
Environmental Strategy
We orient our choices to prevent and mitigate potential negative environmental impacts, ensuring compatibility between economic initiative and environmental protection. In doing so, we take an active role in creating a more sustainable and responsible future.
Protecting the environment and the local areas as an essential good
We devote great attention to the environment and to the community in which we operate, aware that sustainable development requires a balance between economic growth and social and environmental responsibility. We invest in the enhancement of resources and talents, and in the growth of local areas and communities, promoting excellence and inclusion to generate long-term shared value.

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. 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 2024 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.
With 2024, our 2022–2024 Strategic Plan came to an end. Among its various commitments, it included a specific action for climate protection, structured around the following environmental targets:
- 25% reduction in carbon footprint of direct investments in corporate securities by 2025 (compared to 2019 levels);
- gradual phase-out of coal from all corporate securities investments by 2030;
- achievement of net-zero carbon emissions by 2040.
In continuity with these commitments, in 2024 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 confirm those already set out in the 2022–2024 Strategic Plan and 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.
PERSPECTIVE UOM BASE YEAR (2019) 2024 2030 TARGET 2040 TARGET Focus on Investments Carbon footprint 100% -51% -55% Net Zero tCOeq/€ million 108 53 48 - Coverage 82% 87% Absolute Emissions tCO2eq 684,625 739,948 Focus on Oprational Activities Scope 1&2 100% -29% -40% Net Zero tCO2eq 628 444 377 - 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).GHG Emissions 2019 (baseline) 2021 2022 2023 2024 Scope 1 (A) 413 449 446 433 325 ¹Scope 2 - market based (B) 215 263 188 142 119 ²Scope 2 - location based 850 740 683 643 595 Scope 3 (C) 608 444 449 463 964,243* Total (A+B+C) 1,236 1,155 1,083 1,037 964,687 *2024 includes also Category 15 - Investments ¹The “market-based” approach requires the GHG emissions resulting from the purchase of electricity and heat to be determined considering the specific emission factors communicated by our suppliers. For purchases of electricity from renewable sources, an emission factor of zero is attributed with regard to Scope 2;
²The “location-based” approach, on the other hand, provides accounts for emissions from electricity consumption applying national average emission factors.Scope 3 GHG Emissions (location-based methodology)
Energy
All the electricity we consume comes from renewable sources.
The Milan office, located in the Hadid Generali Tower, is also connected to a district heating network that supplies hot water for heating and sanitary applications.
We also launched BG Smart Energy, a campaign in ten episodes to raise our peoples’ awareness of conscious use of energy resources. A group of employees acted as testimonials of energy saving, providing colleagues with tips on how to pay attention to the topic during their everyday work activities.
2019 Consumption (GJ) 2021 Consumption (GJ) 2022 Consumption (GJ) 2023 Consumption (GJ) 2024 Consumption (GJ) % Change 2024-2023 Electrical power 7,523 6,053 5,838 5,754 5,411.43 -5.96% Natural gas 3,705 4,049 3,361 2,662 1,973.11 -25.87% Heat (district heating) 2,240 3,124 2,178 1,643 1,376.20 -16.24% Diesel oil for engine-generations n.a. 6 7.13 6.84 4.61 -32.60% Water
We consider water to be an important resource and we are committed to using it sparingly in all our offices. Water is used primarily for the purposes of hygiene and sanitation and to supply the heating and air-conditioning systems. Photocells or timer controls have been installed to reduce water consumption to a minimum and allow water flow to be controlled effectively.
Water consumption
2019 Water consumption (m3) 2021 Water consumption (m3) 2022 Water consumption (m3) 2023 Water consumption (m3) 2024 Water consumption (m3) % Change 2024-2023 8,412 3,883 7,083 6,659 6,368 -4.37% Paper
Paper is the material most used in the banking sector. We have adopted a policy of preferring materials with a reduced environmental impact, including lightweight paper, environmentally friendly stationery and remanufactured toner.
To reduce paper consumption, we have introduced the following measures:
- electronic archiving and dematerialisation of documents;
- use of e-mail and messaging in communications between companies, branches, offices of Financial Advisors and customers;
- introduction of Banca Generali Digital Collaboration, whereby Financial Advisors can send their investment proposals to customers, who in turn can review and redefine their investment decisions, with the possibility to confirm the instructions digitally without using paper/ print material;
- activation, for clients who use Home Banking, of the Doc@online function, which can be used for the digital transmission of all communications from the Bank (e.g., account statements, term sheets, accounting documents, information memoranda, etc.).
Paper consumption
2019 Paper consumption (quintals) 2021 Paper consumption (quintals) 2022 Paper consumption (quintals) 2023 Paper consumption (quintals) 2024 Paper consumption (quintals) % Change 2024-2023 267 115 38 53 52 -1.88% Waste
We conducted a number of campaigns to raise awareness amongst our employees and equip all locations with specific containers for paper, plastic, glass and aluminium. We carefully manage the disposal of hazardous waste, such as IT waste and toner, by contracting specialised firms. This waste constitutes a very small part of the total and is handled safely. Durable goods are preferably reused internally or donated to local authorities before recycling
Waste generated
Waste generated in 2019 (quintals) Waste generated in 2021 (quintals) Waste generated in 2022 (quintals) Waste generated in 2023 (quintals) Waste generated in 2024 (quintals) % Change 2024-2023 367 115.33 208.25 297.23 281.76 -5.20% Breakdown of 2024 waste collected (%)
Type of waste collection 2021 breakdown (%) 2022 breakdown (%) 2023 breakdown (%) 2024 breakdown (%) Separate collection 29% 50% 59% 51% Unsorted collection 71% 50% 41% 49%
Operational Activities
The main areas of intervention to improve the Bank's environmental performance include management of workplaces and company mobility.
In particular, the main workplaces are managed to achieve constant improvement in workplace comfort and an efficient use of natural resources and energy.
In Milan the Generali Tower, also known as the “Hadid Tower”, is the result of a major urban redevelopment project launched in 2003, has been designed to meet the highest international environmental sustainability and energy efficiency standards, resulting in the award of LEED Platinum certification, owing in part to the production of renewable energy via a photovoltaic system and the supply of 100% green energy. The Hadid Tower is also equipped with a BEMS-Building Energy Management System, which optimises and constantly monitors energy performance. Moreover, the hybrid way of working “Next Normal” and the closure of offices on working Fridays and around national holiday breaks are actions that ensure a tangible reduction in consumption inside the buildings and limit people’s use of their own vehicles.
The sustainable approach also extends to local logistical developments, a process that involves renovating and fitting out the bank branches and Financial Advisors’ offices. These interventions are guided by a technical specification document that contains information relating to the materials used to carry out the renovation and/or fitting out. A specialised third-party certifies that such interventions have been carried out in accordance with sustainability criteria and with a recyclability index (IRA) as close as possible to 100%, thereby ensuring minimal environmental impact even in the refurbishment of premises.
The management of business travel for administrative staff, as outlined in the Banca Generali Group’s Travel and Business Trip Guidelines, aims to reduce travel through the use of digital tools and online training, promotes the use of public or shared transport, and encourages remote working in line with the 'new ways of working' model.
Investments
We have adopted an approach to investing that focuses on climate change and reducing the carbon emissions associated with our portfolios. See the Responsible Investment section for more details.