Assicurazioni Generali SpA

The identification and prioritization of the relevant ESG factors is carried out by Group Investment Management Solutions (GIMS) / Group Investment Governance and Stewardship in collaboration with Group Communications & Public Affairs – Group Sustainability & Social Responsibility. [...] The Group adopts a specific Governance Framework aiming at: identifying and evaluating Companies presenting ESG controversies and/or involved in above mentioned controversial sector (GIMS/Group Investment Governance and Stewardship); deciding to exclude from the investable universe companies based on the above mentioned exclusion criteria (Restricted List) (GCIO & CEO AWM); deciding to strictly monitor companies presenting some poor ESG practices (as mentioned above) but not to be excluded for the time being (Watch List) (GCIO & CEO AWM); taking decision on existing relevant exposure to Restricted / Watch Listed Companies (GCIO & CEO AWM); providing periodical monitoring and reporting to the relevant Group and Local structures/functions (GIMS/Group Investment Governance and Stewardship); review the overall exposure to sensitive transactions (i.e. exposures in counterparties in ESG lists) (GCRO). [...] A Responsible Investment Committee (RIC) is in charge for supporting the GCIO & CEO AWM in: integrating ESG criteria into the investment decision process; evaluating issuers not aligned with the ESG criteria set out by the Group and taking a decision regarding their possible inclusion in Restricted List or Watch List; discussing and reviewing the results of the monitoring activities of Group exposure to ESG risk from investment and follows up the implementation of GCIO&CEO AWM decisions. [...] The Group commits to dialoguing and collaborating with institutions and national and international associations to promote the diffusion of responsible investments, as well as to take part in working groups to foster knowledge, through studies, research and publications. The activity is steered by Group Communications & Public Affairs supported by GIMS / Investment Governance and Stewardship.

Through the *Group International Public Affairs and Regulatory Advocacy* function, the company advocates directly to **policymakers** and indirectly through **trade associations** for strategies that promote an orderly transition to a low-carbon economy, including balanced policies and projects that: [...] The most relevant activities in this area are monitored and publicly reported through: * our Group Integrated Annual Report; * our Group website; * the rating agencies in which we participate; * the EU Transparency Register. Also through public reporting, we are constantly reviewing our activities with a view to continuous improvement.

- climate governance (accountability of the Board and Senior Management over climate-related matters and goal-oriented KPIs into Executives' remuneration); [...] - climate policy engagement and alignment of Companies lobbying activities to its climate goals.

In execution of obligations set by Net-Zero Alliance, Generali Group committed to engage with 20 carbon-intensive investees within its investment portfolio by 2025. The intent is to ease portfolio decarbonization while influencing issuers' climate change strategy. Our aim is to ask these companies to take substantial steps to reduce greenhouse gas emissions in their organizations' operations, supply chain and products in line with what the latest scientific recommendations ask (e.g. the 2018 IPCC Special Report on Global Warming of 1.5 °C). Our intention is to cover with investee companies the topics highlighted by the Climate Action 100+ initiative, with a particular focus on climate policy, climate-related risks, climate lobbying and just transition. Pursuant to the net-zero commitment, we have proceeded to a thorough review of our investment portfolio with the purpose of identifying issuers with the greatest carbon footprint. Companies to engage are selected among issuers of intensive sectors (utilities, energy, steel, cement, transportation) and prioritized according to their carbon footprint impact in our investments portfolio (highest to lowest, by apportioned emissions) and their level of commitment to decarbonization targets. Investment / ESG analysis and credit research functions are kept informed on the status of ongoing active ownership activities through dedicated reports.

In line with the ambitions of the UN-convened Net-Zero Asset Owner Alliance, in its three-year (2021-2024) strategy "Lifetime Partner 24: Driving Growth", Generali Group has committed to engage with at least 20 carbon-intensive investees whose net greenhouse gas emissions significantly influence its investment portfolio by 2025, to ease portfolio decarbonization while influencing issuers' climate change strategy. Our aim is to ask these companies to take substantial steps to reduce greenhouse gas emissions in their organizations' operations, supply chain and products in line with what the latest scientific recommendations ask (e.g. the 2018 IPCC Special Report on Global Warming of 1.5 °C). Our intention is to cover with investee companies the topics highlighted by the Climate Action 100+ initiative, with a particular focus on climate policy, climate-related risks, climate lobbying and just transition. Pursuant to the net-zero commitment, we have been periodically reviewing our investment portfolio with the purpose of identifying issuers with the greatest carbon footprint. Companies to engage are selected among issuers of intensive sectors (utilities, energy, steel, cement, transportation) and prioritized according to their carbon footprint impact in our investments portfolio (highest to lowest, by apportioned emissions) and their level of commitment to decarbonization targets. [...] So far, we have reached 27 investee companies with formal communications. We are dialoguing with 22 of them directly or through our delegated asset manager (9 individually and 13 collectively with other institutional investors and asset managers) and we are monitoring companies that have not responded to us. For those that did not respond and of which we own equity, as part of our escalation strategy outlined in our voting principles, in 2024 Generali will send formal letters to the investee companies, reserving the right to express disappointment through voting on ordinary agenda topics for the lack of dialogue. According to our voting principles, amended in January 2023, this could be done, e.g. by voting against the discharge of responsibility of the Directors in markets where that is an option, by withholding support for the re-election of responsible members of the Board of Directors, or by opposing to executive remuneration. [...] We actively track the progress of our dialogue with companies within our investment portfolio toward decarbonization, using a comprehensive set of indicators and sub-indicators derived from the Climate Action 100+ Net-Zero Company Benchmark. This benchmark assesses the world's largest corporate greenhouse gas emitters on their progress in the transition to the net-zero future. It is composed of distinct sets of assessments, which draw on unique analytical methodologies and datasets designed to evaluate focus company performance on addressing climate change risks and provide greater insight for investors and companies.

