Intesa Sanpalo Communication on Progress 2014

Participant
Published
  • 29-May-2015
Time period
  • January 2014  –  December 2014
Files
Links
Format
  • Part of a sustainability or corporate (social) responsibility report
Differentiation Level
  • This COP qualifies for the Global Compact Advanced level
Self-assessment
  • Includes a CEO statement of continued support for the UN Global Compact and its ten principles
  • Description of actions or relevant policies related to Human Rights
  • Description of actions or relevant policies related to Labour
  • Description of actions or relevant policies related to Environment
  • Description of actions or relevant policies related to Anti-Corruption
  • Includes a measurement of outcomes
  • Meets all criteria for the GC Advanced level
Verification
and Transparency
  • How is the accuracy and completeness of information in your COP assessed by a credible third-party?
  • The COP describes any action(s) that the company plans to undertake by its next COP to have the credibility of the information in its COP externally assessed, including goals, timelines, metrics, and responsible staff

  • Information is assured by independent assurors (e.g., accounting or consulting firm) against recognized assurance standard (e.g., ISAE3000, AA1000AS, other national or industry-specific standard)

  • Information is reviewed by multiple stakeholders (e.g., representatives of groups prioritized in stakeholder analysis)

  • Information is reviewed by a panel of peers (e.g., members of the same industry, competitors, benchmarked leaders, others organized via Global Compact Local Network)

  • Information is assured by independent assurors (e.g., accounting or consulting firm) using their own proprietary methodology

  • Other established or emerging best practices

 
  • The COP incorporates the following high standards of transparency and disclosure:
  • Applies the GRI Sustainability Reporting Guidelines or the GRI Standards

  • Is 'in accordance - core' with GRI Standards

  • Provides information on the company’s profile and context of operation

  • Is 'in accordance - comprehensive' with GRI Standards

  • Applies elements of the International Integrated Reporting Framework

Strategy, Governance
and Engagement
  • Criterion 2: The COP describes value chain implementation
  • Analyze each segment of the value chain carefully, both upstream and downstream, when mapping risks, opportunities and impacts

  • Communicate policies and expectations to suppliers and other relevant business partners

  • Implement monitoring and assurance mechanisms (e.g. audits/screenings) for compliance within the company’s sphere of influence

  • Other established or emerging best practices

    The control of the Code of Ethics implementation in the corporate activities - integrated with the Sustainability Report management process - envisages a self-assessment by the department heads as well as third-party verification

  • Any relevant policies, procedures, and activities that the company plans to undertake by its next COP to fulfill this criterion, including goals, timelines, metrics, and responsible staff

  • Undertake awareness-raising, training and other types of capacity building with suppliers and other business partners

  • Criterion 1: The COP describes mainstreaming into corporate functions and business units
  • Any relevant policies, procedures, and activities that the company plans to undertake by its next COP to fulfill this criterion, including goals, timelines, metrics, and responsible staff

  • Assign responsibility for corporate sustainability implementation to an individual or group within each business unit and subsidiary

  • Design corporate sustainability strategy to leverage synergies between and among issue areas and to deal adequately with trade-offs

  • Other established or emerging best practices

    Intesa Sanpaolo CSR management model is based on a self-governance principle. The “CSR Delegates” –60 colleagues in different Bank departments - collaborate with the CSR Unit in managing sustainability issues in their various areas of operation

  • Place responsibility for execution of sustainability strategy in relevant corporate functions (procurement, government affairs, human resources, legal, etc) ensuring that no function is conflicting with company sustainability commitments and objectives

  • Align strategies, goals and incentive structures of all business units and subsidiaries with corporate sustainability strategy

  • Ensure that different corporate functions coordinate closely to maximize performance and avoid unintended negative impacts

Human Rights
  • Criterion 3: The COP describes robust commitments, strategies or policies in the area of human rights
  • Any relevant policies, procedures, and activities that the company plans to undertake by its next COP to fulfill this criterion, including goals, timelines, metrics, and responsible staff

  • Commitment to comply with all applicable laws and respect internationally recognized human rights, wherever the company operates (e.g., the Universal Declaration of Human Rights, Guiding Principles on Human Rights) (BRE1 + ARE1)

