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| Overall Assessment |
Comment |
Score |
| Comprehensive |
Intesa Sanpaolo has demonstrated a comprehensive and transparent approach to its climate lobbying activities. The company's disclosures clearly identify multiple specific policies it has engaged with – for example, it explicitly names proposals such as the "Directive on Corporate Sustainability Due Diligence and amending Directive (EU) 2019/1937 Ref. COM/2022/71 final," the Regulation (EU) 2020/852 on Taxonomy, and several initiatives related to the EU Green Bond Standard, EU ETS, and CSRD. In addition, it provides detailed information on its lobbying mechanisms, noting direct engagements such as "participated to several meeting with relevant policy makers" and "replying to public consultations (directly and/or through the relevant associations)," with clear reference to targets like the European Commission and Members of the European Parliament. Furthermore, the company articulates specific desired policy outcomes, including proposals to adjust definitions and advocate for pragmatic solutions in policy frameworks – demonstrating a strong commitment to influence critical aspects of climate-related legislation. This transparent and multi-faceted disclosure offers stakeholders a clear picture of its strategic lobbying efforts and objectives.
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4
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| Overall Assessment |
Comment |
Score |
| Strong |
Intesa Sanpaolo demonstrates a defined governance process to ensure alignment of its climate lobbying activities with its overall climate change strategy. The company states that "through its Chief Institutional Affairs and External Communication Officer (CIAECO), Intesa Sanpaolo regularly monitors the numerous and profound changes in the regulatory framework defined at international, European and national level." This monitoring process ensures that "all the positions expressed by the Group are consistent and in line with the strategy." Furthermore, the CIAECO Area coordinates responses to public consultations on climate issues, involving relevant functions of the Group in a drafting procedure that includes up to four subsequent drafts before finalizing the position. This indicates a structured approach to managing climate lobbying alignment. Additionally, the Steering Committee, composed of the first organizational line, meets quarterly to examine climate change issues, including new regulations, further reinforcing oversight and accountability. The evidence also highlights indirect lobbying efforts, as Intesa Sanpaolo engages in drafting papers and proposing amendments both directly and "through the relevant trade associations." These processes collectively reflect strong governance mechanisms for climate lobbying alignment.
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3
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