Code of Conduct - Leone Alato

In this section you will find the Leone Alato's Code of Conduct, adopted by the Board of Directors of Generali Italia, which is the foundation of the Company's cultural identity and defines the basic rules of conduct that employees and members of administrative bodies are required to observe.
Our Code of Conduct is also a point of reference for our consultants, suppliers, agents, etc., and provides specific rules of conduct related to, for example: the promotion of proper business behavior, diversity and inclusion, sustainability, personal information and privacy, free competition and antitrust, prevention of conflicts of interest, abuse of office and corruption, money laundering, terrorist financing and violations of international sanctions.
The Code also enshrines the right to be treated honestly and without discrimination, as well as the right to work for an organization that promotes and rewards work done ethically.
Consistency with the values expressed in our Code helps us build, day by day, a healthy work environment guided by honesty, transparency and impartial behavior.

We want people to feel free to seek clarification and to report behavior or actions considered inappropriate or inconsistent with the law or the Code of Conduct.

Whistleblowing

This section of the website provides information regarding the prerequisites, channels to be used and how to follow in order to make reports of violations of national or European Union regulations (Whistleblowing) or the Code of Conduct that you have become aware of in a public or private work context.

To report any violations of national or European Union regulations or the Code of Conduct, the Company provides a special channel, which guarantees maximum security and confidentiality of information through an encryption protocol, which can be reached at the following link: https://generali.whispli.com/speakup.
Here both written and oral reports can be made anonymously or by name through dedicated telephone lines.

A meeting can be requested through these channels with the Compliance Function, which oversees these channels and is responsible for handling and following up on the reports received.

The report must concern negligent, illegal, irregular or improper circumstances and conduct for which there is reasonable suspicion or of which one has become aware in the performance of one's duties.
The facts pertaining to the alleged violation must be described as clearly and completely as possible to facilitate the initiation of investigative activities.
The report must not concern disputes, claims or demands related to a personal interest in individual labor relations such as, for example, labor disputes or interpersonal conflicts between the reporting person and another worker.
Reporting channels should not be used for irrelevant communications for which dedicated contact points are established (e.g., grievances).

As stipulated in Legislative Decree 24/2023 (Whistleblowing), the Company does not tolerate any form of retaliation against a person who makes a report in good faith or participates in an investigation related to it, and guarantees protection for the identity of the reporter, the reported person as well as other persons, within the limits of the law, and the utmost confidentiality of the information contained in the report.

External Reporting

An external report can be made to the National Anticorruption Authority (ANAC) at the following link Whistleblowing - www.anticorruzione.it in any of the following cases:
- there is no mandatory activation of the internal whistleblowing channel in the work context, or this channel, even if mandatory, is not active or compliant; - an internal whistleblowing has already been made and has not been followed up; - there are well-founded reasons to believe that if an internal whistleblowing were to be made, this would not be followed up effectively or could result in the risk of retaliation; - there are well-founded reasons to believe that the violation may constitute an imminent or obvious danger to the public interest.

For more details, see the Anac Guidelines available on the Authority's website.