  • Integrated or stand-alone statement of policy expressing commitment to respect and support human rights approved at the most senior level of the company (BRE 1 + BRE5 + ARE 1 + ARE 5)

  • Statement of policy stipulating human rights expectations of personnel, business partners and other parties directly linked to operations, products or services (BRE 1)

  • Statement of policy publicly available and communicated internally and externally to all personnel, business partners and other relevant parties (BRE 1 + BRE 5 + ARE 1 + ARE 5)

  • Other established or emerging best practices

    The CSR management control system is capable of identifying, measuring and monitoring, the risks resulting from non-application of principles for the protection of human rights. The results of this process are presented to the Control Committee

  • Criterion 5: The COP describes effective monitoring and evaluation mechanisms of human rights integration
  • System to monitor the effectiveness of human rights policies and implementation with quantitative and qualitative metrics, including in the supply chain (BRE3 + ARE3)

  • Monitoring draws from internal and external feedback, including affected stakeholders

  • Grievance mechanisms that are legitimate, accessible, predictable, equitable, transparent, rights-compatible, a source of continuous learning, and based on engagement and dialogue (BRE4 + ARE4)

  • Other established or emerging best practices

    Outcomes of the due diligence processes (quantitatively/qualitatively monitoring) are disclosed publicly on the Social Report and on the website of the bank

  • Any relevant policies, procedures, and activities that the company plans to undertake by its next COP to fulfill this criterion, including goals, timelines, metrics, and responsible staff

  • Leadership review of monitoring and improvement results

  • Process to deal with incidents the company has caused or contributed to for internal and external stakeholders (BRE 4 + ARE 4)

  • Outcomes of integration of the human rights principles

  • Criterion 4: The COP describes effective management systems to integrate the human rights principles
  • Any relevant policies, procedures, and activities that the company plans to undertake by its next COP to fulfill this criterion, including goals, timelines, metrics, and responsible staff

  • Process to ensure that internationally recognized human rights are respected

  • On-going due diligence process that includes an assessment of actual and potential human rights impacts (BRE 2 + BRE 3 + ARE 2 + ARE 3)

  • Internal awareness-raising and training on human rights for management and employees

  • Operational-level grievance mechanisms for those potentially impacted by the company’s activities (BRE 4 + ARE 4)

  • Process and programs in place to support human rights through: core business; strategic philanthropic/social investment; public policy engagement/advocacy; partnerships and/or other forms of collective action (BRE 6 + ARE 6)

  • Other established or emerging best practices

    Structured management processes have been defined in specific sensitive areas such as project finance/Project related corporate loans (Equator Principles application areas) and for transactions in the field of weapons through a internal policy

  • Allocation of responsibilities and accountability for addressing human rights impacts

  • Internal decision-making, budget and oversight for effective responses to human rights impacts

  • Processes to provide for or cooperate in the remediation of adverse human rights impacts that the company has caused or contributed to (BRE 3+ BRE 4 + ARE3 + ARE 4)

Labour
  • Criterion 6: The COP describes robust commitments, strategies or policies in the area of labour
  • Any relevant policies, procedures, and activities that the company plans to undertake by its next COP to fulfill this criterion, including goals, timelines, metrics, and responsible staff

  • Reference to principles of relevant international labour standards (ILO Conventions) and other normative international instruments in company policies

  • Reflection on the relevance of the labour principles for the company

  • Written company policy to obey national labour law, respect principles of relevant international labour standards in worldwide company operations and engage in dialogue with representative organization of the workers (international, sectoral, national).

  • Inclusion of reference to the principles contained in the relevant international labour standards in contracts with suppliers and other relevant business partners

  • Specific commitments and Human Resources policies, in line with national development priorities or decent work priorities in the country of operation

  • Other established or emerging best practices

    The Code of Ethics, linked to the Group’s Code of Conduct, states that the Bank is committed to helping safeguard human rights in accordance with the principles of the Universal Declaration and recognises the principles set out in the ILO conventions

  • Structural engagement with a global union, possibly via a Global Framework Agreement

  • Participation and leadership by employers’ organizations (international and national) to jointly address challenges related to labour standards in the countries of operation, possibly in a tripartite approach (business – trade union – government).

