Relations with national, European and international institutions and advocacy actions

Intesa Sanpaolo, through the Chief Institutional Affairs and External Communication Officer Governance Area, develops and mantains relations with national, European and international institutions, regulators and supervisors and stakeholders, also on sustainability issues.

The Group participates in the debate on new regulatory proposals in the areas of competence, by sharing the the knowledge across the relevant internal Functions and updating them on the developments of relevant consultations and legislative processes, as well as the timely implementation of corrective measures required by supervisory authorities.

Environmental sustainability is an European goal

2022 was a year that saw the continuing of the increasing trend of the political pressure at European level for sustainability, that remains as a priority and a central issue by the Von der Leyen Commission.

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 Sustainability Reporting Committees - ESRS, the activities attributable to the regulation on the European taxonomy and the progress on the legislative processes of the Green Bond Standard Regulation and the Corporate Sustainability Due Diligence Directive) and the presentation of the "RepowerEU" legislative package which adds the phasing out of fuels fossil fuels to meet the targets for reducing climate-changing emissions by 2030 through the "Fit for 55" package. In particular, all activities related to the new strategy for sustainable finance are directly relevant to Intesa Sanpaolo.

Sustainable finance and digitalization of banking sector

In addition, advocacy and monitoring of the European Commission's initiatives included in the first Action Plan on Sustainable Finance continued during 2020, and the Group continued to be an active member  of the European Banking Federation (EBF), of the European Mortgage Federation (EMF) and of the Association for Financial Markets in Europe (AFME) working groups on Sustainable Finance. 

In addition, Intesa Sanpaolo continued to promote its distinctive positioning in terms of financing the circular economy to relevant stakeholders

With regards to banking digitalization, an ongoing coordination of internal and external working groups active on issues such as FinTech and innovative digital payments, Distributed Ledger Technology and Blockchain, cloud, cybersecurity, artificial intelligence, data economy and open finance, digital euro, digital identity, new digital assets (such as crypto-assets) was ensured. The aim was promoting a regulatory framework in line with the Group's position at European level, according to an approach aimed at encouraging innovation on one hand and consumer and investor protection on the other. 

Partnerships in Europe

On these issues, the collaboration with European trade associations has continued, with the participation of Intesa Sanpaolo experts in thematic working groups that have defined the positions of the industry on the main European initiatives in the digital field.

The Group is continuing to follow the legislative process of the European Commission's proposed regulation on DORA (Digital Operational Resilience Act), which is part of the broader "Digital Finance" package. DORA aims at making the financial sector more resilient to cyber risks. The Group is continuing to play its role in the Public-Private Partnership on Cybersecurity, supported by the European Commission, through its membership in ECSO (European Cyber Security Organisation) to develop innovative European cybersecurity solutions.

The Bank is participating in a European project that has received funding to develop a "common application" for the harmonization of cyber incident reporting.

In relation to blockchain, the Group has become a member of INATBA – the International Association for Trusted Blockchain Applications - which offers DLT developers and users a global discussion forum to interact with regulators and policy makers and take blockchain technology "to the next level."

With regard to the cloud, the Group continues to oversee advocacy activities in the associative sphere (e.g. the European Banking Federation) with particular attention to the issue of cloud switching (i.e. facilitating the transition from one cloud service provider to another), as well as the initiatives European standards (such as GAIA-X) with a view to promoting by-design compliance of cloud services with existing and/or consolidating European values ​​and legislation.

Banking regulations

From the point of view of banking regulation, the Institutional Affairs Department (DIA) in 2022 followed the legislative activities relating to i) the review of the legislation on capital requirements, ii) the management of banking crises and the completion of Banking Union, iii) initiatives on financial services and capital markets and iv) legislative proposals on retail credit. In particular, as part of the new banking package presented in autumn 2021, the Group's advocacy activity continued to support proposals aimed at encouraging green investments, infrastructure projects and support for the real economy, including trade finance.   

With reference to prudential requirements, the bank is actively working both with ABI and with associations at European level on possible support factors for ESG assets. In particular, ISP, the Bank participates in the Energy Efficient Mortgages initiative supported by EMF. Furthermore, for the relaunch of the securitization market, the Bank participated in associative roundtables with EBA and is contributing to the possible definition of green securitization.

Financial markets

With regard to financial markets, regulatory initiatives under the new EU action plan on the Capital Markets Union (CMU) were monitored and advocated. As regards the CMU, we point out the ESAP (European Single Access Point Regulation) legislative initiative, published in November 2021 and currently being analyzed by the co-legislators. The initiative intends 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 information on ESG matters) on EU companies, financial and non-financial, listed and unlisted (including SMEs) object of potential investment, in order to give them greater visibility towards investors.
The following European legislative initiatives are also subject to attention: i) Listing Act, aimed at facilitating access to the capital market for SMEs; ii) EMIR 3.0, which revises the regulatory framework of derivatives clearinghouses, which are also essential in 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 the event of failed settlement; iv) the revision of the Mifir regulation.
Lastly, as regards retail credit, ISP followed the legislative proposal for the revision of the Consumer Credit Directive, published in June 2021 and currently under discussion between the co-legislators.

Lastly, as regards retail credit, Intesa Sanpaolo followed the legislative proposal for the revision of the Consumer Credit Directive, published in June 2021 and currently under discussion among the co-legislators, and the work relating to the consultation on the revision of the Mortgage Credit Directive. (MCD), which will also be revised and updated. In the Consultation, particular attention was paid to the so-called green mortgages, testifying to the interest of legislators and the market in ESG credit categories.

Information channels

The Group functions involved are kept constantly updated through periodic newsletters concerning European policies for growth, innovation, support to businesses, digital policies and those relating to banking and financial market regulations. Targeted updates (so-called EU Regulatory Alerts) are also sent, in the presence of significant news related to regulations that require particularly attention due to the impact they may have on the Group's strategy and activities and, depending on the priority indicated, require the definition of the Group's position to be presented to the European institutions and other stakeholders.

In order to make the activities of the internal working groups more effective, support and training are provided to Group Departments and Services, in particular through seminars aimed not only at presenting the peculiarities of the European legislative process and the possibility for the Group to influence its final decisions, but also at illustrating the status of the art of the most relevant incoming regulations.

Single Supervisory Mechanism e Single Resolution Board

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.

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