Assicurazioni Generali SpA – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Moderate	Generali discloses several elements that indicate a structured though still partial approach to governing climate-related lobbying. It states that "climate policy engagement and alignment of Companies lobbying activities to its climate goals" is part of its overall strategy and that the "Group International Public Affairs and Regulatory Advocacy function" conducts the company’s "direct" advocacy "to policymakers" and "indirectly through trade associations", with "the most relevant activities… monitored and publicly reported through our Group Integrated Annual Report… and the EU Transparency Register", showing a defined mechanism for monitoring and public disclosure. Oversight is anchored at board level: "The Board of Directors ensures that the Group organization and management system is complete, functional and effective in monitoring climate change-related impacts" and "monitors the implementation of this strategy… through the Innovation and Sustainability Committee", which implies senior review of policy engagement consistency with climate objectives. The company also describes a process to keep engagement in line with climate strategy, noting that it "periodically review[s] our investment portfolio" and maintains an escalation framework when dialogue fails, and that its engagement processes are coordinated by cross-functional groups that include Sustainability, Public Affairs and Investment Governance. However, Generali does not disclose a standalone climate-lobbying alignment report, provide detailed criteria or results of assessing trade-association positions, nor evidence of actions such as amending or exiting associations whose positions diverge from its own; the disclosure therefore demonstrates some governance but lacks the comprehensive, publicly evidenced alignment mechanisms expected of a stronger framework. View Sources	C

Overall Assessment

Analysis

Score

Moderate

Generali discloses several elements that indicate a structured though still partial approach to governing climate-related lobbying. It states that "climate policy engagement and alignment of Companies lobbying activities to its climate goals" is part of its overall strategy and that the "Group International Public Affairs and Regulatory Advocacy function" conducts the company’s "direct" advocacy "to policymakers" and "indirectly through trade associations", with "the most relevant activities… monitored and publicly reported through our Group Integrated Annual Report… and the EU Transparency Register", showing a defined mechanism for monitoring and public disclosure. Oversight is anchored at board level: "The Board of Directors ensures that the Group organization and management system is complete, functional and effective in monitoring climate change-related impacts" and "monitors the implementation of this strategy… through the Innovation and Sustainability Committee", which implies senior review of policy engagement consistency with climate objectives. The company also describes a process to keep engagement in line with climate strategy, noting that it "periodically review[s] our investment portfolio" and maintains an escalation framework when dialogue fails, and that its engagement processes are coordinated by cross-functional groups that include Sustainability, Public Affairs and Investment Governance. However, Generali does not disclose a standalone climate-lobbying alignment report, provide detailed criteria or results of assessing trade-association positions, nor evidence of actions such as amending or exiting associations whose positions diverge from its own; the disclosure therefore demonstrates some governance but lacks the comprehensive, publicly evidenced alignment mechanisms expected of a stronger framework.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Comprehensive	Assicurazioni Generali SpA provides comprehensive transparency on its climate policymaking engagements. It explicitly names multiple specific climate policies, including the “2030 climate and energy framework” adopted by the European Council in October 2014 with targets to cut greenhouse gas emissions by at least 55% by 2030, the Corporate Sustainability Due Diligence Directive, the Non-Financial Reporting Directive (2014/95/EU), the EU Taxonomy Regulation (Level I and II) focusing on climate change adaptation across the EU27, and the Corporate Sustainability Reporting Directive. The group also details its lobbying mechanisms and targets, from “one-to-one meetings with representatives of the European Commission, Members of the European Parliament, representatives of national and European supervisory authorities, representatives of national Treasuries” to the issuance and co-signature of position papers, participation in EUROFI meetings in Paris, Prague, and Berlin, and contributing to the public consultation on the revision of the Non-Financial Reporting Directive. Furthermore, Generali clearly articulates the outcomes it seeks, such as transitioning its portfolios to net-zero greenhouse gas emissions by 2050 in line with the 1.5°C goal, advocating for a GHG reduction target of –55% by 2030, enhancing transparency of climate-related disclosures, and supporting coal phase-out strategies. This level of specificity across policies, mechanisms, and objectives demonstrates a comprehensive approach to climate lobbying transparency.	A