Information is assured by independent assurors (e.g., accounting or consulting firm) against recognized assurance standard (e.g., ISAE3000, AA1000AS, other national or industry-specific standard)

Other established or emerging best practices

Report subject to the limited review of DELOITTE & TOUCHE S.p.A. in accordance with the criteria established in the International Standard on Assurance Engagement 3000 - Assurance Engagements other than Audits or Reviews of Historical Financial Info

Applies the GRI Sustainability Reporting Guidelines or the GRI Standards

Is 'in accordance - core' with GRI Standards

Applies elements of the International Integrated Reporting Framework

Place responsibility for execution of sustainability strategy in relevant corporate functions (procurement, government affairs, human resources, legal, etc) ensuring that no function is conflicting with company sustainability commitments and objectives

Assign responsibility for corporate sustainability implementation to an individual or group within each business unit and subsidiary

Design corporate sustainability strategy to leverage synergies between and among issue areas and to deal adequately with trade-offs

Ensure that different corporate functions coordinate closely to maximize performance and avoid unintended negative impacts

Other established or emerging best practices

Group Sustainability - part of the Group Identity & Communication dept - reports directly to the CEO and is responsible for supporting the management in developing strategies that integrate sustainability considerations into the value creation process.

Implement monitoring and assurance mechanisms (e.g. audits/screenings) for compliance within the company’s sphere of influence

Undertake awareness-raising, training and other types of capacity building with suppliers and other business partners

Other established or emerging best practices

At UniCredit suppliers must meet minimum sustainability requirements and are selected according to the standards of conventions of the ILO.Suppliers must also comply with the standards set forth in our Environmental Policy (2015 IR p.84)

System to monitor the effectiveness of human rights policies and implementation with quantitative and qualitative metrics, including in the supply chain (BRE3 + ARE3)

Monitoring draws from internal and external feedback, including affected stakeholders

Leadership review of monitoring and improvement results

Process to deal with incidents the company has caused or contributed to for internal and external stakeholders (BRE 4 + ARE 4)

Grievance mechanisms that are legitimate, accessible, predictable, equitable, transparent, rights-compatible, a source of continuous learning, and based on engagement and dialogue (BRE4 + ARE4)

Outcomes of integration of the human rights principles

Other established or emerging best practices

We monitor the HR Committment effectiveness by leveraging existing monitoring processes linked to the related practices monitored by the owning functions. Eg. Compliance policies include disciplinary actions applied for potential breaches (p. 93 2015 IR)

Commitment to comply with all applicable laws and respect internationally recognized human rights, wherever the company operates (e.g., the Universal Declaration of Human Rights, Guiding Principles on Human Rights) (BRE1 + ARE1)

Integrated or stand-alone statement of policy expressing commitment to respect and support human rights approved at the most senior level of the company (BRE 1 + BRE5 + ARE 1 + ARE 5)

Statement of policy stipulating human rights expectations of personnel, business partners and other parties directly linked to operations, products or services (BRE 1)

Statement of policy publicly available and communicated internally and externally to all personnel, business partners and other relevant parties (BRE 1 + BRE 5 + ARE 1 + ARE 5)

Other established or emerging best practices

See definition since 2011 of our HR Committment updated in 2015 and with a draft action plan to be finalized by 2016, and implementation of our Policy on Gender Equality in 13 countries.

Process to ensure that internationally recognized human rights are respected

On-going due diligence process that includes an assessment of actual and potential human rights impacts (BRE 2 + BRE 3 + ARE 2 + ARE 3)

Internal awareness-raising and training on human rights for management and employees

Operational-level grievance mechanisms for those potentially impacted by the company’s activities (BRE 4 + ARE 4)

Allocation of responsibilities and accountability for addressing human rights impacts

Processes to provide for or cooperate in the remediation of adverse human rights impacts that the company has caused or contributed to (BRE 3+ BRE 4 + ARE3 + ARE 4)

Process and programs in place to support human rights through: core business; strategic philanthropic/social investment; public policy engagement/advocacy; partnerships and/or other forms of collective action (BRE 6 + ARE 6)

Other established or emerging best practices

Our approach on Human Rights was reinforced by a special program overseen by the GESC established to support and improve our Environmental and Social strategy. As per our HR Committment almost 13,000 people were trained.(2015IR pag 17)

Reference to principles of relevant international labour standards (ILO Conventions) and other normative international instruments in company policies

Reflection on the relevance of the labour principles for the company

Written company policy to obey national labour law, respect principles of relevant international labour standards in worldwide company operations and engage in dialogue with representative organization of the workers (international, sectoral, national).

Inclusion of reference to the principles contained in the relevant international labour standards in contracts with suppliers and other relevant business partners

Specific commitments and Human Resources policies, in line with national development priorities or decent work priorities in the country of operation

Structural engagement with a global union, possibly via a Global Framework Agreement

Participation and leadership by employers’ organizations (international and national) to jointly address challenges related to labour standards in the countries of operation, possibly in a tripartite approach (business – trade union – government).

