Code of Ethics implementation and governance - Intesa Sanpaolo
Implementation and governance
Intesa Sanpaolo has adopted an implementation and governance system aimed at promoting the integration of company strategies, policies and procedures with the principles and values stated in the Code of Ethics, through an uttermost sharing and diffusion of its contents.
The model from which the Intesa Sanpaolo Group draws inspiration is based on the self-responsibility of departments that pursue and defend the reputational value of socially responsible behaviour. Each company department develops its actions and activities being inspired by the principles and values of the Code of Ethics. Every department is therefore directly responsible, within its own sphere of influence, for determining and formalising the goals, as well as the consequent plan of actions and projects.
Within each department and Subsidiary Bank, Corporate Social Responsibility (CSR) Delegates are appointed who, operating within their department and in network, cooperate with the Corporate Social Responsibility sub-department by identifying the social responsibility objectives within their own structure, managing, monitoring, and periodically reporting on the projects in progress and maintaining relations with the reference stakeholders.
Corporate Social Responsibility
on the one hand, monitors the effectiveness of dissemination and information through tools identified each time starting from internal assessments focused on measuring knowledge and awareness highlighting areas of weakness and possible intervention; on the other hand, in case of sensitive ethical and reputational areas provides and shares company's policies and guidelines;
supports and advises departments within the company;
in agreement with the responsible functions identifies and reports specific indicators to assess the level of achievement of social and environmental goals compared to the commitments undertaken;
cooperates with the Human Resources Department in the development and diffusion of the culture and values contained in the Code of Ethics;
monitors, with the support of the Internal Auditing Department, the compliance with the principles and values contained in this Code of Ethics, reporting annually to the Management Control Committee and to the Supervisory Body in accordance with Legislative Decree 23/2001;
proposes the appropriate changes to make the Code consistent with the current company’s situation
The implementation process of the Code of Ethics – integrated with the management processes underlying the Sustainability Report – envisages an evaluation and a third-party assessment in accordance with the principles and contents of the ISO 26000 standard. The statement on the CSR governance level in the Intesa Sanpaolo Group describes the method applied and the results, with separate assessment of respect for human rights.
Assurance Statement over the governance on Corporate Social Responsibility - May 2017
Audit interventions to verify the implementation of environmental and social policies
In 2016 the Parent Company Internal Audit Department, in conducting the monitoring activity on the compliance with the principles and values contained in the Code of Ethics, carried out the following activities:
analysis of personnel remuneration and incentive systems;
internal policies for Banca dei Territori human capital enhancement and development (management and technical training);
analysis of the second-level checks on the risks to employees' health and safety;
check on the compliance with regulations concerning employee personal transactions.
Whilst conducting ordinary audits on the credit process, the Internal Audit Department also conducted checks on the compliance with corporate rules on arms and environmental policy and an ongoing monitoring on the compliance with the rules laid down by the Internal Code of Conduct through the performance of "investigation" activities on potentially abnormal situations.
Eventually, process audits were activated - among others - regarding the management and monitoring of Fondo di Beneficenza e opere di carattere sociale e culturale (Charity Fund); expenditures for consultancy, representation and advertising of Banca Prossima; selling of diamonds for investment to Banca dei Territori Personal customers and the proactive credit management.