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)

Other established or emerging best practices

Accounting Firm has carried out the assurance in accordance with ISAE 3000 (Revised)

Applies the GRI Sustainability Reporting Guidelines or the GRI Standards

Is 'in accordance - comprehensive' with GRI Standards

Provides information on the company’s profile and context 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

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

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

Other established or emerging best practices

ESG commitment is one of the four pillars of the new Business Plan. Furthermore, the Steering Committee discusses sustainability issues with the support of the ESG Control Room, which includes 17 Sustainability Managers identified for each Group Area

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

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

Other established or emerging best practices

The monitoring of the Code of Ethics implementation in the corporate activities - integrated with the Consolidated Non-financial Statement (CNFS) reporting process - envisages a third-party verification (along the line set by the ISO 26000 standard)

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

Sensitive areas such as Project finance/Project related corporate loans are evaluated according to the Equator Principles. The commitment to the health and safety of workers is confirmed by the certification to the UNI ISO 45001:2018 standard

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)

Outcomes of integration of the human rights principles

Other established or emerging best practices

Outcomes of the Human Rights due diligence processes are disclosed publicly on the Consolidated Non-financial Statement and on the website (ISO26000 cross-tracking through all areas related to material topics)

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

Intesa Sanpaolo adopted a Human Rights policy which defines areas of responsibility towards each stakeholder, from employees, customers, suppliers to the community

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

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

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 the Consolidated Non-financial Statement

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

Intesa Sanpaolo is committed to identify, mitigate and prevent potential violations of HRs linked to its own activities. The HRs policy refers to the Universal Declaration and recognises the principles set out in the ILO fundamental conventions

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

A mixed company-trade union Committee operates drawing up solutions for employee’s welfare and sustainable projects. A whistleblowing system, which allows employees to report actions that could constitute breaches of banking regulations, is in place

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 reduction of emissions is the result of energy efficiency and other environmental actions to contain CO2 emissions by 37% in the 2012-2022 period (-33% as of end 2021); the new Business Plan defines a new Net-Zero target on own emissions by 2030

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

The Group issued the Guidelines for the governance of ESG risks in lending.The new Business Plan includes the development of a biodiversity policy and a reforestation project. Environmental and Energy Management System is certified ISO14001 and ISO 50001

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

Fight against climate change is a key area of the Group commitment, that has joined the main UN initiatives: PRB, PRI, PSI, SDGs and all Net-Zero alliances. The Group in 2021 published its first TCFD report; it also adopts the Equator Principles

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

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

Tools in place: the Code of Ethics, the Internal Code of Conduct, the Organization, Management and Control Model (L. D. 231/01), the whistleblowing system, the Anti-Corruption Guidelines, the anti-bribery management system in line with the UNI ISO 37001

Leadership review of monitoring and improvement results (D12)

Process to deal with incidents (D13)

Public legal cases regarding corruption (D14)

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

Outcomes of integration of the anti-corruption principle

Other established or emerging best practices

The Compliance and the Internal Audit Dept. ensure ongoing consistency between the control and conduct principles set out by the 231 Model. In the last 3 years: no cases of disciplinary sanctions and dismissals due to corruption against employees

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)

Policy on anti-corruption regarding business partners (D5)

Other established or emerging best practices

In 2021 ISP obtained the confirmation of the ISO 37001 Antibribery Management System certification, following the annual verification processes (maintenance audit) by a certification company.The recertification process is underway for 2022/2024 period

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

In 2021, Intesa Sanpaolo Charity Allowance disbursed 14 million euro in support of 800 projects carried out by non-profit organisations, with 99% of donations being allocated to measures in favour of the more vulnerable categories of the population

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

Intesa Sanpaolo supports the local communities by developing initiatives in partnership with NGOs and is also part of certain number of UNEP FI working groups: e.g. Glasgow Financial Alliance for Net-Zero (GFANZ)

Publicly advocate the importance of action in relation to one or more UN goals/issues

Other established or emerging best practices

ISP CEO and Chairman communicate – through the CNFS’s letter to stakeholders - the Bank’s commitment to support the UN goals. ISP joined the PRB, the PSI, the WEPs and all the NET Zero alliances, which are in line with the achievement of the UN SDGs

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

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

Other established or emerging best practices

With the 22-25 Business Plan, the Group aims to strengthen its leading position in ESG with a world-class position in social impact and strong focus on climate, setting objectives in line with the SDGs and generating sustainable value for stakeholders

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

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

Other established or emerging best practices

The CEO has launched a new Business Plan with a dedicated ESG pillar. For the remuneration system, the CEO and 2,100 Group managers were assigned a specific and structured ESG KPI

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 is conducted yearly in line with the themes outlined in the materiality matrix with a close focus on the Business Plan. In depth results are disclosed yearly on the Consolidated Non-financial Statement

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 Risks and Sustainability Committee supports the BoD in approving the strategic guidelines, policies on sustainability and the CNFS. The Steering Committee supports the definition of strategic guidelines and sustainability policies; examines the CNFS

SDG 1: End poverty in all its forms everywhere

SDG 3: Ensure healthy lives and promote well-being for all at all ages

SDG 4: Ensure inclusive and equitable quality education and promote lifelong learning opportunities for all

SDG 5: Achieve gender equality and empower all women and girls

SDG 7: Ensure access to affordable, reliable, sustainable and modern energy for all

SDG 8: Promote sustained, inclusive and sustainable economic growth, full and productive employment and decent work for all

SDG 9: Build resilient infrastructure, promote inclusive and sustainable industrialization and foster innovation

SDG 10: Reduce inequality within and among countries

SDG 11: Make cities and human settlements inclusive, safe, resilient and sustainable

SDG 12: Ensure sustainable consumption and production patterns

SDG 13: Take urgent action to combat climate change and its impacts

SDG 16: Promote peaceful and inclusive societies for sustainable development, provide access to justice for all and build effective, accountable and inclusive institutions at all levels

SDG 17: Strengthen the means of implementation and revitalize the global partnership for sustainable development

Opportunities and responsibilities that one or more SDGs represent to our business

Goals and indicators set by our company with respect to one or more SDGs

How one or more SDGs are integrated into the company’s business model

Other established or emerging best practices

Many targets set in the new Business Plan are connected with the SDGs. Considering the investments and the loans granted to families and businesses, the Group's commitment extends to all SDGs and generates a positive change at global level