
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- Implementation of Law 231 requirements since inception
- Best standards in internal procedures according to regulation and at technical level (procurement, bid process, etc.)
- Click here to consult the Code of Ethics
- Click here to consult Model 231
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- Chairman – Avv. Mario Ippolito
- Effective member – Dott.ssa Anna Maria Allievi – President of Board of Statutory Auditors
- Effective member – Dott. Paolo E.G. Ciocca – Statutory Auditor
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Reports can be submitted:
For internal reports
a. electronically via the portal by selecting COIMA SGR S.p.A. (for all reports except those concerning the Whistleblowing Officer)
b. in paper form, to the attention of the Head of the Compliance Function – Piazza Gae Aulenti, 12, 20124 Milano MI. To ensure confidential protocolling of the report by the Whistleblowing Officer, the report must be placed in two sealed envelopes: the first with the whistleblower’s identifying data and a photocopy of identification; the second with the report, separating identifying data from the report content. Both envelopes must then be placed inside a third sealed envelope marked externally “Strictly confidential. Reserved for the Whistleblowing Officer”, to guarantee maximum confidentiality.
For external reports
a. if directed to ANAC (for violations of EU provisions), please refer to www.anticorruzione.it
b. if directed to Consob (for TUF violations), please refer to http://www.consob.it/web/area-pubblica/whistleblowing
- Click here to download the Whistleblowing notice
- Click here to download the Whistleblowing privacy notice
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Complaints procedure available for consultation. Financial Disputes Arbitrator website: acf.consob.it
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Policy summary available for download.