Legislative Decree no. 231/2001 and Anti-corruption

illimity has adopted an Organisation, Management and Control Model (OMCM) – consisting of a General Part and a Special Part– as a structured and organic prevention, dissuasion and control system designed to mitigate the risk of possible unlawful conduct by personnel, from which the administrative responsibility of the Company could derive pursuant to Legislative Decree no. 231 of 8 June 2001, by identifying the Bank’s Sensitive Activities and formalising the controls existing within the Bank. The document illimity Way forms an integral part of the OMCM, being an integrity manual discussing the illimity Group’s identity, values, commitment, persons and resources.

Further, with specific reference to the risk of committing acts of corruption, illimity has adopted an Anti-corruption Policy that governs the principles and rules of conduct that staff are required to comply with, within the activities identified as being more highly exposed to corruption risk.