  • Criterion 8: The COP describes effective monitoring and evaluation mechanisms of labour principles integration
  • Any relevant policies, procedures, and activities that the company plans to undertake by its next COP to fulfill this criterion, including goals, timelines, metrics, and responsible staff

  • System to track and measure performance based on standardized performance metrics

  • Dialogues with the representative organization of workers to regularly review progress made and jointly identify priorities for the future

  • Audits or other steps to monitor and improve the working conditions of companies in the supply chain, in line with principles of international labour standards

  • Outcomes of integration of the Labour principles

  • Other established or emerging best practices

    Trade Unions and Employees are regularly included in stakeholder engagement activities. The results of the dialogue processes are published yearly in detail on the website

  • Process to positively engage with the suppliers to address the challenges (i.e., partnership approach instead of corrective approach) through schemes to improve workplace practices

  • Criterion 7: The COP describes effective management systems to integrate the labour principles
  • Any relevant policies, procedures, and activities that the company plans to undertake by its next COP to fulfill this criterion, including goals, timelines, metrics, and responsible staff

  • Risk and impact assessments in the area of labour

  • Dialogue mechanism with trade unions to regularly discuss and review company progress in addressing labour standards

  • Allocation of responsibilities and accountability within the organization

  • Internal awareness-raising and training on the labour principles for management and employees

  • Active engagement with suppliers to address labour-related challenges

  • Grievance mechanisms, communication channels and other procedures (e.g., whistleblower mechanisms) available for workers to report concerns, make suggestions or seek advice, designed and operated in line with the representative organization of workers

  • Other established or emerging best practices

    The Labour/Management Relations Protocol was renewed, envisaging the establishment of a mixed company-trade union entity, the “Welfare, Safety and Sustainable Development Committee”, with the objective of drawing up solutions for work life balance

Environment
  • Criterion 9: The COP describes robust commitments, strategies or policies in the area of environmental stewardship
  • Any relevant policies, procedures, and activities that the company plans to undertake by its next COP to fulfill this criterion, including goals, timelines, metrics, and responsible staff

  • Reference to relevant international conventions and other international instruments (e.g. Rio Declaration on Environment and Development)

  • Reflection on the relevance of environmental stewardship for the company

  • Written company policy on environmental stewardship

  • Inclusion of minimum environmental standards in contracts with suppliers and other relevant business partners

  • Specific commitments and goals for specified years

  • Other established or emerging best practices

    Environmental protection and the focus on climate change are key areas of our commitment, reiterated and enshrined in the Group’s Environmental and Energy Policy which is regularly updated and approved by the Board of Directors

  • Criterion 11: The COP describes effective monitoring and evaluation mechanisms for environmental stewardship
  • Any relevant policies, procedures, and activities that the company plans to undertake by its next COP to fulfill this criterion, including goals, timelines, metrics, and responsible staff

  • System to track and measure performance based on standardized performance metrics

  • Leadership review of monitoring and improvement results

  • Process to deal with incidents

  • Outcomes of integration of the environmental principles

  • Other established or emerging best practices

    The rationalization of resources and reduction of pollutant emissions are the result of the application of a Sustainable Energy Action Plan: a reduction of around 16.8% in CO2 emissions deriving from electricity and heat consumption was recorded in 2014

  • Audits or other steps to monitor and improve the environmental performance of companies in the supply chain

  • Criterion 10: The COP describes effective management systems to integrate the environmental principles
  • Any relevant policies, procedures, and activities that the company plans to undertake by its next COP to fulfill this criterion, including goals, timelines, metrics, and responsible staff

  • Environmental risk and impact assessments

  • Assessments of lifecycle impact of products, ensuring environmentally sound management policies

  • Allocation of responsibilities and accountability within the organisation

  • Internal awareness-raising and training on environmental stewardship for management and employees

  • Grievance mechanisms, communication channels and other procedures (e.g. whistleblower mechanisms) for reporting concerns or seeking advice regarding environmental impacts

