Environmental Strategy

In order to strengthen our framework for managing environmental impacts, in June 2024 environmental and climate-related principles were integrated into the Sustainability Policy. These principles are consistent with the Bank’s environmental commitments undertaken by signing the UN Global Compact and are aligned with the United Nations Sustainable Development Goals (SDGs). In particular, we are committed to a sound and thorough management of our operational activities with respect to the environment, as well as to promoting environmental responsibility among various stakeholders, such as employees, Financial Advisors, customers and suppliers.

With regard to mobility, we prioritise the use of public transport over private cars, especially the least polluting means, as outlined in our Guidelines on Business Trips and Travel.

We also pay close attention to environmental protection within procurement processes, as stated in the Generali Group’s Supplier Code of Ethics, adopted by Banca Generali’s Board of Directors, as well as in our Sustainability Policy.

With regard to investments, with the aim of promoting and supporting the transition through the integration of ESG criteria into investment policies and within the offering of products and services, in July 2024 we adopted the Guidelines on Integrating Sustainability Factors into Investment Services, Collective Asset Management and Active Ownership, which is periodically updated. In this context, the Bank uses an ESG score, which takes into account, inter alia, the environmental performance of financial instruments in terms of climate change mitigation and adaptation. We also follow an active ownership approach to investments (so-called Active Ownership), exercising our voting rights and participating in corporate and industry initiatives in favour of a low-carbon transition.

Active Ownership also plays a crucial role within the Climate Transition Plan itself, which identified engagement activities as one of the main levers for decarbonisation, with a particular focus on climate change mitigation. The first engagement and voting activities carried out in 2024 in support of the transition were reported in the dedicated 2025 Active Ownership Report.

Our commitment is also directed towards mitigating the principal adverse impacts (so-called PAI) of investment decisions on sustainability factors, including indicators linked to GHG emissions.

The analysis of ESG factors is also integrated into the corporate lending process through a due diligence procedure that assesses both the relevant operating sector and its exposure to the overall ESG risk, with a focus on companies’ physical and transition risk. Finally, in recent years, we have embarked upon a path of gradual integration of ESG factors into its risk framework, focusing on climate-related risks.

In continuity with our 2022-2024 Strategic Plancommitments, in 2025 we adopted a Transition Plan for climate change mitigation, identifying specific decarbonisation levers and setting intermediate targets for 2030 and long-term goals for 2040.

To support this Plan and further strengthen our commitment to climate change, we have defined a series of decarbonisation levers. These include: the ongoing consolidation of internal regulations, the development of sustainability-oriented products and services, and the enhancement of the monitoring infrastructure to improve ESG data quality. Moreover, we actively engage with companies and suppliers through engagement activities, provide training to our people on environmental matters, and adopt technologies to reduce consumption and emissions.

The Transition Plan targets are structured separately for the Investments segment and for Operational Activities:

Investments
With regard to Investments, which represent the main source of emissions, the perimeter of the identified objectives refers to the financial assets on which the Bank has direct control, including corporate issuers (equities and bonds) within the Proprietary Portfolio, Discretionary Mandates and Funds of BGFML. We aim to reduce the carbon footprint of investments – measured as Scope 1 and 2 emissions per million euros invested – by 55% by 2030 compared to 2019 levels, with the aim of reaching Net Zero by 2040. We have also confirmed our commitment to complete the phase-out from coal by 2030 for the same scope. 

In order to gradually achieve the coal phase-out target, we have introduced restrictions on investments in carbon-intensive companies, Oil & Gas companies that use unconventional extraction methods. We plan strengthen our monitoring actions with respect to issuers with less exposure to coal through the implementation of a growing data infrastructure.

Operational activities
With regard to Operational Activities, which are a residual source of emissions, we have set a target to reduce Scope 1 and 2 emissions by 40% by 2030.

Among the actions to support the achievement of the target, we have included the gradual exclusion of fossil-fuel company cars, the green retrofitting of the Trieste headquarters, the confirmation of the hybrid way of working and the closure of offices on Fridays.

For the calculation of our carbon footprint, we use data supplied by a certified information provider.

In line with the Corporate Sustainability Reporting Directive (CSRD), we regularly measure and report Scope 1, 2, and 3 GHG emissions related to the Bank’s main sites, included in the Generali Group’s Environmental Management System. These buildings, which are under the Bank’s financial and operational control, are located in Milan (Generali Tower – Hadid) and Trieste (Corso Cavour 5/a), and serve as the primary workplace for the majority of employees, covering 73% of the Banking Group’s workforce.

In line with the principles of ecological transition and our commitment to tackling climate change, we monitor our investment portfolio and report absolute GHG emissions related to Corporate and Government investments (Scope 3 – Category 15).

Scope 1
Scope 1 emissions include direct emissions from sources that are directly owned or controlled by Banca Generali. This category includes emissions generated from heating and refrigerant gases of owned operating sites, and those due to fuel for owned company vehicles.

Scope 2
Scope 2 emissions include indirect emissions from purchased energy, such as electricity and district heating.

Scope 3
Scope 3 emissions include all other indirect emissions that occur in the Bank’s value chain, both upstream and downstream. The emission categories analysed by the Banking Group include the emissions generated by the investment component (the key emission category of financial institutions – Category 15), by activities linked to fuel and energy not included in Scopes 1 and 2 (Category 3), by business travelling (train, airplane and company fleet vehicles – Category 6), by paper use and water consumption (Category 1) and by waste disposal (Category 5).