Management of ESG and climate change related risks
The Intesa Sanpaolo Group, in line with the principles outlined in the Code of Ethics, is aware of the importance of a correct and responsible allocation of resources, according to criteria of social and environmental sustainability. Therefore, it promotes a balanced development aimed at redirecting capital flows towards sustainable investments to balance interests such as the preservation of the natural environment, health, work, the well-being of the community as a whole and the safeguarding of the system of social relations.
Also the Environmental and energy policy and the Principles on Human Right provide for the consideration of the environmental, social and governance risks associated with the activities of customer companies in the investment and lending decisions by the Group.
To this end, the monitoring of these risks provides for:
- their inclusion in the Risk Management framework, with particular reference to the governance of Environmental, Social and Governance Risks in lending transations, to the Management of reputational Risks and to the management of the Most Significant Transactions
- their assessment as part of the processes relating to the implementation of the Equator Principles and Reputational Risk Clearing
- a specific focus on reputational risks and Climate Change risk within the "Risk Appetite Framework"
The Group has developed specific Guidelines for the governance of environmental social and governance (ESG) risks which define the general criteria aimed at excluding the financing of companies and/or projects with particularly relevant environmental, social and governance impacts.
Intesa Sanpaolo, in the evaluation of lending transactions, undertakes not to finance companies and projects that are characterised by their negative impact on:
- UNESCO World Heritage Sites
- wetlands under the Ramsar Convention
- IUCN protected areas I to VI
In addition, the Bank undertakes not to finance companies and projects if these are located in areas of active armed conflict, or if evidence emerges, such as legal proceedings brought by the competent authorities, relating to:
- human rights violations
- forced or child labour practices
The sector policies regulating the financing to specific sectors of activities characterised by more relevant ESG and reputational risk profile are referred to this general framework.
The sector policies currently in force are the policy in the armaments sector (“Rules on the granting of credit and transactions in the armament sector”), the coal policy (“Rules for lending operations in the coal sector”) and the rules for the unconventional oil and gas sector ("Rules on Oil&Gas sector").
Moreover, within the Risk Management Framework the transactions with customers operating in sensitive sectors are subject to risk clearing, comprising an evaluation of ESG and reputational risk profile. Sensitive sectors are defined as those sectors that present a relevant ESG risk, including climate risk; a specific focus is provided for in relation to Most Relevant Transactions and to transactions subject to the application of the Equator Principles, voluntary guidelines for the management of social and environmental risks in project finance.
Also the assessment of creditworthiness conducted for corporate customers includes socio-environmental aspects. In particular, an innovative rating model has been developed in collaboration with Confindustria Piccola Industria and validated by the ECB. In the model, social and environmental aspects can also have a positive impact, leading to an improvement in the rating. In addition to the usual economic and financial assessments, the model aims to make it easier to access credit, with more favourable financial terms, by highlighting the intangible qualities of the business, such as trademarks, patents, quality and environmental certifications, research and development activities, innovation and digitalisation, development and competitive positioning projects, management of business risk and being part of a supply chain.
Further details
Guidelines for the governance of environmental social and governance (ESG) risks
Rules on the granting of credit and transactions in the armament sector
ESG risk management: potential impacts and mitigation actions
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.
