In accordance with regulatory provisions, illimity SGR has established an internal system designed to enable internal/external parties to report (through a whistleblowing process) actions and facts that may constitute a breach of Italian and/or European legislation applicable to the activity carried out by the Company. At the same time the internal system guarantees the confidentiality of the personal data of the whistleblower, the party allegedly responsible for the breach and any other parties mentioned, as well as safeguarding the whistleblower from retaliatory and/or discriminatory conduct.

The whistleblowing must contain a detailed description of the breach and an indication, where possible, of the rules that are considered to have been breached, any other information that may be useful in performing a verification of the contested facts and lastly an email address of the whistleblower in order to receive a receipt confirmation and the specific code required to monitor the progress in the web tool @Whistleblowing.

More specifically, in this context breach shall mean any:

  • unlawful administrative, accounting, civil or criminal action;
  • contrary conduct to the internal and external laws and regulations applicable to the activity carried out by illimity SGR, including those contained in the Company's Organisation, Management and Control Model (OMCM), and in the integrity manual discussing the illimity Group's identity, values, commitment, persons and resources ("illimity way");
  • unlawful acts that fall within the scope of European Union law, relating to financial products and markets; the prevention of money laundering and financial of terrorism; personal data protection; and network and information system security;
  • actions or omissions regarding consumer protection;
  • actions or omissions regarding state aid;
  • actions or omissions that harm the financial interests of the European Union.

Sending a whistleblowing through internal channels

A breach can be reported in the following ways:

  • by using the web tool link @Whistleblowing;
  • by sending a written report to: Head of Internal Audit, Via Soperga 9, 20127 Milan, Italy;
  • by calling the following dedicated phone numberin order to contact the Head of Internal Audit: (+39) 02-82849697.

Response time

With the support of the web tool @Whistleblowing the Head of Whistleblowing will send:

  • receipt confirmation within 7 days of the whistleblowing;
  • verification results within 3 months of receipt confirmation's date of the whistleblowing.

The above channels cannot be used to send a complaint regarding the financial services provided by the Company.

Sending a whistleblowing through external channels

A breach can be reported through the external channels set up by:

  • The National Anti-Corruption Authority (Autorità Nazionale Anticorruzione - ANAC), by following the procedures published on the website https://www.anticorruzione.it/-/whistleblowing
    Whitleblowing can only be carried out if:
    • an internal whistleblowing hasn't been followed up;
    • there are grounded reasons for believing that the internal whistleblowing wouldn't be followed up or could lead to retaliation;
    • there is a grounded reason for believing that the breach constitutes an imminent or obvious risk to the public interest.
  • Consob, by following the procedure published on the website https://www.consob.it/web/area-pubblica/whistleblowing

Reference documents

illimity Società di Gestione del Risparmio S.p.A. | Headquarters: 9 Via Soperga - 20124 - Milan Share capital €1,000,000.00 fully paid in.
Enrolled in the Milan Business Register - Economic Registry (REA) no.: MI 2567666 - Tax no. 10936730968 - Participating company in the “illimity” VAT Group VAT Number 12020720962. Enrolled in SGR register ex art. 35 TUF - sezione gestori di FIA n. 183.
Sole shareholder company in the illimity Bank S.p.A. Group, enrolled in the Register of Banking Groups with no. 245.
Company subject to management and coordination by illimity Bank S.p.A.