The cross-membership mechanisms and the non-excessive composition of committees, bodies and structures facilitate coordination between the subjects involved in the Internal Control and Risk Management System. During the course of its meetings, the Risk Management and Internal Control Committee and the Board of Statutory Auditors interact frequently, subject to agreement and to discuss individual topics, with the CEO, the Corporate Financial Reporting Officer, the External Auditing Firm, the Chief Risk Officer and the Compliance and Anti-money Laundering Officer. They also systematically interact with the Internal Auditing Officer who usually takes part in the meetings.
The Supervisory Body as per Italian Leg. Decree 231/2001 also benefits from the same cross-membership mechanisms and similar systematic methods when interacting with other parties involved in the Internal Control and Risk Management System.
With a view to reinforcing coordination and the sharing of information between control functions and in order to achieve economies of scope whilst respecting the mutual autonomy of the parties, as well as developing control methods that are consistent with the business operations:
- Despite there already being contact and inter-relations between these functions, particularly in cases of bilateral discussions;
- In the light of provisions as per 15th Amendment to the Bank of Italy’s Circular 263.
The Compliance and Anti-money Laundering Office, the Anti-money Laundering service, the Risk Management Office, the Internal Auditing Office and the Financial Reporting Officer formally organised further opportunities for coordination and collaboration between the control functions.
Lastly, with regards to coordination between the parties involved in the Internal Control and Risk Management System, a specific web application was developed during 2014 (launched at the beginning of 2015) to support reporting activities and the charting of possible improvement areas in the aforementioned functions and corporate bodies, particularly with regards to the Internal Control System.