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.

Potential risk
Potential impacts
Mitigation measures
Integrity in corporate

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

Fines and penalties,
limitations to conducting
Damage to reputation and
Compliance system divided
into different levels to monitor
the compliance risk, with
specialised functions
Internal control system
Definition of corporate internal
Admission to the cooperative 
compliance scheme with the Italian Revenue Agency
Specialist training for employees 
Introducing a whistleblowing system 
Guidelines for the governance 
of environmental, social and 
governance risks in lending 
activities and associated self-regulation 
policies for sensitive sectors 
Adherence to UNEP FI's 
Principles for ResponsibleBanking (PRB) 
Service quality and
customer satisfaction
Unfair commercial
Inadequate customer
service levels
Inadequate customer
Loss of access to
dissatisfaction with loss 
of competitiveness, 
customers and market 
shares leading to 
reduced profitability
Disputes and complaints 
Fines and penalties 
Damage to reputation and 
Model focussing on the level of
service, on personalised advisory services,
and on transparency
Process of clearing for new
products and services
Careful and proactive
management of complaints
Dialogue with Consumer Associations
Initiatives aimed at ensuring 
accessibility to services
Business continuity plan
Innovation, digital 
transformation and 
Ineffective transition 
from traditional to 
digital channels
IT risk
Business continuity 
in the event of an 
emergency, blocking 
or malfunctions
Loss of 
customers and market 
shares leading to 
reduced profitability
Disputes and 
Fines and penalties
Damage to reputation 
and brand
Prevention of IT risk 
Careful assessment of emerging risks 
Development of an innovative offering/ 
Physical network integration with online 
Dissemination of the digital culture 
Innovations aimed at ensuring 
accessibility to services for people with 
Financial inclusion and 
supporting production
Inadequate offering of 
products/services to 
Reputational risks
Loss of 
customers and market 
shares leading to 
reduced profitability 
Damage to reputation 
and brand 
Offering development in favour or 
financial inclusion for vulnerable people 
Development of solutions in support of 
the third sector 
Offering development to
support production
Sustainable investments
and insurance
Assessment and control
of ESG risks in the
investment portfolios
Investments in controversial
Reputational risks
Failure to comply with 
Loss of competitiveness,
market shares and
customers who are
conscious of ESG aspects,
leading to reduced
Damage to reputation and
Fines and penalties

Integration of ESG factors into the 
Investment process
Development of the range of ESG 
Company engagement activities
ESG training 
Internal control system
Subscription to PRI (Principles 
for Responsible Investment) 
and the Principles of 
Subscription to PSI (Principles 
for Responsible Insurance)
Community support Reputational risks
Damage to reputation 
and brand
Development of investments and 
partnerships with a social impact in the 
Development of training and work 
projects for the next generations 
Initiatives supporting the promotion of 
culture for social cohesion 
Development of institutional initiatives 
in support of the community
Employment protection Conflicts and related 
labour dispute risks
Strikes with impacts on
service continuity for
Employee dissatisfaction
with impacts on
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
System of labour relations
enhancement, diversity
and inclusion
of the Group’s people
Inadequate employee
growth and motivation
Incapacity to acquire and
maintain talents 
Termination of 
the employment 
relationship with 
managers holding 
relevant roles
Insufficient focus on 
diversity and inclusion issues
Employee dissatisfaction
with impacts on productivity
Lack of adequately trained
and qualified personnel
Inadequate customer
service levels
Damage to reputation 
and brand
Investments in training activities
Talent management programmes
Recognition of employees' merit
Succession plans for business 
Initiatives to enhance diversity and 
inclusion, including training with a 
specific focus on the topic
Diversity & Inclusion Principles 
Sexual orientation and identity 
diversity regulations
Rules for combating sexual harassment
Adhesion to “Women’s Empowerment
Health and safety
of customers and
Accidents in the workplace
Occupational diseases
Risks associated 
with the COVID-19 pandemic
Employee dissatisfaction
with impacts on productivity
Damage to persons 
arising from the 
COVID-19 pandemic
Damage to persons and objects
during robberies
Damage to reputation 
and brand
health and safety training
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
Development of specific organisational, 
training, technical and medical solutions 
to combat the COVID-19 pandemic
Preventing and combating
Employee well-being
Inadequate employee 
Work/life balance 
Employee dissatisfaction
with impacts on productivity
Loss of skills as result of
employee exits

Risk assessment of subjective
and social conditions
Assessment of work-related
Work-life balance initiatives
Offering of solutions for welfare and 
quality of life in the company
Development of climate surveys

Transition to a  
sustainable, green and 
circular economy
Management of social
and environmental risks
in loans
Transactions or loans in
controversial sectors
Reputational risks
Loss of 
competitiveness, market 
shares and customers 
who are conscious of 
ESG aspects, leading to 
reduced profitability 
Problematic loans or 
need for provisions 
Damage to reputation 
and brand
Non-performing loans or 
needs for provisions 
Damage to reputation and 

Assessment of ESG, climate change 
and reputational risks within the Risk 
Appetite Framework
Rating model which also includes 
intangible aspects of companies 
Risk clearing processes which 
include environmental, social and 
governance aspects 
Equator Principles for project 

Guidelines for the governance
of environmental, social and
governance risks concerning lending
operations and associated self-regulation
policies for sensitive
Opinions involving the
assessment of social-environmental
Inclusion of ESG factors into the credit 
Development of a specific offering to 
facilitate the transition with dedicated 
Employee and customer training and 
Development of study and research 

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