pg. 165

"ANTI-CORRUPTION

UniCredit has a zero-tolerance approach towards acts of corruption.

The bank's approach to anti-bribery and corruption is laid out in the dedicated Global Rules, published on the UniCredit Group website, which set minimum standards of anti-corruption compliance 13 throughout the Group. Whenever local rules in a country of operation are stricter than the Global Rules - the stricter local rules apply. Each Legal Entity is responsible for the development and implementation of an effective Local Anti-Corruption Programme. Moreover, Italian Group Legal Entities have also implemented an Organisational and Management Model (hereinafter the Model) pursuant to Italian Legislative Decree 231/01 (Administrative liability of legal entities, companies and associations hereby L.D. 231/01) that foresees, inter alia, specific Protocols aimed at avoiding bribery and corruption issues"