Sustainability Documents

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Sustainability Documents

Sustainability Policy	It aims to define the strategic principles of the Banking Group in the field of sustainability by defining the Sustainability Framework in order to identify, assess and manage risks and opportunities related to ESG factors.
Charter of Sustainability Commitments	It defines the long-term strategic goals for doing business responsibly and living in the community, helping to create a healthy, resilient and sustainable society.
Rules Regulating the Proceedings of Meetings of the Board of Directors and of Board Committees	They describe in detail the functioning of the corporate bodies, particularly focusing on the Nomination, Governance and Sustainability Committee, which oversees the Group’s capacity to create long-lasting value.
Diversity Policy for Members of Company Bodies	It lays down the criteria for promoting diversity in terms of various aspects, such as gender, age, position, skills, educational background and professional profile within the organisation, starting with the composition of its company bodies.
Policy for Managing Engagement with All Shareholders	Banca Generali is committed to managing dialogue with all its shareholders through fair, transparent and differentiated forms of engagement, in the belief that establishing and maintaining a constant and ongoing relationship with all major stakeholders is in its own specific interest, as well as a duty towards the market. To this end the Bank's Board of Directors approved this policy for the management of the aforementioned activities in line with the legal, regulatory and self-regulatory requirements in force.
Rules of the Board of Statutory Auditors	These Rules have been adopted by the Company’s Board of Statutory Auditors to bring the policies, rules, and procedures governing the functioning of corporate governance relating to the aforementioned body into compliance with the law and Articles of Association, as well as with the principles of the Supervisory Regulations. The Rules are also intended to ensure that the corporate governance rules applicable to the said body conform to the principles laid down in the Corporate Governance Code.

Internal Code of Conduct	It establishes the rules of conduct for those who work or act on behalf of Banca Generali to ensure conduct in accordance with the highest standards of business integrity with regard to the OECD Guidelines for Multinational Enterprises and Corporate Governance Principles, UN and ILO conventions for the universal protection of human and workers' rights and the UN Global Compact.
Ethical Code for Suppliers of the Generali Group	It delineates the principles of behaviour and conduct expected of contractual partners offering services or products to Banca Generali, with regard in particular to compliance with the principles of ethics, propriety, fairness and transparency, as well as compliance with the laws on data protection, worker protection and environmental protection.
Whistleblowing Procedure	It lays down the principles, methods and control measures adopted to manage reports of laws and company regulations, ensuring the identity of whistleblowers remains confidential and that they are protected against retaliation.
Organisational and Management Model	It sets out the system for identifying and mitigating the risks that members of the company bodies and those who work or act on behalf of the Bank may commit the offences identified in Legislative Decree No. 231 of 2001 in the interest of the organisation, including offences against the public administration, tax offences, occupational health and safety offences and environmental offences.
Policy for Managing Money-Laundering and Terrorist Financing Risks	It formulates the roles, responsibilities, processes and internal control systems that prevent the risk of money-laundering and terrorist financing in the conduct of the activity.
Wolfsberg Group Correspondent Banking Due Diligence Questionnaire	It details the characteristics of the system and procedures adopted to prevent money-laundering and terrorist financing in the conduct of the Group's activities on the basis of the questionnaire prepared by the Wolfsberg Group.
Policies on connected party transactions	They establish the system for identifying and mitigating the risks that the proximity of certain individuals to the Bank's decision-making centres may jeopardise the objectivity and impartiality of decisions regarding the granting of loans and other transactions potentially detrimental to depositors and shareholders.
Tax Strategy	It describes the tax strategy as an essential element of the Tax Control Framework (TCF), defining how the tax variable is managed in a safe and prudent way.
Anti-Bribery & Corruption Policy	It defines Banca Generali Group’s ABC risk management framework and sets forth the Group’s ABC Standards and the requirements applicable to its Subsidiaries.

Guidelines on Integrating Sustainability Factors into Investment Services, Collective Management, and Active Ownership	It defines how the Banking Group integrates consideration of ESG factors into Investment Services, Collective Management and Active Ownership
Conflicts of Interest Management Policy	It sets out the system protecting clients' interests in the provision of investment services and activities, and additional services.
Remuneration Policy and Report	It illustrates the pillars of the policy and mechanisms of operation of the structure of the incentive system for the Banking Group's key personnel, focusing on the alignment of performance objectives and indicators with strategic targets, including ESG objectives.
Personal Data Protection Policy	It lays down the key principles and fundamental requirements of reference in processing the personal data of clients, personnel and other relevant stakeholders in accordance with the European General Data Protection Regulation.
Security Policy	It describes the objectives, basic principles and main responsibilities regarding security protection at Banca Generali, including cybersecurity and the protection of the Group's operating continuity.

Annual Integrated Report	It describes Banca Generali Group's sustainability performance according to the integrated reporting framework issued by the International Integrated Reporting Council and a set of indicators selected by the GRI Sustainability Reporting Standard.
Independent Auditors’ Report on the Consolidated Non-Financial Statement	It certifies the results of the limited assurance on the ESG performance conducted by the auditing firm according to the ISAE 3000 Revised standard and included in the Non-financial Statement.
Investor presentation on ESG	Summary of Banca Generali's sustainability model, strategies and performance.
Corporate Governance Report	It highlights Banca Generali’s degree of compliance with the principles and application criteria established by the Corporate Governance Code of Borsa Italiana and international best practices.
Country by Country Report	It details the nature of the activity performed and, separately for each country, the amount of turnover generated, profits earned, taxes paid, number of employees and amount of public funding received.
Tax Transparency Report	The tax transparency report details tax strategy and principles; tax risk governance, management and control system; relationship with the tax authority and stakeholders; and finally tax reporting.
Pillar 3 Public Disclosure	Within the framework of the banking regulatory system governed by the Basel Accords (Basel 3), Pillar 3 represents the “disclosure requirements” that complement the regulatory capital requirement (Pillar 1) and supervisory review process (Pillar 2). It provides an overview of the risks assumed, the characteristics of the related systems aimed at identifying, measuring and managing the said risks and the capital adequacy of the Banca Generali Group.