Other established or emerging best practices

The role of the Diversity Manager was created in 2013 with the approval of the Gender Equality Policy. By the end of 2015 we had 24 people in the job across the Group (pag 65 2015IR)

System to track and measure performance based on standardized performance metrics

Dialogues with the representative organization of workers to regularly review progress made and jointly identify priorities for the future

Process to positively engage with the suppliers to address the challenges (i.e., partnership approach instead of corrective approach) through schemes to improve workplace practices

Outcomes of integration of the Labour principles

Other established or emerging best practices

In 2014 we implemented ourPolicy on Gender Equality in line with the Joint Declaration on Equal Opportunities and Non Discrimination signed by our Group and the EWC in 2009 (please visit our website unicreditgroup.eu "key milestones section")

Risk and impact assessments in the area of labour

Dialogue mechanism with trade unions to regularly discuss and review company progress in addressing labour standards

Allocation of responsibilities and accountability within the organization

Internal awareness-raising and training on the labour principles for management and employees

Grievance mechanisms, communication channels and other procedures (e.g., whistleblower mechanisms) available for workers to report concerns, make suggestions or seek advice, designed and operated in line with the representative organization of workers

Other established or emerging best practices

To manage structural changes in our organization and their impacts on our colleagues in a responsible way we support social dialogue with employee representatives at the international level through the European Works Council (EWC) (pg48 Supplement 2015IR)

System to track and measure performance based on standardized performance metrics

Leadership review of monitoring and improvement results

Process to deal with incidents

Audits or other steps to monitor and improve the environmental performance of companies in the supply chain

Outcomes of integration of the environmental principles

Other established or emerging best practices

Under our environmental management systems, we are conducting second party audits of our suppliers and tours of their facilities(https://www.unicreditgroup.eu/en/a-sustainable-bank/our-capitals/natural-capital/environmental-management-system-.html)

Environmental risk and impact assessments

Assessments of lifecycle impact of products, ensuring environmentally sound management policies

Allocation of responsibilities and accountability within the organisation

Internal awareness-raising and training on environmental stewardship for management and employees

Grievance mechanisms, communication channels and other procedures (e.g. whistleblower mechanisms) for reporting concerns or seeking advice regarding environmental impacts

Other established or emerging best practices

Environmental Management Systems across the Group ensure the implementation of environmental programs in order to reduce impacts related to our operations and lending practices (ref to pag. 83-84 2015IR).

Reference to relevant international conventions and other international instruments (e.g. Rio Declaration on Environment and Development)

Reflection on the relevance of environmental stewardship for the company

Written company policy on environmental stewardship

Inclusion of minimum environmental standards in contracts with suppliers and other relevant business partners

Specific commitments and goals for specified years

Other established or emerging best practices

We are committed to acting responsibly related to procurement activities.(https://www.unicreditgroup.eu/content/dam/unicreditgroup-eu/documents/en/sustainability/environment-suppliers/environmental-management-system/Environmental_Commitment-160615.pdf)

Support by the organization’s leadership for anti-corruption (B4)

Carrying out risk assessment of potential areas of corruption (D3)

Human Resources procedures supporting the anti-corruption commitment or policy, including communication to and training for all employees (B5 + D8)

Internal checks and balances to ensure consistency with the anti-corruption commitment (B6)

Actions taken to encourage business partners to implement anti-corruption commitments (D6)

Management responsibility and accountability for implementation of the anti-corruption commitment or policy (D7)

Communications (whistleblowing) channels and follow-up mechanisms for reporting concerns or seeking advice (D9)

Internal accounting and auditing procedures related to anticorruption (D10)

Other established or emerging best practices

Mechanisms to effectively manage:escalation procedures, quarterly management information requested from hub entities(Italy, Germany, Austria, Poland);Compliance Risk Assessment processes performed for each regulatory area in all legal entities (supp pg32)

Leadership review of monitoring and improvement results (D12)

Process to deal with incidents (D13)

Outcomes of integration of the anti-corruption principle

Other established or emerging best practices

Mechanisms to effectively monitor: quarterly management information requested and periodically (at least once a year) report to BoD.

Publicly stated formal policy of zero-tolerance of corruption (D1)

Commitment to be in compliance with all relevant anti-corruption laws, including the implementation of procedures to know the law and monitor changes (B2)

Detailed policies for high-risk areas of corruption (D4)

Policy on anti-corruption regarding business partners (D5)

Other established or emerging best practices

UniCredit has zero tolerance towards acts of corruption, prohibts facilitation payments and does not permit any transfer of value to pubblic officals without approval, also forbids political donations (Supp. pg 32-33 2015IR)

Pursue social investments and philanthropic contributions that tie in with the core competencies or operating context of the company as an integrated part of its sustainability strategy

Coordinate efforts with other organizations and initiatives to amplify—and not negate or unnecessarily duplicate—the efforts of other contributors

