Financial Crime World

Internal Audit or Compliance: Whistleblowing Line for Reporting Suspected Fraud

As part of our commitment to integrity and transparency, we have established a Whistleblowing Line for all members of staff to report any suspected fraud anonymously.

Why Report Suspected Fraud?

If you suspect that someone is involved in bribery or corruption, whether it’s a colleague, customer, or supplier, please report it immediately. This is a zero-tolerance policy, and anyone found to be involved in such activities will face severe consequences.

Monitoring and Review

Our Group regularly monitors and reviews procedures designed to prevent bribery and corruption, making improvements where necessary to ensure compliance with regulatory requirements and maintain our reputation.

Governance Structure

To ensure the effective implementation of this policy, we have established a governance structure comprising various roles and responsibilities. These include:

  • Board of Directors: ultimate responsibility for implementing the policy
  • Audit Committee: approves the policy and monitors its implementation
  • Executive Committee (ExCo): reviews the policy and ensures it is embedded throughout our operations
  • Compliance Division: responsible for drafting, enforcing, and updating procedures related to anti-bribery and corruption
  • Risk Management Division: assesses compliance risks and ensures they are within our risk appetite
  • Internal Audit Division: independently evaluates internal controls, policies, and procedures
  • Line Directors: accountable for adherence to this policy within their divisions
  • Local Managers or Regional Managers: responsible for informing their teams about gifts related to their area
  • Legal Services: provides general advice on relevant legislation and support on legal issues
  • Organization Department: communicates the policy to all employees and incorporates its key principles into procedures
  • Procurement Department: develops sourcing, procurement, and vendor management policies and procedures
  • Human Resources: incorporates anti-bribery and corruption provisions into codes of conduct and ethics

Reporting Incidents

If you become aware or suspect that an activity or conduct could be considered a bribe or corrupt, please report it immediately to your direct supervisor or line manager or via our Whistleblowing Line. All incidents will be properly investigated and addressed.

Exception Approval Process

In cases where a deviation from this policy is requested, we have established an exception approval process. This requires justification, compliance with legal and regulatory frameworks, and approval from the Chief Compliance Officer and CEO or Deputy CEO.

Implementation Procedures (Key Processes)

We have implemented various procedures to ensure compliance with this policy, including:

  • Approval for gifts over €50: by higher authority
  • Approval for gifts over €100: by two-level higher authorities
  • Recording all gifts in a gift registry
  • Assessment of gifts for conflicts of interest and rejection if necessary
  • Documentation of potential conflicts of interest and controls to minimize them

We are committed to maintaining the highest standards of integrity and transparency, and we appreciate your cooperation in reporting any suspected fraud or corruption.