FinecoBank Banca Fineco SpA

The board-level Corporate Governance and Environmental and Social Sustainability Committee oversees Sustainability issues related to FinecoBank's business operations and the dynamics of interaction with all Stakeholders, as well as the evolution of the Bank's Sustainability strategy, based on the relevant international guidelines and principles. Specifically, it oversees the evolution of the Group's Sustainability strategy, assesses the risks related to Sustainability issues, examines and, where appropriate, formulates proposals regarding corporate plans, objectives, rules and procedures on social and environmental issues, also playing a support role to the Board of Directors for the approval of policies aimed at promoting diversity and inclusiveness, contributes to the review of products with ESG purposes for which the Bank acts as producer, monitors the positioning of the Company and the Group with respect to the financial markets on Sustainability issues and Stakeholder relations, and examines and advises on the policy for managing relations with all the Shareholders. It also reviews in advance the Consolidated Non-Financial Statement (NFS) and the Environmental Statement pursuant to EMAS Regulation No. 1221/2009/EC for approval by the Board of Directors. Finally, the Committee has specific tasks with reference to corporate governance issues[4]. [...] In order to support the Corporate Governance and Environmental and Social Sustainability Committee, a Sustainability Management Committee is established, supported by the Sustainability Structure and composed of FinecoBank managers. The Committee is entrusted with the main task of defining a proposal for the Bank's Sustainability strategy (corporate plans, rules and procedures on social and environmental issues) and the related objectives to be achieved, to be submitted to the aforementioned board-level Committee for consideration, as well as to the Board of Directors for approval, if necessary. The Management Committee is also in charge of monitoring the progress of the defined Sustainability strategy. [...] The Sustainability Structure, reporting to the Chief Financial Officer (CFO) Department, is responsible for supporting the CFO and the Sustainability Management Committee in the management of Sustainability at Fineco, including the development and monitoring of the Sustainability Strategy and in the drafting and subsequent approval of the NFS and EMAS Environmental Statement by the relevant Corporate Bodies.

The Corporate Governance and Environmental and Social Sustainability Board-level Committee, established in 2020 with exclusive responsibility for sustainability matters, oversees FinecoBank's business operations and the interactions with all its stakeholders in relation to sustainability, providing support to the Board of Directors. Specifically, it oversees the evolution of the Group's sustainability strategy, assesses sustainability-related risks, and examines and, where necessary, draws up proposals concerning plans, objectives, rules and corporate procedures on social and environmental issues. It also provides support to the Board of Directors for the approval of policies aimed at promoting diversity and inclusiveness, in addition to monitoring the positioning of the Company and the Group with the financial markets in relation to sustainability and stakeholder relations, reviewing and issuing opinions on the policy for managing dialogue with shareholders in general, and reviewing the Non-Financial Statement (NFS) and the environmental statement pursuant to the EMAS Regulation no. 1221/2009 prior to their submission to the Board of Directors for approval. Finally, the Committee has been assigned specific duties in relation to corporate governance[7]. In support of the Corporate Governance and Environmental and Social Sustainability Committee, a Sustainability Management Committee has also been in place since 2019, comprised of FinecoBank managers. The Committee has the main task of drawing up a proposal for the Bank's sustainability strategy (company plans, rules and procedures in relation to social and environmental issues) and the related objectives to be achieved, to be examined by the Corporate Governance and Environmental and Social Sustainability Committee and where necessary approved by the Board of Directors. Lastly, since July 2019, Fineco has had a Sustainability Office, a technical unit reporting to the Chief Financial Officer (CFO), tasked with supporting the CFO and the Sustainability Management Committee in managing sustainability within Fineco, including the development and monitoring of the ESG strategy (corporate plans, rules and procedures on social and environmental issues) and in the drafting and subsequent approval of the Consolidated Non-Financial Statement by the competent Corporate Bodies. The major change in 2021 was the updating of the compliance model for sustainability issues. Specifically, the regulations in this area have been classified into three macro-areas corresponding to non-financial reporting, other sustainability obligations and environmental protection. On the basis of the regulatory framework identified, one or more units have been selected for each macro-area responsible for carrying out compliance monitoring: |MACRO-AREA|CORPORATE UNIT DESIGNATED FOR ENSURING COMPLIANCE| |---|---| |Non-financial disclosure|Sustainability Office| |Other sustainability-related obligations|Chief Risk Officer Department, for ESG risk management regula­ tions| |Compliance Department, for regulations on investment services, credit, remuneration and incentive schemes| |Environmental protection|Chief People Officer Department, for the regulations on mobility management| |Real Estate Unit, for the regulations on responsible consumption, waste disposal and pollution reduction at buildings used by the Bank and by the personal financial advisors| |Chief Financial Officer, as Management Representative pursuant to the EMAS Regulation, and Sustainability Office reporting to the CFO, for the Environmental Management System regulation.| Each of the designated units is therefore responsible for overseeing and monitoring external regulations, analysing new requirements and identifying actions to be implemented with the engagement of the units concerned, defining and carrying out level 2 controls and identifying any improvement actions where necessary, and lastly producing the appropriate periodic information reports on the level 2 controls for the Compliance Department, which reports in turn to the corporate bodies. The Sustainability Office has also been assigned a broader coordination role in this area.

Describe the process(es) your organization has in place to ensure that your engagement activities are consistent with your overall climate change strategy[…]Engagement activities with both clients and Personal Financial Advisors are fully integrated in our Sustainability strategy, which includes climate-related goals. Therefore there activities are designed to reach these goals and to be consistent with the strategy.
In addition, we engage indirectly with trade association (ABI, the Italian Banking Association) by contributing to public consultation processes on climate-related regulations.

Describe the process(es) your organization has in place to ensure that your external engagement activities are consistent with your climate commitments and/or climate transition plan?[…]Engagement activities with both clients and Personal Financial Advisors are fully integrated in our Sustainability Strategy, which includes climate-related goals. Therefore these activities are designed to reach these goals and to be consistent with the Strategy.

Does your organization have a public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement?[…]No, and we do not plan to have one in the next two years