Confidential investigation in the banking sector
Note: For privacy, security and confidentiality reasons, the name of the client company will not be disclosed.
Background
The case involves a major banking institution with a national presence, operating in the wealth management and private banking segment. The organization, known for its excellence in trust management and professional discretion, places great emphasis on internal ethics, compliance with regulations, and behavioral transparency among its staff.
Within this context of high reputational sensitivity, an alleged violation of the use of leave under Law 104/1992, which grants employees the opportunity to take advantage, in the presence of a severe disability (their own or a family member’s), of:
- Up to 3 days of monthly paid leave, also divisible into hours
- Or 2 hours daily leave to ensure care for the frail person
Reporting and suspicion
HR staff had noticed alleged inconsistencies between the stated reasons for leave taken under 104 and the employee’s actual behavior.
Specifically, it was speculated that leave days were repeatedly misused, unrelated to any care needs.
Given the sensitivity of the subject matter-which touches sensitive rights and protected conditions-the management decided not to act reactively or summarily, but to rely on a qualified third party to verify the facts.
Why ASI (an SSI group company) was chosen.
The company chose to turn to ASI of the Società Servizi Italia group for three main reasons:
- Experience in handling sensitive corporate infidelity cases, particularly on issues related to leave, strategic absenteeism, and code of ethics violations
- Strict and law-abiding operating method that can simultaneously protect the rights of the worker and the interests of the company
- Operational discretion and production of objective documentation to support possible disciplinary action
The investigative intervention
ASI set up a discreet and documented observation service, active on days when the employee was absent from work to take leave under Law 104.
During one of the days in question:
- the subject’s arrival at a long-term parking lot at the airport was documented
- images of the coupon displayed on the dashboard were detected
- the employee was monitored to the boarding area, where he was found to have boarded an international flight
- Return and return to the home, several days apart, was also documented
All activities were carried out in full compliance with current regulations, ensuring maximum procedural fairness and traceability of sources.
Outcome and case management
The investigation file was turned over to the legal and human resources department.
The evidence collected confirmed that paid leave under Law 104 had been used for personal purposes that were incompatible with the regulatory provisions.
As a result, the company has:
- initiated an internal disciplinary procedure
- concluded with a formal sanction measure
- Strengthened control procedures on theuse of special permits
Result
Thanks to the professionalism and confidentiality of the intervention conducted by ASI, the company was able to:
- To ascertain the facts conclusively
- Protect the internal climate and equity among employees
- Strengthen the culture of compliance and sense of responsibility
Conclusion
Leave granted under Law 104 is a fundamental right, but it is also a sensitive area and potentially subject to abuse.
In this case, the investigative intervention established the misuse of benefits, protecting the organization from a risky precedent and reaffirming the validity of ethics policies.
ASI, an SSI group company, is confirmed as the ideal partner for confidential internal investigations, especially in contexts with high legal, regulatory and reputational sensitivity.
