The "Leasys Ethics Helpline" is a comprehensive and confidential reporting tool to assist Leasys workforce members to report concerns regarding the Leasys Principles outlined in the "Code of Conduct", our other corporate policies (including alleged fraud, abuse, and other misconduct in the workplace) or applicable laws, banking regulations and relevant Union laws.
Our workforce is our most important asset. By creating open channels of communication, Leasys can promote a positive work environment and maximise productivity. An Ethics Helpline allows for an effective reporting system which will aid in our efforts to foster a culture of integrity and ethical decision-making and to put in place more effective monitoring of the relevant rules and regulations.
NAVEX is an independent third party service provider that has been retained by Leasys to administer the "Leasys Ethics Helpline" and case management application.
EthicsPoint is the name of the helpline services and case management application owned and operated by NAVEX, Inc.
The "Ethics Helpline" is designed for employees to report any concerns pertaining to the Principles outlined in the Leasys "Code of Conduct", our other corporate policies or applicable laws, banking regulations and relevant Union laws.
The “Ethics Helpline” is a resource for the Leasys workforce.
When you observe any behaviour you believe may violate the Principles contained in the "Code of Conduct", other corporate policies, or applicable laws or regulations, we encourage you to report the matter as soon as known.
The available reporting channels are the following: the “Ethics Helpline” (by preference); dedicated email inbox fcabank_whistleblowing@fcagroup.com; letter; oral or written communication to the Head of Compliance and Supervisory Relations (appointed Head of Whistleblowing) or to the Organismo di Vigilanza.
Yes, the process allows for both these services.
We all have the right to work in a positive environment and for a company compliant with the relevant internal or external rules and regulations. With this right comes the responsibility of acting in an ethical manner and letting the appropriate people know if you believe someone is not acting appropriately. By working together, we can maintain a healthy and productive work environment. Violations of the Code of Conduct, other corporate policies or the Law can threaten the assets, goodwill and reputation of an entire company. Reporting a concern allows those responsible for conducting due diligence to ensure the matter is properly addressed.
Absolutely! We encourage you to report concerns. Workforce members know what is going on in our company and may have initial knowledge of an activity that could be cause for concern. Your reporting can minimise the potential negative impact on the company and our workforce.
Concerns are entered directly into NAVEX's secure server to prevent any possible breach in security.
Reported concerns are made available by NAVEX only to specific individuals within Leasys who are entrusted with evaluating the reports, based on the type of reported concern and location of the incident. Each of these report recipients has had training in keeping these reports confidential to the fullest extent practicable under the circumstances.
The NAVEX system is a tool utilised by Leasys to aid us in maintaining a safe, secure, ethical and legally compliant workplace. Effective communication is critical in today's workplace and this is a great tool to enhance that communication.
Leasys has carefully chosen this reporting tool to meet our compliance needs while maintaining a positive reporting environment.
NAVEX does not generate or maintain any internal connection logs with IP addresses; no information linking your PC to NAVEX is available when you access the "Ethics Helpline". In fact, NAVEX is contractually committed not to pursue a reporter's identity.
If you feel uncomfortable making a report on your work PC, you have the option of using a PC outside of the work environment through the NAVEX secure website. Many people choose this option.
No matter where a report is generated it will remain protected, confidential and anonymous. An Internet portal never identifies a reporter by screen name and the NAVEX system strips away identifying information, such as an IP address, so that anonymity is maintained. Plus, NAVEX is contractually committed not to pursue a reporter's identity.
Please be aware that anonymous reporting may not be permitted in some countries.
The NAVEX system is designed to protect your anonymity. In fact, NAVEX is contractually committed not to pursue a reporter's identity. To further ensure your anonymity, you – as a reporting party – should not reveal any identifying details as part of your report.
Please be aware that anonymous reporting may not be permitted in some countries.
Investigating a report is usually faster and more efficient when the Leasys Team is able to follow up on the issue directly with the person reporting the matter. If you have identified yourself, reasonable efforts will be made to respect your confidentiality. Your identity will not be disclosed unless necessary for carrying out a proper investigation, required in the course of legal proceedings, or as required by local laws or local company mandates.
Leasys will not tolerate any form of retaliation for reporting a concern in good-faith.
Once you have finished reporting your concern, you will be provided with a report key and asked to create a password. With these two pieces of identification, you will be able to follow up on a report by visiting the "Ethics Helpline" portal. You may need to wait a few days after your submission before you can monitor progress and check whether you are being asked for any additional information. To allow for protection of the matter and any parties involved, details of the case cannot be provided.
In order to maintain the highest level of confidentiality, you will be asked to file a new concern if you lose either your report key or your password. You should mention that your new report relates to one filed earlier.
Leasys chooses to promote ethical behaviour, and is required to comply with the applicable laws and regulations. All unethical or non-compliant conduct, at any level, ultimately hurts the company and all employees, including you. Disastrous effects can occur in an otherwise seemingly harmless lapse of poor decision making. If you are made aware of any incident of alleged misconduct or ethical violation, or a violation of the laws and regulations applicable to the Bank, consider it your responsibility to report the incident, no matter how trivial it may initially appear.
File a concern. The NAVEX system can help you prepare and file your concern so it can be properly understood. Leasys would rather you report a situation that turns out to be harmless than let possible unethical or illegal behaviour go unchecked because of uncertainty.
The NAVEX system and report distribution protocols are designed so implicated parties are not notified about or granted access to reports in which they have been named, unless required by local laws.
When you file a concern via the "Ethics Helpline" using the dedicated internet portal, you receive a unique report key and are asked to select a password. With the report key and your password, you can return to the NAVEX system again and access the original report. At that point, you can add more details.
NAVEX provides functionality that enables Leasys representatives to post questions for you, even if you report anonymously. When you receive your report key, you will be provided with the amount of time we expect for the report to be processed. When that time has passed, we strongly suggest you check to see if any questions have been posted. Providing the opportunity for such dialogue aids in investigating matters.
All NAVEX correspondences are held in the same strict confidence as the initial report, continuing under the umbrella of anonymity, if you so choose, to the extent permitted by local law and local company mandate.