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Management of environmental, social and governance risks

The Group has implemented specific processes and responsibilities to understand and manage risks in such a way as to ensure long-term soundness and continuity, extending the benefits to its stakeholders. 
Below is an overview of the main ESG risks that are significant due to their potential impact on company activities and the related mitigation measures.

Issue
Potential risk
Potential impacts
Mitigation measures
Integrity in corporate
conduct

Risks of non-compliance
with applicable legislation 
(corruption, money,
laundering, taxation, free
competition, privacy,
labour law) and ineffective
response to regulatory
changes
Risk of providing
employees with insufficient
or no training
Reputational risks

Fines and penalties,
limitations to conducting
business
Damage to reputation and
brand
Compliance system divided
into different levels to monitor
the risk of non-compliance, with
specialised functions
Internal control system
Definition of corporate internal
regulations
Specialist training for employees
Introducing a whistleblowing
system
Guidelines for the governance
of environmental, social and
governance risks in lending
activities and associated selfregulation
policies for sensitive
sectors
Adherence to UNEP FI's
Principles for ResponsibleBanking (PRB)
Service quality and
customer satisfaction
Unfair commercial
practices
Inadequate customer
service levels
Inadequate customer
communications
Ineffective transition
from traditional to digital
channels
Inadequate customer
communications
Business continuity in the
event of an emergency,
blocking or malfunctions
Loss of competitiveness,
customers and market
shares leading to reduced
profitability
Disputes and complaints
Fines and penalties
Damage to reputation and
brand
Damage to persons and
objects during robberies
Model focussing on the level of
service, on personalised advice,
and on transparency
Process of clearing for new
products and services
Careful and proactive
management of complaints
Innovation in the offer aimed at
ensuring accessibility to services
Business continuity plan
Multichannel approach
and accessibility
IT risk
  Prevention of IT risk
Health and safety
of customers and
employees
Accidents in the workplace
Occupational diseases
Robberies
  Certification of the health and
safety management system
(ISO 45001) in all branches and
buildings in Italy
Assessment and management
of infection risk
Risk assessment for
workplaces and work processes
Coordination and rules for
health and safety management
systems in Banks of the ISBD
scope
Preventing and combating
robberies
Employee well-being
Health and safety of
employees
Employee dissatisfaction
with impacts on productivity
Risk assessment of subjective
and social conditions
Assessment of work-related
stress
Work-life balance initiatives
Prevention and welfare for
employees
Supporting to
production
Management of social
and environmental risks
in loans
Transactions or loans in
sensitive sectors
Reputational risks
Non-performing loans or
needs for provisions
Damage to reputation and
brand
Rating model which also includes
intangible aspects of companies
Risk clearing processes which
include environmental, social and
governance aspects
Equator Principles for project
finance
Guidelines for the governance
of environmental, social and
governance risks in lending
activities and associated selfregulation
policies for sensitive
sectors
Opinions involving the
assessment of socialenvironmental
fact
Sustainable investments
and insurance
Assessment and control
of ESG risks in the
investment portfolios
Investments in sensitive
sectors
Reputational risks
Loss of competitiveness,
market shares and
customers who are
conscious of ESG aspects,
leading to reduced
profitability
Damage to reputation and
brand
Subscription to PRI (Principles
for Responsible Investment)
and the Principles of
Stewardship
Subscription to PSI (Principles
for Responsible Insurance)
Range of Ethical/ESG funds
Company engagement activities
Retention,
enhancement, diversity
and inclusion
of the Group’s people
Inadequate employee
growth and motivation
Incapacity to acquire and
maintain talent
Insufficient focus on
diversity and inclusion
§issues
Employee dissatisfaction
with impacts on productivity
Lack of adequately trained
and qualified personnel
Inadequate customer
service levels
Investments in training activities
Talent management programmes
Recognition of employees' merit
Initiatives to ensure diversity and
inclusion
Diversity & Inclusion Principles
Sexual orientation and identity
diversity regulations
Employment protection Conflicts and related 
labour dispute risks
Disputes
Strikes with impacts on
service continuity for
customers
Employee dissatisfaction
with impacts on
productivity
Responsible management
of corporate restructuring
processes, with the reallocation
of employees to other activities
New hires to promote
generational change
Management of labour dispute risks
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