Violation Reporting Systems - Whistleblowing

Eurizon Capital S.A. has an internal system for reporting acts or facts that may constitute violations of rules governing the Company activities or other unlawful conduct (Whistleblowing).

Who can make a report

According to the EU Directive no. 2019/1937 of the European Parliament and of the Council of 23 October 2019, the following subjects can make a whistleblowing report:

  • employees and civil servants;
  • self-employed workers;
  • former employees;
  • prospective employees;
  • contractors, subcontractors and suppliers;
  • volunteers and paid or unpaid trainees;
  • shareholders (natural persons);
  • individuals with administrative, control, supervisory or representative functions including non-executive Members.

The Whistleblowing process, which integrates the other reporting systems and processes active in the Company, makes it possible to report, with the utmost guarantee of confidentiality, violations that damage the public interest or the integrity of Eurizon Capital S.A. of which become aware within the working context, or on the basis of the legal-economic relationship existing with the Company, protecting the whistleblower from any possible retaliatory or discriminatory behaviour.


How to make a report

Whistleblowing reports can be sent using the specific channels indicated below (available 24 hours a day, 7 days a week, in Italian and English version).

The report must allow the identification of the whistleblower (name and surname, relationship with the company and contact details) and must contain a detailed description of the facts and conduct considered to be in conflict with the law, also indicating, where possible, the documents, the rules that are considered to have been violated and the other findings useful for conducting the investigation of the disputed facts. Finally, the whistleblower has the obligation to declare whether she/he has a personal interest connected to the report.
The Internal Audit function ensures the correct execution of the process.


INTERNAL CHANNELS of Eurizon Capital S.A.

The report can be made, using the following communications way:

written, using the main channel, by sending an email to:,
to which the Head of Internal Audit has access.

Communications are managed through specific channels, segregated and independent from the ordinary ones.

The whistleblower may also request, through the above-mentioned channel, a meeting aimed at making the report. The meeting will be scheduled within a reasonable time by the Whistleblowing Team.

The personal data and information acquired by Eurizon Capital SA following the "Whistleblowing" report will be processed by the same in its capacity as Data Controller for the related management and will be kept no later than 5 years after the ending of the procedure and has as its legal basis the fulfilment of an obligation by law.
Privacy notice pursuant to the GDPR (General Data Protection Regulation - EU Regulation 2016/679).


EXTERNAL CHANNELS of Eurizon Capital S.A.

As a priority, whistleblowers are encouraged to use internal channels and, if certain conditions are met, they can carry out an external report to the competent Authorities.

It is possible to carry out an external report, for Luxembourg, to the competent Authorities listed at art. 18 of the Luxembourg law of 16 May 2023, if at least one of the following conditions occurs at the time of its submission:

  • the mandatory activation of the internal reporting channel is not envisaged within the working context, i.e. this channel is not active or, even if activated, does not comply with external regulations;
  • an internal report has been already made and it has not been followed up, where follow-up means the action undertaken by the person entrusted with the management of the reporting channel to assess the existence of the facts reported, the outcome of the investigations and any measures taken;
  • there are reasonable grounds to believe that, if she/he were to carry out an internal report, it would not be followed up effectively or that the same report could lead to the risk of retaliation;
  • there are reasonable grounds to believe that the violation may constitute an imminent or obvious danger to the public interest.


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