  • Other established or emerging best practices

    A dedicated team within the CSR Unit is in charge of monitoring the environmental direct impacts of the Bank also through the adoption of an Environmental and Energy Management System certified ISO 14001 and ISO 50001 (till now applied to 220 sites)

Anti-Corruption
  • Criterion 12: The COP describes robust commitments, strategies or policies in the area of anti-corruption
  • Any relevant policies, procedures, and activities that the company plans to undertake by its next COP to fulfill this criterion, including goals, timelines, metrics, and responsible staff

  • Publicly stated formal policy of zero-tolerance of corruption (D1)

  • Commitment to be in compliance with all relevant anti-corruption laws, including the implementation of procedures to know the law and monitor changes (B2)

  • Statement of support for international and regional legal frameworks, such as the UN Convention against Corruption (D2)

  • Detailed policies for high-risk areas of corruption (D4)

  • Other established or emerging best practices

    Internal control procedures have been further enhanced. New monitoring aspects have been introduced for money laundering and tax risk in relation to transactions executed with customers resident for tax purposes in other countries

  • Policy on anti-corruption regarding business partners (D5)

  • Criterion 14: The COP describes effective monitoring and evaluation mechanisms for the integration of anti-corruption
  • Any relevant policies, procedures, and activities that the company plans to undertake by its next COP to fulfill this criterion, including goals, timelines, metrics, and responsible staff

  • Leadership review of monitoring and improvement results (D12)

  • Process to deal with incidents (D13)

  • Outcomes of integration of the anti-corruption principle

  • Other established or emerging best practices

    Attention to the prevention of corruption risks is very high. The Compliance, Audit and Internal Control Departments ensure ongoing consistency between the control and conduct principles set out by the 231 Model

  • Public legal cases regarding corruption (D14)

  • Use of independent external assurance of anti-corruption programmes (D15)

  • Criterion 13: The COP describes effective management systems to integrate the anti-corruption principle
  • Any relevant policies, procedures, and activities that the company plans to undertake by its next COP to fulfill this criterion, including goals, timelines, metrics, and responsible staff

  • Carrying out risk assessment of potential areas of corruption (D3)

  • Human Resources procedures supporting the anti-corruption commitment or policy, including communication to and training for all employees (B5 + D8)

  • Internal checks and balances to ensure consistency with the anti-corruption commitment (B6)

  • Actions taken to encourage business partners to implement anti-corruption commitments (D6)

  • Management responsibility and accountability for implementation of the anti-corruption commitment or policy (D7)

  • Communications (whistleblowing) channels and follow-up mechanisms for reporting concerns or seeking advice (D9)

  • Internal accounting and auditing procedures related to anticorruption (D10)

  • Other established or emerging best practices

    Specific tools for the management and prevention of the risk of corruption have long been in place: the Code of Ethics, the Internal Code of Conduct, the Organisation, Management and Control Model pursuant to Legislative Decree 231/01

  • Support by the organization’s leadership for anti-corruption (B4)

UN Goals and Issues
  • Criterion 18: The COP describes partnerships and collective action
  • Any relevant policies, procedures, and activities that the company plans to undertake by its next COP to fulfill this criterion, including goals, timelines, metrics, and responsible staff

  • Develop and implement partnership projects with public or private organizations (UN entities, government, NGOs, or other groups) on core business, social investments and/or advocacy

  • Join industry peers, UN entities and/or other stakeholders in initiatives contributing to solving common challenges and dilemmas at the global and/or local levels with an emphasis on initiatives extending the company’s positive impact on its value chain

  • Other established or emerging best practices

    Project Malawi is a humanitarian program started in 2005 developed in cooperation with International and local NGOs to fight against AIDS and to support local development through microfinance initiatives. In 2014 only, 63,067 beneficiaries were reached

  • Criterion 15: The COP describes core business contributions to UN goals and issues
  • Any relevant policies, procedures, and activities that the company plans to undertake by its next COP to fulfill this criterion, including goals, timelines, metrics, and responsible staff

  • Develop relevant products and services or design business models that contribute to UN goals/issues

