The COP describes any action(s) that the company plans to undertake by its next COP to have the credibility of the information in its COP externally assessed, including goals, timelines, metrics, and responsible staff

Information is reviewed by multiple stakeholders (e.g., representatives of groups prioritized in stakeholder analysis)

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)

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

Provides information on the company’s profile and context of operation

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

Other established or emerging best practices

Intesa Sanpaolo CSR management model is based on a self-governance principle. The “CSR Delegates” –60 colleagues in different Bank departments - collaborate with the CSR Unit in managing sustainability issues in their various areas of operation

Analyze each segment of the value chain carefully, both upstream and downstream, when mapping risks, opportunities and impacts

Communicate policies and expectations to suppliers and other relevant business partners

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

Other established or emerging best practices

The control of the Code of Ethics implementation in the corporate activities - integrated with the Sustainability Report management process - envisages a self-assessment by the department heads as well as third-party verification

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)

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)

Other established or emerging best practices

Structured management processes have been defined in specific sensitive areas such as project finance/Project related corporate loans (Equator Principles application areas) and for transactions in the field of weapons through a restrictive internal policy

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

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

Outcomes of the due diligence processes (quantitatively/qualitatively monitoring) are disclosed publicly on the Social Report and on the website of the bank

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

The CSR management control system is capable of identifying, measuring and monitoring, the risks resulting from non-application of principles for the protection of human rights. The results of this process are presented to the Control Committee

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

Audits or other steps to monitor and improve the working conditions of companies in the supply chain, in line with principles of international labour standards

Outcomes of integration of the Labour principles

Other established or emerging best practices

Trade Unions and Employees are regularly included in stakeholder engagement activities. The results of the dialogue processes are published yearly in detail on the website

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

Other established or emerging best practices

The Code of Ethics, linked to the Group’s Code of Conduct, states that the Bank is committed to helping safeguard human rights in accordance with the principles of the Universal Declaration and recognises the principles set out in the ILO conventions

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

Active engagement with suppliers to address labour-related challenges

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

The Labour/Management Relations Protocol was renewed, envisaging the establishment of a mixed company-trade union entity, the “Welfare, Safety and Sustainable Development Committee”, with the objective of drawing up solutions for work life balance

System to track and measure performance based on standardized performance metrics

Leadership review of monitoring and improvement results

Process to deal with incidents

Outcomes of integration of the environmental principles

Other established or emerging best practices

A notable reduction of around 7.4% in CO2 equivalent emissions deriving from electricity and heat consumption was recorded in 2015 due to management saving and plant efficiency actions

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

A dedicated team within the CSR Unit is in charge of monitoring the environmental direct impacts of the Bank also through the adoption of an Environmental and Energy Management System certified ISO 14001 and ISO 50001 (till now applied to 210 sites)

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

Environmental protection and the focus on climate change are key areas of our commitment, reiterated and enshrined in the Group’s Environmental and Energy Policy which is regularly updated and approved by the Board of Directors

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)

Statement of support for international and regional legal frameworks, such as the UN Convention against Corruption (D2)

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

Other established or emerging best practices

Internal control procedures have been further enhanced. New monitoring aspects have been introduced for money laundering and tax risk in relation to transactions executed with customers resident for tax purposes in other countries

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

Specific tools for the management and prevention of the risk of corruption have long been in place: the Code of Ethics, the Internal Code of Conduct, the Organisation, Management and Control Model pursuant to National Legislative Decree 231/01

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

Attention to the prevention of corruption risks is very high. The Compliance, Audit and Internal Control Departments ensure ongoing consistency between the control and conduct principles set out by the 231 Model

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

Other established or emerging best practices

Intesa Sanpaolo has identified and is measuring the most significant projects/activities already in progress which are connected with the SDGs, i.g. “Bank the Unbanked” in Egypt for SDG nr. 1, “Loan for the green economy” for SDG nr. 13

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

Other established or emerging best practices

The 2015 Plan of Intesa Sanpaolo Charity Fund confirmed the strategic focus on projects with a significant impact on fragile individuals. The objective is to reinforce a social cohesion model that is also functional to the long-term results of the Group

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

Intesa Sanpaolo has been supporting for years the Food Collection Day with the Banco Alimentare Foundation: in 2015 collected 8,990 tons of food were distributed to more than 8,000 charitable organisations in favor of 1 and a half million people in need

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

Other established or emerging best practices

The Intesa Sanpaolo CEO and Chairmen communicate – through the Social Report’s letter to stakeholders - the Bank commitment to the development of projects and initiatives in support of the principles and the broader goals pursued by the United Nations

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

Other established or emerging best practices

The CEO launched the 2014-2017 Strategic Plan in which the objective to be a Bank for the real economy means increasing integration of sustainability into the core business of the bank

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 on CSR issues have been integrated with the broader business activities over time. Each year, we publish on the website a report on the engagement process, the results of listening and the initiatives implemented

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

Board establishes, where permissible, a committee or assigns an individual board member with responsibility for corporate sustainability.

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

Other established or emerging best practices

The Control and Risk Committees supervise also social and environmental risks. They receive regular reporting by the CSR Unit on the consistence of the Code of Ethics values into the Bank’s activities (assessments by an independent consulting company)