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 function 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 - January 2018
Audit interventions to verify the implementation of the Code of Ethics
Compliance with the principles and values of the Code of Ethics was monitored with the support of the current Chief Audit Officer (former Internal Auditing Department), so that it could be reported annually to the Management Control Committee and the Surveillance Body pursuant to Legislative Decree 231/2001. Audits were conducted that also considered social and environmental responsibility aspects and implications including:
transactions with Related Parties and associated entities;
research and Development Special Fund financing and management of the Fund for the development of social business (Banca Prossima);
migrant Assistance Sistema di Protezione per Richiedenti Asilo e Rifugiati (SPRAR) (protection system for asylum seekers and refugees) (Banca Prossima);
money transfer operations (focus on several Regional Governance Centres: Piedmont, Valle d’Aosta and Liguria; Milan and Province);
management of purchasing procedures, centralised or for specific companies and activities, and significant outsourced processes of important operational functions.
The audits did not identify any breaches or critical issues.
In 2017, the current Chief Audit Officer (former Internal Auditing Department) carried out audits directly or indirectly aimed at verifying compliance with internal regulations and in relation to anti-money laundering and embargoes and, more generally, on various areas/processes of the Bank, some of which were particularly important because of their sensitivity in relation to 231/2001 legislation. It also verified the adequacy of the Integrated Internal Control System in these areas. A total of 267 audits were carried out, 10 of which directly or indirectly concerned aspects related to social and environmental policies. In particular, in 2017the new Risk Models were activated, which ensure a risk-based assessment approach across the company Structures.