Charter of Values and Code of Ethics

The Group’s Charter of Values, approved by the Board of Directors of the Company on 11 December 2008, is the result of an impressive collective effort: all employees of Group Companies and a number of agent representatives actively participated in the drafting process – over 6,000 people in total.

The Charter of Values formed a basis for the preparation of the Group’s Code of Ethics, at the beginning approved by the Board of Directors on 19 March 2009. The first version of the Code was updated to take into account the evolution of the Unipol Group in recent years and to meet the highest international standards, and most recently approved in its latest version by the Unipol Board of Directors on 23 March 2017. The Code of Ethics outlines the standards of conduct the Group observes in its relationships with all stakeholders.

The Code of Ethics applies to all Group Companies: it is addressed to everyone who influences or who is in any case impacted by Group activities: investors, directors, employees, agents, professionals, customers, suppliers, civil society and future generations.

In order to ensure the application of the principles expressed in the Code of Ethics and to guarantee its effectiveness, the Board of Directors of Unipol Group established two bodies:

• the Ethics Committee, consisting of no less than three and no more than five directors who meet the independence requirements prescribed by applicable laws and regulations (currently consisting of three members);
• the Ethics Officer, selected from qualified and independent candidates, with in-depth knowledge of the Group and recognised sensitivity regarding issues of ethics and corporate responsibility (office currently held by Walter Visani, a Unipol employee since 1982).

The two bodies have a proactive role regarding the content and purpose of the Code and are responsible for its promotion, proper interpretation and implementation.

In particular, requests for information or clarification regarding the content of the Code of Ethics and reports of alleged violations of the principles outlined in the Code of Ethics may be submitted to the Ethics officer, which will be treated with the utmost confidentiality and receive a reply within 30 days (extended to 60 days for more complex cases).

Since the Code is a voluntary self-regulatory instrument, all Stakeholders may submit reports to the Ethics Officer, except for cases in which other courts have been involved.

In order to be taken into consideration, reports of alleged violations of the Code of Ethics should be sent to the Ethics Officer, in written and non-anonymous form, in the following manners:

a)     via email, to the address responsabile.etico@unipol.it
b)    via ordinary post, to the address: Unipol – Ethics Officer, via Stalingrado, 45 – 40128 Bologna

Any requests for clarification and/or informed opinions on the most appropriate conduct models for avoiding violations or non-compliance with the Code of Ethics can be made over the phone by contacting the number 051-5077111.

The Charter of Values and the Code of Ethics, in their most recent version, have been adopted by the Board of Directors of the Company with approval of 10/05/2017