  • Other established or emerging best practices

    Foreign subsidiaries which are located in emerging markets develop every year specific projects to favour inclusion of vulnerable people such as the "School Feeding Programme" in Egypt in partnership with the World Food Programme

  • Align core business strategy with one or more relevant UN goals/issues

  • Adopt and modify operating procedures to maximize contribution to UN goals/issues

  • Criterion 16: The COP describes strategic social investments and philanthropy
  • Any relevant policies, procedures, and activities that the company plans to undertake by its next COP to fulfill this criterion, including goals, timelines, metrics, and responsible staff

  • Pursue social investments and philanthropic contributions that tie in with the core competencies or operating context of the company as an integrated part of its sustainability strategy

  • Coordinate efforts with other organizations and initiatives to amplify—and not negate or unnecessarily duplicate—the efforts of other contributors

  • Other established or emerging best practices

    Intesa Sanpaolo Charity Fund defines the areas of action for donations, whether non-recurring or classified as investments in the community. In 2014 the focus was on projects with a social impact on fragile individuals, hit by the economic crisis

  • Take responsibility for the intentional and unintentional effects of funding and have due regard for local customs, traditions, religions, and priorities of pertinent individuals and groups

  • Criterion 17: The COP describes advocacy and public policy engagement
  • Publicly advocate the importance of action in relation to one or more UN goals/issues

  • Other established or emerging best practices

    The Intesa Sanpaolo CEO communicates – through the Social Report’s letter to stakeholders - the Bank commitment to the development of projects and initiatives in support of the principles and the broader goals pursued by the United Nations

  • Any relevant policies, procedures, and activities that the company plans to undertake by its next COP to fulfill this criterion, including goals, timelines, metrics, and responsible staff

  • Commit company leaders to participate in key summits, conferences, and other important public policy interactions in relation to one or more UN goals/issues

Governance
  • Criterion 19: The COP describes CEO commitment and leadership
  • Any relevant policies, procedures, and activities that the company plans to undertake by its next COP to fulfill this criterion, including goals, timelines, metrics, and responsible staff

  • CEO leads executive management team in development of corporate sustainability strategy, defining goals and overseeing implementation

  • CEO publicly delivers explicit statements and demonstrates personal leadership on sustainability and commitment to the UN Global Compact

  • CEO promotes initiatives to enhance sustainability of the company’s sector and leads development of industry standards

  • Other established or emerging best practices

    The CEO launched the 2014-2017 Business Plan in which the objective to be a Bank for the real economy means increasing integration of sustainability into the core business of the bank

  • Make sustainability criteria and UN Global Compact principles part of goals and incentive schemes for CEO and executive management team

  • Criterion 21: The COP describes stakeholder engagement
  • Publicly recognize responsibility for the company’s impacts on internal and external stakeholders

  • Define sustainability strategies, goals and policies in consultation with key stakeholders

  • Consult stakeholders in dealing with implementation dilemmas and challenges and invite them to take active part in reviewing performance

  • Establish channels to engage with employees and other stakeholders to hear their ideas and address their concerns

  • Other established or emerging best practices

    Stakeholder engagement on CSR issues have been integrated with the broader business activities over time. Each year, we publish on the website a report on the engagement process, the results of listening and the initiatives implemented

  • Any relevant policies, procedures, and activities that the company plans to undertake by its next COP to fulfill this criterion, including goals, timelines, metrics, and responsible staff

  • Criterion 20: The COP describes Board adoption and oversight
  • Board of Directors (or equivalent) assumes responsibility and oversight for long-term corporate sustainability strategy and performance

  • Board establishes, where permissible, a committee or assigns an individual board member with responsibility for corporate sustainability.

  • Board (or committee), where permissible, approves formal reporting on corporate sustainability (Communication on Progress)

  • Other established or emerging best practices

    The Internal Control Committee supervises also social and environmental risks. It receives regular reporting by the CSR Unit on the consistence of the Code of Ethics values into the Bank’s activities (assessments by an independent consulting company)

  • Any relevant policies, procedures, and activities that the company plans to undertake by its next COP to fulfill this criterion, including goals, timelines, metrics, and responsible staff