Code of Ethics

The Code of Ethics published for the first time in 2007, was updated in 2025 with the approval of the Intesa Sanpaolo Board of Directors on 8 April 2025. It 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.

The Code is a document that follows, updating itself, the evolution of the context in which the bank operates, guaranteeing maximum transparency and consistency, prerequisites for a relationship of trust with stakeholders.

It contains voluntary commitments in the management of relations with all internal and external subjects of the Group (stakeholders) making explicit the values ​​and principles of the Group.

Starting from the shared values, the Code directs the behavior of each and every one towards the stakeholders, in line with the commitments made by the Group in relation to international initiatives: UN Global Compact, the contribution to the Sustainable Development Goals, the Women's Empowerment Principles, the Net Zero Alliances as well as the PRB Principles for Responsible Banking, PRI Principles for Responsible Investment and PSI Principles for Sustainable Insurance Programs under the United Nations Environment Program Finance Initiative (UNEP FI). The Code is inspired by the main guidelines existing at national and international level in terms of liability:

• UN Universal Declaration of Human Rights;
• UN Guiding Principles on Business and Human Rights;
• UN Convention on the Rights of the Child;
• United Nations Convention on the Rights of Persons with Disabilities;
• UN International Covenant on Civil and Political Rights;
• Declaration on Fundamental Principles and Rights at Work (ILO) and the other core Labour Conventions, in particular the right of association and collective bargaining, the prohibition of forced and child labour, and nondiscrimination in hiring practices;
• OECD Due Diligence Guidance for Responsible Business Conduct;
• Organisation for Economic Co-operation and Development (OECD) Guidelines for Multinational Enterprises and the anti-corruption principles established by the United Nations;
• Council of Europe Convention on Preventing and Combating Violence against Women (Istanbul Convention);
• Charter of Fundamental Rights of the European Union.

With the aim of making the principles and values ​​set out in this Code concrete, in addition to referring to external guidelines, the Group has adopted various policies that set the guidelines necessary to guarantee transparency and professionalism in the relationship with all interlocutors.

Intesa Sanpaolo adopted, for example, a specific policy on human rights, approved by the Board of Directors in December 2017.

The key characteristics of our Code of Ethics are: great emphasis on dissemination of the sustainability culture, maximum responsibility assigned to the departments aimed at defining a concrete plan of actions and projects, and rigorous and constructive approach in managing critical cases.

The Code is divided into three sections:

• the Charter of Relations, which describes the mission, principles and values, commitments and responsibilities of the Intesa Sanpaolo Group;
• the Principles of Conduct in stakeholder relations;
• the Implementation and Governance mechanisms.

To ensure the widest possible diffusion, the Code of Ethics, published in the web pages of Intesa Sanpaolo and on the company Intranet, is drawn up with particular attention to the inclusion of blind and visually impaired persons, following the rules of accessibility certified by LIA Foundation - Italian accessible books.

A copy is given to each director, employee or external collaborator upon appointment, hiring or beginning of the collaboration agreement, respectively.

The process for managing cases of non-compliance with the Code of Ethics is encoded in corporate policy, protects those who make the reports in good faith from any form of retaliation, discrimination or penalisation, ensuring the utmost confidentiality without prejudice to legal obligations. 
All the stakeholders may report any cases of non-compliance by writing to codice.etico@intesasanpaolo.com.
ESG Steering receives and processes the reports, which can be submitted by any stakeholder and, after assessing them, takes action in collaboration with the departments affected by the reports.

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.

This Code and its updates are approved, with the support of the Risks and Sustainability Committee, by the Board of Directors of Intesa Sanpaolo S.p.A., in its capacity as the Parent Company; they are brought to the attention of the competent bodies of Intesa Sanpaolo’s subsidiaries subject to management and coordination for their adoption.

The Chief Sustainability Officer is responsible for proposing the appropriate changes and necessary updates to the Code in order to ensure its coherence and relevance. 

The governance of the Code is based on: 

• the self-responsibility of the structures that have, in the development of their actions and activities, to safeguard the Group's reputation through socially responsible behaviour, inspired by the principles and values ​​of the Code itself; 
• the annual and possibly intra-annual sustainability reporting, in place 
• the management of reports of alleged non-compliance with the Code
• initiatives for the dissemination of knowledge of the values, principles and commitments expressed in the document and more generally of the culture of sustainability 
• the monitoring of compliance with the principles and values ​​of the Code by ESG & Sustainability of the Central Financial Market Coverage Department and by the structures of the Chief Audit Officer, the latter on the basis of the annual checks program planned from a risk-based perspective 
• any analysis by an independent third party on the application of the principles of the Code.

The Management Control Committee, coordinating with the Supervisory Body pursuant to Legislative Decree no. 231/2001 to the extent of its competence and with the support of the competent functions, supervises compliance with the principles and values ​​contained in the Code.

ESG Steering presents a Report on the Code of Ethics and on the principles of social and environmental responsibility to the Management Control Committee and to the Supervisory Body pursuant to Legislative Decree 231/2001, to the Risk and Sustainability Committee and to the Board of Administration with the contribution of the Chief Audit Officer structure.

The process of implementing the Code of Ethics - which integrates with the management processes underlying the Consolidated Non-financial Statement - may include a third-party evaluation and assessment in accordance with the principles and contents of the ISO 26000 standard. The level certification of Sustainability governance in the Intesa Sanpaolo Group exposes the methodology applied and the results, separately evaluating the area that refers to respect for human rights.