Relations with national, European and international institutions and advocacy actions

The political centrality of environmental sustainability (in all its forms) is also demonstrated by the intensity of the legislative activities linked to this priority, among which we can mention the works attributable to the "renewed strategy for sustainable finance" (such as the advances in the definition of European sustainability reporting standards - ESRS, the activities related to the regulation on the European taxonomy and the progress on the legislative processes of Green Bond Standard Regulation and Corporate Sustainability Due Diligence Directive) and the presentation of the "RepowerEU" legislative package which adds phasing out of Russian fossil fuels to the objectives of reducing climate-changing emissions by 2030 set through the "Fit for 55" package. In particular, all activities linked to the new strategy for sustainable finance are directly relevant for Intesa Sanpaolo.

The advocacy and monitoring activity of the European Commission's legislative initiatives on sustainable finance also continued and the Group continued to participate in the working tables on Sustainable Finance of the European Banking Federation (FBE), of the European Mortgage Federation (EMF) and the Association for Financial Markets in Europe (AFME). Furthermore, Intesa Sanpaolo continued to promote its distinctive positioning in terms of financing the circular economy towards relevant stakeholders.

In the field of banking digitalisation, there is constant coordination of internal and external working groups active on issues such as FinTech and innovative digital payments, cybersecurity, artificial intelligence, data economy and open finance, digital euro, digital identity, new digital assets (such as crypto-asset ), with the aim of promoting a regulatory framework in line with the Group's position at European level, according to an approach aimed at encouraging innovation on the one hand and the protection of consumers and investors on the other.

Collaboration with European trade associations continued on these issues, which saw the participation of Intesa Sanpaolo experts in the thematic working groups that defined the industry's positions on the main European initiatives in the digital field.

The Group is monitoring the second level legislation of the regulation on the DORA-Digital Operational Resilience Act, which is part of the broader "Digital Finance" package and which aims to make the financial sector more resilient to cyber risks. The Group is continuing to play its role within the Public-Private Partnership on Cybersecurity, supported by the European Commission, through its membership of ECSO - European Cyber ​​Security Organization to develop innovative European cybersecurity solutions.

Regarding the establishment of a European digital identity framework, the Group participates in the activities of the European Union pilot project for testing the European Digital Identity Wallet (EDIW) for payment purposes.

On the subject of Artificial Intelligence, the Group has followed the legislative process on the AIA-Artificial Intelligence Act, now adopted, also with a view to its strong commitment to the principles of responsible AI.

Finally, the proposal for a European regulation on data sharing (so-called FIDA) is also the subject of attention, which aims to open the financial data of European customers to third parties - on the basis of their prior consent - and which presents critical aspects also relating to security and fraud.

From the point of view of banking regulation, the Institutional Affairs Directorate (DIA) during 2023 followed the legislative process relating to i) the revision of the legislation on capital requirements, ii) the management of banking crises and the completion of the Banking Union, iii) initiatives regarding financial services and capital markets and iv) legislative proposals regarding retail credit. In particular, as part of the new banking package presented in autumn 2021, ISP's advocacy activity continued to support proposals aimed at encouraging green investments, infrastructure projects and support for the real economy, including trade finance.

The Bank also participates in the Energy Efficient Mortgages initiative supported by the European Mortgage Federation. Furthermore, to relaunch the securitization market, the Bank has participated in associative roundtables with the EBA and is contributing to the possible definition of green securitisation.

As regards the financial markets, the regulatory initiatives falling within the scope of the new EU action plan on the Capital Markets Union (CMU) are monitored and object of advocacy. As regards the CMU, the ESAP (European Single Access Point Regulation) legislative initiative was carefully followed. The initiative aims to promote the establishment of a platform that acts as a single and centralized point at EU level for free access to relevant information (including ESG information) on EU companies, financial and non-financial, listed and unlisted (including SMEs) subject to potential investment, in order to give them greater visibility towards investors.

The following European legislative initiatives were also the subject of attention: i) Listing Act, aimed at promoting access to the capital market for SMEs; ii) EMIR 3.0, which revisits the regulatory framework of derivatives clearing houses, also essential from a post-Brexit perspective; iii) the revision of the regulation on central depositories (CSDR), where one of the points of attention is the reform of the penalty mechanism in case of failure to settle; iv) the revision of the Mifir regulation; the Retail Investment Strategy.

Lastly, as regards the retail payments sector, the Directive and regulation on payment services (PSD3 and PSR) and the legislative package relating to the digital euro are being monitored.

The Group functions involved are constantly updated via periodic newsletters regarding European policies for growth, innovation, business support, digital policies and those regarding banking and financial market regulations. Targeted updates (so-called EU Regulatory Alert) are also sent if significant regulatory changes occur that require the attention of the functions concerned due to the impact they may have on the Group's strategy and activities and, depending on the priority indicated, require the definition of a Group position to be represented to the European institutions and other stakeholders.

In order to make the activity of the internal working groups more effective, support and training are provided to the Group's operational and business structures, in particular through seminars aimed at presenting the peculiarities of the European legislative process, updating them on the orientations of the legislators during the legislative process, illustrate the status and details of current and future relevant regulatory dossiers.

Since the SSM (Single Supervisory Mechanism) was launched at the end of 2014, the Department maintains an ongoing relationship with the Single European Supervisor, coordinating the Group's annual supervision plan, aiming to ensure due consistency and uniformity in interaction processes with the supervisor and to promote a widespread culture of "supervisory awareness" to increasingly strengthen the capacity to respond to Supervisor's requests. The Bank also maintains, through its dedicated structures, an ongoing relationship also with the Single Resolution Board, the EU authority responsible for managing the resolution of large banks in difficulty.