Communication on Progress

Participant
Published
  • 10-Jun-2014
Time period
  • January 2012  –  December 2013
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?
  • 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)

  • 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 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

  • Applies elements of the International Integrated Reporting Framework

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

  • Is 'in accordance - core' with GRI Standards

  • Is 'in accordance - comprehensive' with GRI Standards

Strategy, Governance
and Engagement
  • Criterion 1: The COP describes mainstreaming into corporate functions and business units
  • Assign responsibility for corporate sustainability implementation to an individual or group within each business unit and subsidiary

  • Other established or emerging best practices

    The Intesa Sanpaolo CSR management model is based on internal Departments' self-governance. The CSR Unit collaborates with a network of 70 CSR delegates appointed by the head of their own Business Unit

  • 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

  • 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

  • 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

  • Criterion 2: The COP describes value chain implementation
  • 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

    New "Group Procurement Guidelines" and related "Implementig rules" were issued during 2013. They require that CSR criteria shoud be taken in due consideration during the sourcing process

  • 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

  • Analyze each segment of the value chain carefully, both upstream and downstream, when mapping risks, opportunities and impacts

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

Human Rights
  • Criterion 4: The COP describes effective management systems to integrate the human rights principles
  • 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)

  • Other established or emerging best practices

    Due diligence process have been defined in specific sensitive areas such as project finance loans and transaction in the field of weapons

  • 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

  • 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)

  • 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)

  • 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

  • Other established or emerging best practices

    A new monitoring process evaluates the adoption of the Code of Ethics principles into businss activity. The process has been developed based on the ISO26000 methodology

  • 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)

  • 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

  • Criterion 3: The COP describes robust commitments, strategies or policies in the area of human rights
  • 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 Code of Ethics explicity states Intesa Sanpaolo committment to safeguard HRs. The Code is published on the website, on the Intranet and distributed to new recruits and suppliers

  • 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

Labour
  • Criterion 8: The COP describes effective monitoring and evaluation mechanisms of labour principles integration
  • 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

    The main monitoring mechanism is based on stakeholder engagement that regularly includes focus groups and climate survey with Trade Unions and employees. Results are published on Intesa Sanpaolo website

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

  • Criterion 6: The COP describes robust commitments, strategies or policies in the area of labour
  • 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 Etichs, states that the Bank is committed to helping safeguard HRs in accordance with the principles of Universal Declaration and recognises the principles set out in the ILO conventions.

  • 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

  • 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 7: The COP describes effective management systems to integrate the labour principles
  • 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

  • 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 continuous dialogue with the Trade Unions has been focused on the issues of employment protection, social cohesion and the development of an integrated platform of corporate welfare

  • 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

  • Active engagement with suppliers to address labour-related challenges

Environment
  • Criterion 11: The COP describes effective monitoring and evaluation mechanisms for environmental stewardship
  • 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 related to: fuel management, energy efficiency, innovation, green purchasing and training

  • 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

  • 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
  • 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 of 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 cerfied UNI CEI EN ISO 50001:2011 (applied in 193 sites)

  • 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 9: The COP describes robust commitments, strategies or policies in the area of environmental stewardship
  • 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

    Our commitment to the fight against climate change is defined in an "Environmental and Energy Policy" approved by the Board of Director for the whole Intesa Sanpaolo Group

  • 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

Anti-Corruption
  • Criterion 13: The COP describes effective management systems to integrate the anti-corruption principle
  • 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

  • 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

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

  • Criterion 14: The COP describes effective monitoring and evaluation mechanisms for the integration of anti-corruption
  • Leadership review of monitoring and improvement results (D12)

  • Process to deal with incidents (D13)

  • Outcomes of integration of 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

  • Public legal cases regarding corruption (D14)

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

  • Other established or emerging best practices

  • Criterion 12: The COP describes robust commitments, strategies or policies in the area of anti-corruption
  • 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

    The Bank's Model for the prevention of corruption was updated with a preliminary mapping of the sensitive processes with regard to the risk of the crime of active corruption among privates that envisages specific control and conduct 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

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

UN Goals and Issues
  • Criterion 15: The COP describes core business contributions to UN goals and issues
  • Develop relevant products and services or design business models that contribute to UN goals/issues

  • Other established or emerging best practices

    In 2013 new remmittance services had been launched for migrant. The service is offering transparency of transactions and is targeting the removal of remittances from unconventional channels.

  • 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

  • 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
  • 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

    The Bank in partnership with Onlus and shareholders'Foundations continued to sustain Micro finance initiatives for the prevention of usury. Moreover donations are issued through a special “Fund for charitable,social and cultural donations”

  • 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

  • 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 18: The COP describes partnerships and collective action
  • 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 HIV and to support local development through microfinance initiatives

  • 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 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 letter to stakeholder of the sustainability Report , signed by the CEO and the two presidents, communicate the commitment to the development of projects 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
  • 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

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

  • 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

  • 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

  • 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 (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.

  • 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

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