BNP Paribas whistleblowing framework

If you are a customer of BNP Paribas and wish to report any dissatisfaction or complaint, please approach your usual business contact or the person in charge of customer complaints.

 

BNP Paribas Group is committed to strict compliance with laws and regulations and to enforce the rules set out in the Group's Code of Conduct .

The whistleblowing framework, accessible from this page, allows you to report information about a crime or an offence, a threat or damage to the public interest, a violation or an attempt to conceal a violation of applicable and binding law (laws, regulations, etc.) or a breach of the Group's Code of Conduct .

Whistleblowing reports are managed by the HR Conduct Referent - “Respect for People” and the Compliance Whistleblowing Referent in a confidential manner and in compliance with the current regulations.

Whistleblowers are granted protection against the risk of retaliation provided by local applicable law, provided that in the report they openly declare that they wish to take advantage of this benefit. In the absence of a clear indication, the report could be treated as ordinary. However, it should be noted that the BNP Paribas Group manages ordinary reports, guaranteeing the same confidentiality and protection safeguards provided for Whistleblowing reports. ​

Any abuse of the whistleblowing framework may expose the whistleblower to criminal proceeding and/or disciplinary sanctions (if employee), however, the good faith use of such framework will not expose the whistleblower to any disciplinary sanctions, even if the facts subsequently prove to be inaccurate or do not give rise to any follow-up.

By submitting a report, you declare that you have read and understood the information relating to the BNP Paribas Whistleblowing Framework and the Data Protection notice .

 

Frequently Asked Questions

Find below the most frequently asked question: ​

  • When to report?

    When you have reason to believe that a violation of the law or the BNP Paribas Code of Conduct has been committed or in the event of a threat or harm to the public interest.

  • How to report?

    If you are an external third party, please use the form available on this page.

    If you are an employee (Group employee or external staff), please use the specific channels indicated in the internal procedures and on the company intranet.

  • Can I remain anonymous?

    Yes, your report may be anonymous, unless it is legally prohibited. 

    However, we recommend you to provide contact information to allow the Whistleblowing Referent to contact you to be able to request further information or clarification on the reported fact

  • Will I receive any feedback on my report?

    An acknowledgement of receipt of the report will be sent to you after receipt. You will then be informed of the progress in the processing of your report and of the outcome of the investigation.

  • Will confidentiality be ensured? ​

    Yes, the Referents are trained in handling whistleblowing reports confidentially and they take appropriate steps to do so.

  • What types of issues can be reported? ​

    -    crime or offense (civil, administrative, criminal, accounting, etc.)

    -      threat or serious damage to the public interest or to the integrity of the Entity,

    -     violation or attempt to conceal a violation of applicable and binding law of:

    • an international standard, or
    • a unilateral act of an international organization carried out on the basis of that rule, or
    • a law or regulation;

    -   violation of the Group Code of Conduct and/or unlawful conduct relevant for the purposes of Legislative Decree 231/2001 and Model 231.

 

How to raise a report:

 

  1. IN WRITING FORM

    Insert the report in two closed envelopes, in order to separate the whistleblower's identification data from the reporting form:

    • the first with a photocopy of a valid identification document of the whistleblower;
    • the second with the "Reporting Form".

      insert the two envelopes into a third closed envelope bearing the words "riservata all’attenzione del Responsabile Dispositivo Allerta Etico" on the outside and sent to the following ordinary mail address:

      BNL S.p.A., Dispositivo Allerta Etico, Compliance Area, Viale Altiero Spinelli 30, 00157 Roma

       

  2. IN ORAL FORM

    By means of an appointment requested in writing to the ordinary mail address "BNL S.p.A., Dispositivo Allerta Etico, Compliance Area, Viale Altiero Spinelli 30, 00157 Roma", specifying your desire to report by a direct meeting or telephone interview (even in the case of telephone contact it will be possible to remain anonymous)

  3. EXTERNAL CHANNELS

    The BNP Paribas Group encourages its employees to use the "internal reporting channels" as a priority.

    The whistleblower can, however, make an "external alert" to Autorità Nazionale Anti Corruzione (ANAC) which, in implementation of Legislative Decree 24/2023, has been identified as the authority responsible for receiving and managing external alerts, even in anonymous form.

    In accordance with the art. 6 of Legislative Decree 24/2023, in fact, "The whistleblower can therefore make an external alert to ANAC if, at the time of its submission, one of the following conditions occurs:

    • the mandatory activation of the internal whistleblowing channel is not foreseen within his/her work context or this, even if mandatory, is not active or, even if activated, does not comply with the provisions of the Decree;
    • the whistleblower has already made an internal alert and it has not been followed up on;
    • the whistleblower has reasonable grounds to believe that, if he/she made an internal alert, it would not be followed up effectively or that the same report could lead to a risk of retaliation;
    • the whistleblower has reasonable grounds to believe that the violation may constitute an imminent or obvious danger to the public interest.

Furthermore, the whistleblower can also notify ANAC of any retaliatory acts resulting from an alert.

External alerts to ANAC must be carried out according to the methods indicated on the Authority's institutional website.