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Most reports are handled informally by managers unless seriousness, nature, or impartiality prevents resolution, in which case responsibility moves to the Compliance Officer. Cases are routed through local, group, or helpline channels, recorded in the EthicsPoint database, treated confidentially on a need-to-know basis, and concluded with remedial actions and removal or retention rules for personal data.",{"@graph":63,"@context":119},[64,80,102],{"@type":65,"itemListElement":66},"BreadcrumbList",[67,71,74,77],{"item":68,"name":69,"@type":70,"position":9},"https://docshare.wps.com","Home","ListItem",{"item":72,"name":10,"@type":70,"position":73},"https://docshare.wps.com/template/",2,{"item":75,"name":41,"@type":70,"position":76},"https://docshare.wps.com/template/letters/",3,{"item":78,"name":59,"@type":70,"position":79},"https://docshare.wps.com/template/management-of-concerns-process-grc-generali-group-process-on-managing-reported-concerns/253645/",4,{"url":78,"name":59,"@type":81,"image":82,"author":87,"headline":59,"publisher":90,"fileFormat":93,"inLanguage":57,"description":61,"dateModified":94,"datePublished":95,"encodingFormat":93,"isAccessibleForFree":96,"interactionStatistic":97},"DigitalDocument",{"url":83,"@type":84,"width":85,"height":86},"https://docshare.wps.com/thumbnails/management-of-concerns-process-grc-generali-group-process-on-managing-reported-concerns/253645.png","ImageObject",442,249,{"name":88,"@type":89},"Fez","Person",{"url":68,"name":91,"@type":92},"DocShare","Organization","application/pdf","2026-10-25","2026-09-13",true,{"@type":98,"interactionType":99,"userInteractionCount":101},"InteractionCounter",{"@type":100},"ViewAction",7,{"@type":103,"mainEntity":104},"FAQPage",[105,111,115],{"name":106,"@type":107,"acceptedAnswer":108},"How are concerns handled when a manager cannot resolve them informally?","Question",{"text":109,"@type":110},"If informality is not possible due to seriousness, the nature of the concern, or lack of impartiality, the concern is sent to the Compliance Officer for management.","Answer",{"name":112,"@type":107,"acceptedAnswer":113},"What channels are available to report concerns within the Generali Group?",{"text":114,"@type":110},"Reporting can be made through local management plus alternative channels: Local Compliance, Group Compliance, and the Generali Group Compliance Helpline.",{"name":116,"@type":107,"acceptedAnswer":117},"How does the process protect confidentiality during evaluation and investigation?",{"text":118,"@type":110},"Evaluation and investigation are conducted with utmost confidentiality, and relevant information is shared only between the Compliance Function and other persons strictly on a need-to-know basis.","https://schema.org",{"og:url":78,"og:type":121,"og:title":59,"og:site_name":91,"og:description":61},"article",{"robots":123,"canonical":78},"index,follow",{"doc_id":125,"site_id":56},253645,1790201716,{"code":4,"msg":5,"data":128},{"doc_id":125,"user_id":129,"nickname":88,"user_avatar":130,"doc_module":9,"category_id":40,"category_name":41,"doc_title":59,"doc_description":61,"doc_content":131,"file_id":132,"file_url":133,"file_type":134,"file_size":135,"view_count":101,"is_deleted":4,"is_public":9,"is_downloadable":9,"audit_status":9,"page_count":76,"language":136,"language_code":57,"site_id":56,"html_lang":57,"table_of_contents":137,"faqs":138,"seo_title":139,"seo_description":61,"update_tm":140,"read_time":9},2336478940794,"https://ap-avatar.wpscdn.com/davatar_9964176cb1d06d4a9deccf72a44ae3dc","The Generali Group Process on Managing Reported Concerns  \n1. Introduction  \nThis document explains the process utilized by the Generali Group to manage concerns reported in accordance with the Group Code of Conduct.  \n2. Informally Handled Concerns  \nIn the majority of cases reported to managers, the reporter will have the expectation that the case will be handled informally by the manager and not escalated to other departments. Where the manager is unable to informally resolve the concern, because of its seriousness, nature or their lack of impartiality, the concern will be sent to the Compliance Officer1 for its management.  \n3. Reporting Channels  \nThe Generali Group provides several alternative reporting channels in addition to local management:  \n􀁸 Local Compliance  \n􀁸 Group Compliance  \n􀁸 The Generali Group Compliance Helpline  \n4. Initial Case Assignment  \nOnce reported, the case will be assessed to identify the appropriate Compliance Officer for the management of the concern.  \nThe case will be assigned based on the Generali Group rules on handling concerns and this means that cases are normally assigned to the local company Compliance Officer, other than in the following cases:  \n\n| Cases Involving | Assignment of Concern |\n| --- | --- |\n| Company top management | Regional or Group Compliance Officer |\n| Significant accounting, auditing or financial matters | Regional or Group Compliance Officer |\n| Local or Regional Compliance Officer | Group Compliance Officer |\n| Group Compliance Officer | Chairman of the Board of Directors of Assicurazioni Generali |\n\nCases reported via the Generali Group Compliance Helpline are automatically assigned to the appropriate compliance officer, following the above mentioned rules.  \nThe Regional/Group Compliance Officers may be based in a country, other than where the concern took place; however, any information will be handled in accordance with local legislation.  \nInternal   \n1 The Group Compliance Policy qualifies the Compliance Function as independent from any operational functions. The Compliance Officer reports to the Board of Directors.  \n5. Details needed to assign the case  \nWhen submitting a concern, the reporter should provide the following information to assist the process for the assignment of the case:  \n1. The country in which the reporter is located;  \n2. The country in which the reported breach took place;  \n3. The Generali Group company to which the report relates;  \n4. Whether the case involves:  \no Top Management  \no Compliance Officer  \no Significant accounting, auditing or financial matters.  \nThe above information will also assist the identification of cases where local law restricts the use of the reporting channels.  \n6. Evaluation and investigation of the Case  \nThe evaluation and investigation of the case will be undertaken with the utmost confidentiality and the relevant information will be shared between the Compliance Function and other persons on a strictly need‐to‐know basis.  \nA preliminary evaluation will be undertaken to ensure they are the appropriate Compliance Function to handle the case and that the case is sufficiently detailed to enable an investigation.  \nOnce the preliminary evaluation is completed, the Compliance Function will start investigating the case, with support from Internal Audit and other external professional advisors, as required.  \n7. Remedial Measures  \nFollowing the investigation, the Compliance Function will identify any remedial measures that are required.  \nWhere disciplinary sanctions may be appropriate, the Compliance Function will involve Human Resources in the process.  \nAll remedial measures will be submitted to the company CEO/administrative body for final decision.  \n8. EthicsPoint Database  \nAll the reported cases within Generali Group will be recorded on EthicsPoint database, other than those that are handled informally.  \nThe access to the individual cases is defined on a case by case basis, and is limited to the","cbCais9OFuLMgYkE","https://ap.wps.com/l/cbCais9OFuLMgYkE","pdf",126782,"English","# Introduction\n# Informally Handled Concerns\n# Reporting Channels\n# Initial Case Assignment\n## Cases Involving\n# Details needed to assign the case\n# Evaluation and investigation of the Case\n# Remedial Measures\n# EthicsPoint Database\n# Reporting\n# Conclusion of the Case and Removal of Personal Data","[{\"question\":\"How are concerns handled when a manager cannot resolve them informally?\",\"answer\":\"If informality is not possible due to seriousness, the nature of the concern, or lack of impartiality, the concern is sent to the Compliance Officer for management.\"},{\"question\":\"What channels are available to report concerns within the Generali Group?\",\"answer\":\"Reporting can be made through local management plus alternative channels: Local Compliance, Group Compliance, and the Generali Group Compliance Helpline.\"},{\"question\":\"How does the process protect confidentiality during evaluation and investigation?\",\"answer\":\"Evaluation and investigation are conducted with utmost confidentiality, and relevant information is shared only between the Compliance Function and other persons strictly on a need-to-know basis.\"}]","Management of concerns process - GRC - Generali Group Process on Managing Reported Concerns | PDF",1789268331]