In our daily work, we strive to combine profitability and competitiveness with respect for the highest standards of professional ethics. Discretion, professionalism, integrity and utmost respect for the law are some of the values that guide us in our work. It is no coincidence that business ethics and integrity are among the most material topics in our materiality matrix.

The Code of Ethics and Code of Conduct

Since 2010 we have followed a Code of Ethics containing frames of reference and guiding principles that complement our legal obligations and self-imposed commitments and steer the conduct of our people, confirming and upholding our group’s mission and fundamental values.

A reputational safeguard

We firmly believe that honourable and transparent conduct improves and protects our reputation, credibility and standing with the public, regulators and institutions over time.
This is why all conduct must be based on lawfulness, transparency, good sense and personal ethics, in accordance with our values, guiding principles and business procedures and with the knowledge needed not to expose the group to compliance or reputational risks.


The values and principles set forth in the Code of Ethics are fundamental for the definition of a sound corporate governance system and the logical basis for the creation of an adequate internal control and risk management system.
These are the values and principles that we uphold in all our operations:

  • integrity and honesty;
  • objectiveness;
  • professionalism and empowerment of resources;
  • discretion;
  • management of conflicts of interest;
  • transparency and thorough information;
  • protecting health;
  • protecting the environment;
  • protecting copyright and intellectual property rights;
  • proper use of corporate assets.

All the group companies have adopted the Code of Ethics, and it applies to directors, statutory auditors, employees, consultants, interns, freelancers and suppliers.

Management of conflicts of interest

We have adopted a specific policy for the management of conflicts of interest which enables us to identify, prevent and manage any situations in which the bank could act in such a way that compromises a customer’s interests in the pursuit of its own or those of another customer. This policy also enables us to identify any personal conflicts of interest of employees, who are required to immediately report any situations so specific safeguards may be implemented.

Furthermore, a directive on outside personal interests requires employees to obtain authorisation from senior management before acquiring any personal economic interests or accepting positions in companies outside the group.

Along with the Code of Ethics, the Code of Conduct establishes the fundamental principles underpinning the bank’s reputation and frames the values that the bank upholds in its day-to-day operations. It is the ethical frame of reference governing the bank’s internal and external relationships and describing the standards of conduct that all of Mediobanca’s employees and freelancers must uphold.
The fundamental values are:

  • good conduct;
  • discretion;
  • professionalism;
  • independence.

Those subject to the Code of Conduct are required to be proactive. They must participate in the bank’s training courses on the relevant legislation, promote the spread of an ethical culture, set a positive example for their colleagues and immediately report any violations, cooperating in investigations if necessary.
Violations of the Code of Conduct and internal regulations may affect employees’ bonuses and result in disciplinary action according to the gravity, entity and external impact of the breach.

The 231 Model

We have adopted an organizational model in compliance with Italian Legislative Decree no. 231, named the 231 Model, to prevent crimes from being committed in the bank’s interest or to its advantage. The model outlines rules of conduct and identifies controls on the basis of the ethical principles in the Code of Ethics and banking association guidelines. We have also established a supervisory body to monitor the functioning and effective application of the model.


Under Italian Legislative Decree no. 231 of 8 June 2001, companies may be held liable and consequently sanctioned for certain crimes that directors or employees commit or attempt to commit in the interest of their company or to its benefit. However, companies are not liable if they have adopted and effectively implemented organizational, management and control models to prevent these crimes and if they have established a supervisory body responsible for monitoring the functioning and compliance of the models.

In July 2018, the Board of Directors approved the updated 231 Model following developments in the legislative framework and significant changes in the group’s internal organization, such as the creation of the Private Banking division.
The organizational model includes:

  • a general section, which provides an overview of the model’s guiding and operating principles, along with legislative references;
  • special sections, namely:
    • mapping of crimes and at-risk activities;
    • the group’s Code of Ethics;
    • information flows to and from the supervisory body;
    • the list of crimes describing the predicate offences applicable for the bank.
Fight against corruption

We do not tolerate active or passive bribery.

We earn and preserve our business relationships solely on the basis of our service offer and our ability to meet customers’ specific needs. We do not act in any way that is or could appear to be intended to obtain or offer undue advantage and we work to prevent acts of bribery in the structuring and execution of transactions and business agreements.

To prevent corruption and ensure compliance with all applicable regulations, we have established internal rules, procedures and controls and regularly hold training courses and conduct monitoring. In particular, we are currently drafting an anti-bribery directive.

All companies in the group’s scope have adopted anti-bribery policies and procedures.

Formazione 2 EN

We have a specific policy defining the principles, methods and safeguards for employees who report (anonymously or otherwise) any malfunctioning in the organizational model or internal control system, any other irregularity in operations or violations of banking regulations.

Approved by the board of directors and updated in July 2018, the whistleblowing policy provides for the proper management of whistleblowing reports, ensuring the confidentiality of the parties involved. The policy also establishes a liaison with the supervisory body, which receives reports in connection with Italian Legislative Decree no. 231.

Anti-money laundering

We have adopted processes, tools and controls to fully follow the principles in our anti-money laundering policy, ensuring the traceability of checks and the training of our people.

Prudent approach to risks

We stand apart for our prudent and selective risk management approach, which can be seen in our excellent asset quality and high capitalization, which surpasses minimum capital requirements and is one of the highest among Italian banks.


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