Code of Ethics

The Code of Ethics published for the first time in 2007, was updated in 2023 with the approval of the Intesa Sanpaolo Board of Directors on 28 June 2023. 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 & Sustainability 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.

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.