Sustainable governance
We integrate ESG principles into our strategic processes and decision-making system through a structured and dedicated governance framework.
Our sustainable approach
The Bank and its people are focused on protecting households’ wealth with integrity, passion and dedication, with an emphasis on medium-long term objectives. Pursuing a sustainable growth path requires vision, which means taking on social responsibility and understanding and anticipating future, including those related to innovation and the management of generational wealth transfer. For this reason, we focus on future generations, who bring new needs in terms of innovative offerings and digitalization, and we are committed to supporting the entrepreneurial world, where generational transition represents a moment of discontinuity that requires an integrated approach and a strategic partner.
A new way to invest
With the aim of promoting the sustainable development of our business activities and generating long-term value, we have adopted the Sustainability Policy at Banking Group level.
The Policy defines the Sustainability Framework so as to identify, assess and manage the risks and opportunities associated with ESG factors, in line with the evolution of the industry’s ESG regulations and illustrates the key enablers of sustainability, including the governance model, internal regulation, risk framework, remuneration, monitoring and reporting.
The Policy also reflects the commitments we have undertaken through our signatory status to the Principles for Responsible Investment (UN PRI) and the United Nations Global Compact (UNGC).
Internal Code of Conduct
In pursuing its growth objectives, we remain faithful to the fundamental principles that characterize its ethics, such as transparency, fairness and impartiality. These principles are reiterated in the our Internal Code of Conduct, which is in line with the rules of conduct reported in the Generali Group’s Code of Conduct.
The Internal Code of Conduct defines the minimum rules of conduct to be observed in dealings between colleagues, as well as with customers, competitors, suppliers and the Group’s other stakeholders and contains specific provisions governing the promotion of diversity and inclusion, protection of company assets, conflicts of interest, bribery, financial information and the processing of insider information, the prevention of money laundering, financing for terrorism and international sanctions.
Whistleblowing and AML/CTF/IS Policy
To monitor compliance with the Internal Code of Conduct and in accordance with the applicable legal framework, we have adopted a whistleblowing procedure that makes it possible to collect, assess and manage reports of potential fraudulent phenomena, violations of internal rules and suspect behaviour. The procedure guarantees protection from all forms of retaliation, discrimination or penalisation and ensures them the utmost confidentiality, without prejudice to legal obligations.
In addition, with the aim of combating money-laundering and the financing of terrorism, which constitute a serious threat for the legal economy and can result in destabilising effects, above all for the banking and financial system, we have adopted an Anti-Money Laundering, Counter-Terrorist Financing, and International Sanction Policy(AML/CTF/IS Policy). The Policy, approved by the Board of Directors, is part of the broader internal control system of our Bank, aimed at ensuring compliance with applicable laws and regulations.
Adhesion to UN Global Compact
At the beginning of 2024, at Banca Generali we have also joined the UN Global Compact, a voluntary initiative launched by the United Nations to encourage businesses the world over to define an economic, social and environmental framework aimed at promoting a sound and sustainable global economy from which everyone can benefit. To this end, as a participant, Banca Generali is committed to share, support and apply within its sphere of influence the ten fundamental principles regarding human rights, labour standards, environmental protection and fight against corruption.
The double materiality analysis is a tool for strategic reading of the Bank’s internal and external context aimed at identifying and determining the priorities of, environmental, social and governance aspects deemed material and significant across our value chain. This analysis is conducted from a dual perspective: identifying the actual or potential impacts of our business activities on people and the environment (inside-out approach), as well as the sustainability-related risks and opportunities (outside-in approach) that may influence the Bank’s financial performance and results, thereby creating or eroding corporate value in the short, medium, or long term.
The double materiality assessment process begins with the definition of the company’s value chain, which for us of Banca Generali is structured to maximize operational efficiency, foster continuous innovation, and offer a wide range of high-quality services to clients, fully reflecting our Mission and Vision. Our value chain is composed of two main segments: Operational Activities, which include both the supply chain (Upstream) and the Bank’s Core operations, and Business activities, which refer to the provision of high-quality services and holistic advisory.
In line with regulatory requirements, we considered a topic to be ‘material’ if it was found to be relevant from at least one of the two perspectives (inside-out and/or outside-in). As a result, we identified 9 material topics: 2 environmental, 4 social, and 3 governance-related. The outcome of the double materiality analysis was shared with the Sustainability and Innovation Committee (CSI) and the Board of Statutory Auditors, and was subsequently validated and approved by the Board of Directors on November 5, 2025. The table below provides a detailed overview of the analysis.
The results of the double materiality analysis highlight how, within our business model—centered on a holistic advisory approach aimed at supporting clients in the management and protection of their overall wealth—transparency and accuracy in communicating the characteristics of our services and products are of fundamental importance.
By placing client needs and preferences at the heart of our strategy, and by focusing on enhancing the value of our services, we have further strengthened our commitment to sustainable and responsible investment. We have also reaffirmed our dedication to promoting and supporting the transition to a low-emission economy, recognizing the significance of climate change.
We have implemented specific safeguards to protect our clients’ personal data, ensuring data protection and cybersecurity, and we are continuously committed to adopting good governance practices, particularly in the areas of anti-bribery and corruption, and whistleblowing.
