Our approach to controversial areas
The BPER Group adopts criteria and procedures dedicated to the management of sectors considered controversial, as outlined within its internal policies governing risk assessment and management.
Details regarding the initiatives implemented by the BPER Group in these sectors follow.
Fight against compulsive gambling
Policy on arms
The relationship between banks and defense sector operators has long been a focus of attention from Italian civil society, particularly associations aiming to prevent Italy and its companies from being involved in the production and trade of so-called "controversial" weapons, especially when counterparts are located in countries subject to international sanctions. For these reasons, and in line with the guiding principles of its Code of Ethics, since 2012 the Group has initially adopted "Linee Guida di Gruppo per la regolamentazione dei rapporti delle banche del Gruppo BPER con gli Operatori della difesa e le Imprese produttrici di armamenti" now updated as a Policy. With this, the Group has aimed to adopt self-regulation that governs, more strictly and transparently than current laws, its presence in this sector.
In defining the Policy, the Group sought the correct balance between some general values, such as:
- promotion of human rights and peace
- respect for the right to defense and security of peoples and nations
- respect for the freedom of enterprise and economic initiative (including arms manufacturers) within the rules of the legal system.
The Banks and Financial Companies of the Group may therefore appear in the annual reports prepared by the Presidency of the Council pursuant to Law No. 185/90, albeit within the limits set by the Policy, in order to monitor the risk that the goods or services subject to export are destined for entities other than democratic governments or that violate human rights. The Policy also governs other types of operations and cases such as participations, financing, current account or investment relationships.
The Parent Company annually publishes a report providing evidence of activities conducted with companies operating in the defense sector, including financing relationships. Finally, it should be noted that BPER Banca has adopted appropriate procedural safeguards to avoid the risk of financing anti-personnel mine producers, as required by Law No. 220 of December 9, 2021.
In developing this Policy, we sought to strike an appropriate balance among several core values that serve as our guiding principles:
- Respect for the freedom to conduct business and for economic initiative—including that of arms manufacturers—within the framework of the legal system;
- Promotion of human rights and peace.
- Respect for the right to defense and security of peoples and nations;
Transactions in physical gold
Among the services we offer our clients is the buying and selling of gold. We exclusively trade gold bars produced by refineries that hold international certifications—attesting to their adherence to due diligence practices regarding their suppliers—and that are included on the "London Good Delivery" list, which is recognized globally as the industry standard. This ensures that the metal has undergone verification processes to confirm its compliance with international standards, as well as with the regulations and codes of conduct established by key industry associations (such as the LBMA and RJC) and international bodies (such as the OECD). Furthermore, we ensure that our suppliers employ mechanisms to monitor and evaluate their gold supply chains, with the aim of preventing criminal activity—ranging from geopolitical and financial offenses (such as money laundering, corruption, and the financing of terrorism) to human rights abuses, genocide, child labor, and environmental crimes.
Transactions in Physical Gold
Among the services offered to customers, the Bank offers Gold trading. BPER Bank trades only gold bars produced by refineries that hold international certifications attesting to compliance with due diligence practices on their suppliers and registered on the London Good Delivery list, recognized internationally as the market standard.
It is thus guaranteed that the metal being sold is Conflict Free and complies with the regulations and codes of conduct prepared by the main industry association bodies (LBMA, RJC) and international bodies (OECD); it is also ensured that suppliers are equipped with tools for the control and evaluation of gold purchasing chains, in order to combat possible forms of crime both geopolitical-financial (anti-money laundering, corruption, financing of terrorism) and related to human rights abuse, genocide, exploitation of child labor or crimes against the environment.