Take responsibility for the intentional and unintentional effects of funding and have due regard for local customs, traditions, religions, and priorities of pertinent individuals and groups

Other established or emerging best practices

The UC Foundations deal with philantropy/social innovation and support young generations, in parnterships and joint actions with other companies/institutions (pag 78-79 2015IR)

Publicly advocate the importance of action in relation to one or more UN goals/issues

Commit company leaders to participate in key summits, conferences, and other important public policy interactions in relation to one or more UN goals/issues

Other established or emerging best practices

CEO commitment to UN Global Compact support (pag 5 2015IR) and - in general - company commitments to issues related to labor, anti-corruption, human rights and environment. Among others, Group CEO formally endorses Natural Capital Declaration

Align core business strategy with one or more relevant UN goals/issues

Develop relevant products and services or design business models that contribute to UN goals/issues

Adopt and modify operating procedures to maximize contribution to UN goals/issues

Other established or emerging best practices

UniCredit promotes social inclusion and helps communities thrive through our colleagues' volunteer efforts and our Group's long term commitments to and cooperation with non profit entities (pag 78 2015IR)

Develop and implement partnership projects with public or private organizations (UN entities, government, NGOs, or other groups) on core business, social investments and/or advocacy

Join industry peers, UN entities and/or other stakeholders in initiatives contributing to solving common challenges and dilemmas at the global and/or local levels with an emphasis on initiatives extending the company’s positive impact on its value chain

Other established or emerging best practices

Main partnerships and affiliations , supp 2015IR pag 4-5

CEO leads executive management team in development of corporate sustainability strategy, defining goals and overseeing implementation

CEO publicly delivers explicit statements and demonstrates personal leadership on sustainability and commitment to the UN Global Compact

CEO promotes initiatives to enhance sustainability of the company’s sector and leads development of industry standards

Make sustainability criteria and UN Global Compact principles part of goals and incentive schemes for CEO and executive management team

Other established or emerging best practices

Compensation policy aligns business needs and sustainable goals.Goal setting process for Group executives based on specific guidelines for performance management (https://www.unicreditgroup.eu/en/governance/compensation.html?topmenu=INT-TM_GOV9_en031)

Publicly recognize responsibility for the company’s impacts on internal and external stakeholders

Define sustainability strategies, goals and policies in consultation with key stakeholders

Consult stakeholders in dealing with implementation dilemmas and challenges and invite them to take active part in reviewing performance

Establish channels to engage with employees and other stakeholders to hear their ideas and address their concerns

Other established or emerging best practices

Stakeholder engagement pagg 26-27 2015IR and Social and Relationship Suppl to 2015IR pagg 58 to 61

Board of Directors (or equivalent) assumes responsibility and oversight for long-term corporate sustainability strategy and performance

Board (or committee), where permissible, approves formal reporting on corporate sustainability (Communication on Progress)

Other established or emerging best practices

We established the Group Environmental and Social Council (GESC) to oversee the implementation of UniCredit’s environmental and social initiatives and commitments in cooperation with all relevant counterparts (pag 11;17;82 2015IR)

Achieving and maintaining gender equality in senior management and board positions

Achieving and maintaining gender equality in middle management positions

Equal pay for work of equal value

Flexible work options

Access to child and dependent care

Support for pregnant women and those returning from maternity leave

Recruitment and retention, including training and development, of female employees

Gender-specific health and safety issues

Education and training opportunities for women workers

Creating and maintaining workplace awareness of gender equality and, inclusion and non-discrimination for all workers

Mentoring and sponsorship opportunities for women workers

Other established or emerging best practices

Our Gender Balance Program received a further boost in 2015 with the CEO signing the Statement of Support for the UN Women's Empowerment Principles - please refer to pag 65 of our 2015 Integrated Report

Support for women business owners and women entrepreneurs

Supplier monitoring and engagement on women's empowerment and gender equality including promotion of the Women's Empowerment Principles to suppliers

Gender-sensitive marketing

Gender-sensitive product and service development

Other established or emerging best practices

In our Global Policy on Gender Equality we state that each Legal Entity will also have to circulate the document to its suppliers and subcontractors

Achieving and maintaining gender equality in senior management and board positions

Achieving and maintaining gender equality in middle management positions

Equal pay for work of equal value

Recruitment and retention, including training and development, of female employees

Education and training opportunities for women workers

Mentoring and sponsorship opportunities for women workers

Other established or emerging best practices

Please refer to the 2015 Supplement to the 2015 Integrated Report (Human Capital section)

Designing community stakeholder engagements that are free of gender discrimination/stereotyping and sensitive to gender issues

Gender impact assessments or consideration of gender-related impacts as part of its social and/or human rights impact assessments

Ensuring female beneficiaries of community programmes

Community initiatives specifically targeted at the empowerment of women and girls

Other established or emerging best practices

In Germany in 2015 we offered mentoring programs for startups run by experienced businesswomen from the HVB Women’s Council and startup experts from the bank to encourage new entrepreneurial ventures by women (pag 77 2015IR)