Finally, at Banca Generali, we place great importance on the enhancement and recognition of human capital, which is reflected in our concrete focus on working conditions and on Diversity, Equity & Inclusion (DE&I) within our workforce.For further information please see Annual Integrated Report 2025
In Banca Generali we liaise with numerous stakeholders, each with different requirements and expectations. We recognise as stakeholders all those parties (Institutions, Organisations, groups or individuals) who can influence or be influenced by our activities. To identify stakeholders of priority interest we use the following criteria: responsibility, influence, proximity, representation and strategy.
Overall, stakeholder listening and dialogue activities are carried out mainly in order to:- understand the needs and expectations of stakeholders of priority interest in the medium to long term to support strategic planning;
- anticipate risks of a different nature (operational, reputational, etc.);
- monitor the level of satisfaction and check the extent to which the different stakeholder categories have a positive perception of their relationship with the Bank;
- seize new opportunities through the joint identification of solutions capable of creating shared value for the Organisation and its stakeholders.
Our awareness of the central role played by our stakeholders in the process of a sustainable growth has led us to initiate forms of active dialogue and discussion. Our main stakeholders include:
- Employees of the Banca Generali Group;
- Our network of Financial Advisors;
- National, international, and financial sector institutions (including companies, trade associations, and the third sector);
- Shareholders;
- Supervisory authorities and rating agencies;
- Customers;
- Suppliers;
- Financial and non-financial strategic partners.;
- Communities.
Transparent Communication is a fundamental aspect for us, and in this context, we prepare detailed reports and regular updates on sustainability issues, particularly for the administration, management, and control bodies. This approach allows us not only to ensure that stakeholders' opinions are heard and considered but also to promote a culture of responsibility and collaboration within the organization.
There are also specific sharing activities with shareholders and authorities in case of discussions/requests, defined by the Shareholder Dialogue Policy. Finally, we regularly collect our employees' opinions through surveys, the main results of which are shared and analysed with senior management.
At Banca Generali, sustainability is an unquestionable strategic orientation supported by a strong internal commitment.
In this regard, within the “Rules Regulating the Proceedings of Meetings of Board of Directors and of Internal Committees”, as approved on 11 May 2021 and last updated on 9 May 2024, Banca Generali decided to foster sustainability in all its Board Committees; moreover Banca Generali’s Internal Regulation and Banca Generali’s Group Regulation also foresee certain responsibilities in the area of sustainable governance in the hands of Managing and Risk Committees
The integration of sustainability in the aforementioned committees is briefly described below.
Internal Committees
- Managing Committee
The Managing Committee is an advisory body set up to assist the company’s top management by subjecting the Bank’s most significant strategic and managerial aspects to in-depth assessment, as a panel. It consists of the CEO, the two Deputy General Managers and top managers. It is in charge of examining, on a half-yearly basis, all matters related to the Banking Group’s social, environmental and sustainability responsibility.In this context, the Committee defines sustainability-related opportunities, risks, common objectives, targets, areas for improvement, content and reporting methods, and analyses the results set out in the Annual Integrated Report, discussing the achievement of the targets set, the difficulties faced and the problems still to be solved.
Risk Committee
The Risk Committee is the corporate body in charge of ensuring a coordinated supervision of the management and control system of the risks assumed by the Banca Generali’s Group, with reference to the Risk Appetite Framework. In this context, the Risk Committee has specific tasks and responsibilities in monitoring the risks assumed by the Banca Generali’s Group, including risks and profiles connected to ESG (Environmental, Social and Governance) factors.
Board Committees
- Sustainability and Innovation Committee
The Sustainability and Innovation Committee, established in April 2024 in line with market best practices and the interests of various stakeholders, has investigative, advisory and propositional functions, in support of the Board of Directors, on sustainability and innovation. In particular, in the area of sustainability, the Committee supports the Board in the integration of sustainability in the definition of business strategies, as well as in the definition of the materiality matrix and monitors ESG issues, including, in the social and environmental area: climate change, diversity, equity and inclusion, and health and safety in the workplace.
- Nomination and Governance Committee
The Committee is responsible for advising and making recommendations to the Board of Directors on nominations and governance. In exercising its functions, the Committee must take into account that the members of the Bank's Board of Directors express a balanced composition of experience and theoretical and/or technical knowledge of managerial and/or entrepreneurial management, including in the ESG area.
- Internal Audit and Risk Committee
The Internal Audit and Risk Committee performs supporting functions for the body with strategic supervision functions with regard to risks and the internal control system. It also ensures that the risks and profiles connected to ESG factors are thoroughly assessed in order to foster the Sustainable Success of the Company and Banking Group.
- Remuneration Committee
The Remuneration Committee is responsible for advising and making recommendations on remuneration to the Board of Directors. It formulates proposals regarding plans, targets, rules and company procedures relating to social and environmental issues and, more generally, sustainability, in line with applicable laws and regulations.
- Credit Committee
The Credit Committee performs preliminary, consultative and propositional functions in support of the Board of Directors regarding loans, particularly the evaluation of loan applications. In supporting the Board of Directors to the extent of its remittance, the Committee ensures that the Board may adopt all appropriate lending resolutions in accordance with an assessment of the risks underlying the loans that also take account of the risks connected to environmental, social and governance (ESG) factors.
Management
All the competences regarding sustainability are attributed to the General Counsel & Sustainability, within which the Banking Group Sustainability Service was established, with the task of coordinating the structures of the banking group on strategic sustainability projects.