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Code of Ethics

The Code of Ethics approved in 2007 and updated in December 2016, is adopted by all the banks and the companies of the Intesa Sanpaolo Group in Italy and abroad as a self-regulation document for the integration of social and environmental considerations into company processes, practices and decisions beyond those required by Legislative Decree 231/2001. It contains voluntary commitments in the management of relations with all the Group’s internal and external stakeholders, setting out the core values and principles of the Group. 

Implementation and Governance

Intesa Sanpaolo has adopted an implementation and governance system aimed at promoting the integration of company strategies, policies and procedures with the principles and values stated in the Code of Ethics, through an uttermost sharing and diffusion of its contents.

The model from which the Intesa Sanpaolo Group draws inspiration is based on the self-responsibility of departments that pursue and defend the reputational value of socially responsible behaviour.
Each company department develops its actions and activities being inspired by the principles and values of the Code of Ethics. Every department is therefore directly responsible, within its own sphere of influence, for determining and formalising the goals, as well as the consequent plan of actions and projects.

Within each department and Subsidiary Bank, Corporate Social Responsibility (CSR) Delegates are appointed who, operating within their department and in network, cooperate with Corporate Social Responsibility by identifying the social responsibility objectives within their own structure, managing, monitoring, and periodically reporting on the projects in progress and maintaining relations with the reference stakeholders.

ESG & Sustainability:

  • on the one hand, monitors the effectiveness of dissemination and information through tools identified each time starting from internal assessments focused on measuring knowledge and awareness highlighting areas of weakness and possible intervention; on the other hand, in case of sensitive ethical and reputational areas provides and shares company's policies and guidelines
  • supports and advises departments within the company
  • in agreement with the responsible functions identifies and reports specific indicators to assess the level of achievement of social and environmental goals compared to the commitments undertaken
  • cooperates with the Human Resources Department in the development and diffusion of the culture and values contained in the Code of Ethics
  • monitors, with the support of the Chief Audit Officer, the compliance with the principles and values contained in this Code of Ethics, reporting annually to the Management Control Committee and to the Supervisory Body in accordance with Legislative Decree 23/2001
  • proposes the appropriate changes to make the Code consistent with the current company’s situation

The implementation process of the Code of Ethics – integrated with the management processes underlying the Sustainability Report – envisages an evaluation and a third-party assessment in accordance with the principles and contents of the ISO 26000 standard. The statement on the CSR governance level in the Intesa Sanpaolo Group describes the method applied and the results, with separate assessment of respect for human rights.

Assurance Statement over the governance on Corporate Social Responsibility - January 2022
Audit interventions to verify the implementation of the Code of Ethics

Compliance with the principles and values of the Code of Ethics was monitored with the support of the current Chief Audit Officer, so that it could be reported annually to the Management Control Committee and the Surveillance Body pursuant to Legislative Decree 231/2001. Audits were conducted on 20 risk areas that also considered social and environmental responsibility aspects and implications including:

  • Governance of ESG projects and initiatives (transversal audit)
  • Transactions with Related Parties and associated entities
  • Personnel remuneration and incentive systems (in various Group companies)
  • Research and Development Special Fund reporting
  • Monitoring of acquisitions under centralised management
  • Checks on loan disbursement activities on specific sectors or business areas, in correlation with the ongoing pandemic emergency (“Management of COVID-19 moratoria”) or with environmental requalification
  • incentives (e.g.: Superbonus, Ecobonus bonuses and other tax incentives in the construction sector)
  • Management of loans to innovative start-ups (focus on customers of the Banca dei Territori Division)
  • Evolution of social impact initiatives under the Impact Fund (mainly with regard to aspects related to financial inclusion) and pledge lending business analysis
  • Analysis of consumer protection and claims management activities in Prestitalia (again with regard to aspects related to financial inclusion)
  • Assessment of the governance and business model processes of Intesa Sanpaolo Innovation Center
  • Customer complaints management activities (on various Group companies) and in general measures aimed at assessing the service quality (e.g.: focus on the order acquisition process from Private customers)
  • Assessment, in the context of the analysis of “corporate” lending transactions, of the correctness of the procedures adopted for specific transactions in sensitive sectors (Oil & Gas, Gaming, energy production, weaponry sector)
  • Within the Banca dei Territori Division, personnel management and reallocation in relation to the integration with the UBI Banca Group, and introduction of smart working for Network personnel
  • Opening and management of relations with institutional customers in IW Bank
  • Analysis of the methods for disposal of some scrapped goods (UbiLeasing).
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