The Group governance is structured in such a way as to favour effective management of the risks and opportunities tied to climate change, which is considered one of the ESG factors most material for the Group, our value chain and the stakeholders. [...] The Board of Directors ensures that the Group organization and management system is complete, functional and effective in monitoring climate change-related impacts. In 2018, it therefore approved the Strategy on Climate Change, updated and further developed yearly since 2020, until the latest version approved in July 2023, outlining a plan for investment, underwriting and stakeholder engagement activities to mitigate climate risks and facilitate the just transition to a low-carbon economy. The Board of Directors also monitors the implementation of this strategy and the results achieved through the Innovation, Social and Environmental Sustainability Committee. In 2023, these elements were analysed during 2 meetings of the Committee. [...] Climate change may have pervasive impacts across the entire organization. For this reason, the decisions on how to integrate the assessment and effective management of climate change impacts into the different business processes are guided by the Group Management Committee. A component of the variable remuneration of the Group CEO and top management depends on the results achieved in the implementation of the Generali Group Strategy on Climate Change. [...] This cross-functional approach is also reflected in a work group that pools together the Chiefs of the functions of Group Investment, Group P&C Retail, Group P&C Corporate & Commercial, Group Life & Health Insurance, Group Integrated Reporting, Group Risk Management, and Group Sustainability. The goal of this work group is to guarantee the management of the risks and opportunities tied to climate change in compliance with the strategy defined by the Board and to ensure the reporting on these aspects both to internal competent bodies and to external stakeholders, in line with the TCFD recommendations.

The Board of Directors ensures that the Group organization and management system is complete, functional and effective in monitoring climate change-related impacts. In 2018, it therefore approved the Group Strategy on Climate Change, which was updated and further developed in March 2020, June 2021 and June 2022, outlining a plan for investment, underwriting and stakeholder engagement activities to mitigate climate risks and facilitate the just transition to a low-carbon economy. The Board of Directors also monitors the implementation of this strategy and the results achieved through the Innovation and Sustainability Committee. In 2022, these elements were analysed during 4 meetings of the Committee. [...] Climate change may have pervasive impacts across the entire organization. For this reason, the decisions on how to integrate the assessment and effective management of climate change impacts into the different business processes are guided by the Sustainability Committee at top management level, which can rely on adequate responsibilities and a cross-functional vision across multiple Groups' functions and geographies. This Committee, sponsored by the Group CEO, consists of the heads of both the GHO functions and business units. The decisions set forth by the Committee are implemented by the competent management, each for its area of responsibility. In December 2022, the Sustainability Committee was incorporated into the responsibilities of the Group Management Committee. A component of the variable remuneration of the Group CEO and top management depends on the results achieved in the implementation of the Strategy on Climate Change. [...] This cross-functional approach is also reflected in a work group that pools together the functions of Group Chief Investment Officer, Group P&C Retail, Group P&C Corporate & Commercial, Group Life & Health, Group Integrated Reporting, Group Risk Management, and Group Sustainability & Social Responsibility. The goal of this work group is to guarantee the management of the risks and opportunities tied to climate change in compliance with the strategy defined by the Board and to ensure the reporting on these aspects both to internal competent bodies and to external stakeholders, in line with the TCFD recommendations.

Describe the process(es) your organization has in place to ensure that your engagement activities are consistent with your overall climate change strategy[…]Education and participation are key to facilitate the transition to low-emission economy. That is why we are actively contributing to the public debate, working to improve understanding of the risks of climate change (CC), to raise awareness of the need for a green transition and to foster the development of systemic responses to CC challenge. We participate in numerous initiatives and working groups on env. issues, with a particular focus on CC.

We are active members of the Investor Leadership Network, a collaborative platform launched in 2018, which brings together leading global investors to accelerate financial industry actions on CC. We are part of the ILN working group which is focused on spreading good practices for the financial risks related to CC as part of the FSB-TCFD.

We have taken part in the Italian National Dialogue on Sustainable Development project sponsored by UNEP, for the preparation of the paper Financing the future on CC mitigation and adaptation through insurance and investment activities. We have organised high-profile institutional events including the presentation in Italy of Interim Report of the European Commission High-Level Expert Group on sustainable finance.

We have also contributed to the analysis of the impact of CC on insurance companies, participating in the drafting of Position Paper "The heat is on† published by CRO Forum. We have also participated in the "Asset Owner Disclosure† project aimed at collecting examples of good practices, including the case of Generali, for the effective management of CC impacts in our sector.

We have participated in important international initiatives, such as
- the TCFD, to promote voluntary financial disclosures on the risks, opportunities and strategies related to CC. We have publicly endorsed and we also participate in the UNEP FI PSI –TCFD Pilot Group to define the guidelines for insurance companies that plan to adopt the recommendations of the TCFD;
- Paris Pledge for Action, to bring together private sector actors willing to implement the Paris Agreement (COP21);
- the Statement of the European Financial Services Round Table (EFR), with which the leading operators in the financial sector pledge to reduce climate-related financial risks and to support customers in the transition to a low-carbon;
- Climate Risk Statement of The Geneva Association, with which the leading insurance companies assume common commitments on the measures to be taken to address and mitigate CC.

Does your organization have a public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement?[…]Yes