Governance is the system through which an organisation makes and implements the decisions to pursue its goals, since it is the implemented choices and activities that can make a significant contribution to sustainable development. The corporate structure therefore constitutes the Company's institutional framework and, according to a Sustainability-based approach, in order for the Company to effectively adopt strategies that respect and enhance the other two factors (Environmental and Social), governance must also be guided by ethical principles in line with ESG and climate-related parameters. [...] With a view to increasingly integrating Sustainability into its business, the Bank has adopted an ESG governance system that provides for the interaction of different bodies devoted to overseeing and managing these issues and their impacts. As provided for by the Business Plan, ESG governance was further strengthened mainly through the creation of the Sustainability Board Committee in May 2023. [...] The Board of Directors (the "BoD"), the Board of Statutory Auditors, the Sustainability Committee and the Control and Risk Committee take climate issues into account when defining the risk management strategy and policies. [...] As part of its strategic oversight responsibilities, the BoD is responsible for defining the guidelines, targets and strategies at the Group level on climate-related and environmental issues, as well as for monitoring actual progress against the defined targets. [...] To ensure the implementation of the C&E risk management policies defined by the BoD, the Managing Director is responsible for the methodological and process framework, as well as the functioning of the systems, models and techniques for identifying, analysing and assessing C&E risks, overseeing their continuous updating. Moreover, the Managing Director monitors the trend of indicators of exposure to C&E risks and their consistency with the risk appetite targets and limits defined. If necessary, he oversees the identification of the actions required to bring the exposure back to suitable levels, verifying compliance with the relevant corporate functions, and he promotes the actions necessary to ensure organisational and internal control structures in line with the exposure to C&E risks. [...] The Sustainability Board Committee, composed of three non-executive directors, of which at least one is independent, plays an investigative, consultative and proactive role in assessing the sustainability factors considered fundamental for the medium-long term strategy and their translation into the Bank's policies. [...] The Committee analyses the Sustainability disclosures prepared by the Bank, in particular the NFS, the TCFD Report and the contribution relating to Sustainability topics contained in the Public Disclosure complying with Pillar 3 regulations, examining the documentation before it is sent to the BoD to take the relevant decisions. Moreover, it also promotes constant discussion with stakeholders on the issues falling under its responsibility and supports the Bank in the dialogue with the Authorities regarding the outcomes of the Supervisory assessments on Sustainability issues and, in particular, on the management of C&E risks. [...] The Control and Risk Committee supports the BoD in carrying out its functions in terms of defining risk objectives and strategies regarding the prevention and governance of risks considered relevant, including ESG-related risks and, specifically, C&E risks, both from a current and forward-looking perspective. [...] The Committee examines the TCFD Report and makes any relevant comments and suggestions; it also supports the BoD in the periodic monitoring of risk exposure, by verifying the completeness, adequacy and functionality of the internal control system. With particular regard to risk containment, it ensures compliance with the limits set by the BoD or required by mandatory regulations. [...] The Sustainability Management Committee periodically examines regulatory changes, standards and national and international practices of reference on climate-related ESG topics, and assesses the proposals in terms of the introduction and amendment of relevant internal regulations and implementation of the guidelines through concrete initiatives, with regard to which it also defines the operational plans, monitoring their actual implementation. It contributes to the coordination of organisational structures and subsidiaries in order to verify compliance with the Sustainability guidelines established by the BoD and implemented in strategic planning as applicable from time to time. [...] The Committee coordinates the activities aimed at identifying climate-related topics that are potentially relevant also in the context of the materiality analysis, and examines the TCFD Report, making any relevant observations and suggestions to the Sustainability Board Committee. Furthermore, it oversights transactions with green debt instruments whose issuance is related to Group activities: in detail, it approves the reference framework and the annual allocation and impact reporting, reviews and validates the set of eligible activities, and finally, it oversees and monitors the management of funds raised. The Committee also coordinates and monitors the dialogue with relevant stakeholders. [...] The Committee Chair is the Chief Financial Officer who has the tasks of informing the Sustainability Board Committee of the outcomes of each meeting by providing minutes and work papers. [...] The Sustainability Office supports and coordinates the central and peripheral organisational structures, as well as the Group's subsidiaries, in understanding and applying ESG-related factors and in the dialogue with the relevant stakeholders. In addition, it offers support for and coordinates the drafting of the Group's guidelines, targets and strategies on Sustainability aspects, with particular reference to the commitments undertaken by the Bank in relation to the decarbonisation targets. [...] It also manages the dialogue with ESG rating agencies, the filling in of questionnaires and the monitoring of ratings at a Group level; in addition, to the extent of its competence, it manages relations with the Supervisory Authorities, in particular supporting the Risk Control Service in relation to C&E risk issues. The Sustainability Office supports the Sustainability Management Committee in identifying initiatives to be implemented, in the operational management in compliance with the Business Plan, and in the periodic monitoring and reporting on initiatives. [...] The Internal Audit Service, as part of its responsibility to verify the correct functioning of the internal control system, verifies compliance with Sustainability policies and the adherence of corporate and Group operations with them; furthermore, it assesses the adequacy and functionality of the ESG risk management process adopted by the Bank, with particular reference to climate-related and environmental risks. It is responsible for reporting to the corporate bodies any inefficiencies, weaknesses or irregularities that emerge during its verification activities, formulating recommendations and bringing possible improvements to their attention. As provided for by the BoD's Action Plan, in 2023 the Internal Audit Service completed an ESG Framework focusing on the Group's regulatory system, organisation and main oversights used to mitigate direct and indirect impacts on the environment and climate, also with the aim of verifying their consistency with respect to the initiatives defined in the Business Plan. [...] The Bank actively participated in the specific Working Groups (so-called WGs) promoted by the Italian Banking Association ("ABI") in particular: - the "Bank, environment and climate change" working group, in which European consultations and emerging regulations are analysed and best practices regarding the issue of climate change are shared; - the "Sustainability" working group, where all the other issues related to ESG topics are addressed such as, for example, Taxonomy. In general, the association promotes knowledge sharing activities within the banking sector, enabling synergies among its actors, including through training courses and other events or activities. As far as environmental aspects are concerned, the Italian Banking Association also supports banks in the dissemination of data, providing indications and clarifications on the issue. In addition, ABI is focused on promoting a harmonised regulatory framework through direct dialogue with the institutions.