| Issue | Potential risk | Potential impacts |
Mitigation measures |
| Integrity in corporate conduct |
Compliance risks with applicable legislation (corruption, money laundering, taxation, free competition, privacy, labour law) and
|
Fines and penalties, limitations to conducting business |
Internal control system divided into several levels Definition of corporate internal regulations Specialist training for employees Introducing a whistleblowing system Adoption of internal regulations for the conduct of company operations also in relation to ESG issues |
| Quality of service and customer satisfaction | Unfair commercial practices Inadequate customer service levels Inadequate customer communications Loss of access to services |
Customer dissatisfaction with loss of competitiveness, customers and market shares leading to reduced profitability Disputes and complaints Fines and penalties Damage to reputation and brand |
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 cybersecurity | Ineffective transition from traditional to digital channels IT risk Business continuity in the event of an emergency, blocking or malfunctions |
Loss of competitiveness, customers and market shares leading to reduced profitability Disputes and complaints Fines and penalties Damage to reputation and brand |
Prevention of IT risk Careful assessment of emerging risks Development of an innovative offering/ solutions Physical network integration with online structures (e.g. Isybank) Dissemination of the digital culture Innovations aimed at ensuring accessibility to services for people with disabilities |
| Financial inclusion and supporting production | Inadequate offering of products/services to customers Reputational risks |
Loss of competitiveness, 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 sectors Reputational risks Failure to comply with regulations |
Loss of competitiveness, market shares and customers who are conscious of ESG aspects, leading to reduced profitability Damage to reputation and brand Fines and penalties |
IIntegration of ESG factors into the Investment process Development of an ESG offering Company engagement activities ESG training Internal control system Subscription to Principles for Responsible Investment (PRI) and Principles of Stewardship Subscription to Principles for Sustainable Insurance (PSI) |
| Community support and commitment to culture | Reputational risks | Damage to reputation and brand | Development of investments and partnerships with a social impact in the community 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 | Disputes Strikes with impacts on service continuity for customers and profitability Employee dissatisfaction with impacts on productivity |
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 |
| Retention, enhancement, diversity and inclusion of the Group’s people | Inadequate employee enhancement and motivation Inability to attract and retain talent 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 and development activities Talent Attraction strategy (short and long term) which, broken down by various communication actions and on different channels, is defined with respect to the different targets of interest Talent management and development programmes Recognition of employees’ merit New incentive plans (including LTIP) to foster individual entrepreneurship Succession plans for business continuity Initiatives to enhance diversity and inclusion, including training with a specific focus on the topic Diversity, Equity & Inclusion Principles Sexual orientation and identity diversity regulations Rules for combating sexual harassment Commitment to the “Women’s Empowerment Principles” Request for certifications on relevant topics (e.g. ISO PDR 125:2022) |
| Health, safety and wellbeing of the Group’s people | Accidents in the workplace Occupational diseases Risks associated with the COVID-19 pandemic Robberies Inadequate employee motivation Work/life balance difficulties |
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 Employee dissatisfaction with impacts on productivity Loss of skills as a result of employee exits |
Health and safety training Certification of the health and safety management system (ISO 45001) in all branches and buildings in Italy Certification of the psychosocial risk management system (ISO45003) Biosafety Trust Certification Protocol aimed at preventing and mitigating the risk of infections from biological agents Assessment and management of infection risk Risk assessment for workplaces and work processes Preventing and combating robberies Risk assessment of subjective and social conditions Assessment of work-related stress Work-life balance initiatives Flexible working and new organisational models Voluntary and free medical examinations to promote people’s health 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 ESG risks in loans Transactions or loans in controversial sectors Reputational risks Regulatory compliance risk Litigation risk |
Loss of competitiveness, market shares and customers who are conscious of ESG aspects, leading to reduced profitability Problem loans or need for provisions Damage to reputation and brand |
Inclusion of ESG, climate change and reputational risks within the Risk Appetite Framework Rating model which also includes company qualitative aspects on ESG issues Risk clearing processes which include environmental, social and governance aspects Equator Principles for project finance Group Guidelines for the Governance of Environmental, Social and Governance (ESG) risks Inclusion of ESG factors into the credit framework with Rules for the classification of sustainable credit products and lending transactions Development of a specific offering to facilitate the transition with dedicated plafond, including with a view to derisking of loans Drafting of a transition plan for the target sectors Employee, customer and stakeholder training and engagement Research development |
Management of risks related to climate change
Intesa Sanpaolo takes into account the social, environmental and governance risks, associated with the activities of its customer companies and the economic activities it invests in and pays particular attention to the in-depth study of sustainability issues related to sectors considered sensitive, i.e. those with a significant socio-environmental risk. In this context, the Bank pays particular attention to the risk arising from climate change (both physical risk and transition risk). Key activities in climate risk management concern:
- the identification, assessment and measurement of such risks;
- the implementation, development and monitoring of a company-wide risk management framework, including risk culture, risk appetite and credit limits.
Within the Risk Appetite Framework (RAF), the Group has introduced a specific reference to climate risk, working to develop its integration into the existing risk management framework with particular reference to credit risk and reputational risk.
The potential impacts, the related time horizon (short, medium, long) and the mitigation and adaptation actions taken for each potential risk observed are identified annually, with reference to both indirect and direct risks.
Last updated 3 July 2024 at 16:36:03
