Governance

To learn more about our policies you can contact us at:
ESG@iccrea.bcc.it

The BCC Iccrea Group sees sustainability as an opportunity to reaffirm the principles and values of credit cooperation by highlighting the attention that BCCs dedicate to their local communities, people and economies, respecting the environment and pursuing Article 2 of the BCC Articles of Association.

The governance of sustainability

The Group has a system of sustainability governance – understood as the integration of the three ESG (Environmental, Social and Governance) factors in its governance, strategies and operational and control processes – which rests on precise centres of responsibility. This system fosters the involvement of corporate bodies and business areas, taking into primary consideration the objective of creating and distributing value for stakeholders.

The Board of Directors defines the Group's sustainability guidelines and strategies, paying particular attention to the objectives of sustainable finance and the integration of environmental, social and governance factors into corporate decision-making processes. It is responsible for integrating ESG-related objectives into the business plan, operational processes, risk management and remuneration policies.

Thus, the Sustainability Plan, the Policies and the Group's guidelines relating to sustainability are approved by the Board of Directors, subject to review by the ESG Committee and the other internal board committees for the matters within their purviews.

Moreover, the Board of Directors evaluates and approves the Consolidated Non-Financial Statement (CNFS) cwhich highlights the company's sustainability goals, also as a result of the stakeholder engagement process and the identification of the so-called “material topics”.

The actions of the Board of Directors are therefore focused on strategy, on regulatory compliance and risk management, as well as on the ongoing and thorough drive for guidance and oversight in these areas, with the aim of launching initiatives that, in line with the historic support provided to local communities by the Cooperative Credit Banks, can facilitate and promote a sustainable transition.

The ESG Committee

The ESG Committee has a propositional and advisory function vis-à-vis the Board of Directors with respect to evaluations and decisions related to issues concerning sustainability and cooperative identity.

Overall, the ESG Committee deals with the following areas::

Definition and monitoring of ESG strategies and subsequent sustainability reporting.
Updating the internal regulatory framework in light of the continuously evolving external regulations.
In close liaison with the Risk Committee, reporting to and from the Supervisory Authorities on climate and environmental risks.

In performing its advisory and proposing functions vis-à-vis the strategic oversight body, the Committee avails itself of support of the Group Sustainability & ESG Strategy Organisational Unit, as well as of all other organisational supervisory bodies.

The organisational unit in charge

The Group Sustainability & ESG Strategy organisational unit established within the Parent Company is the company's focal point with regard to sustainability issues and plays a proactive and coordinating role, working primarily in the following areas: i) definition of sustainability strategies and consequent monitoring; ii) coordination of the process of integrating ESG factors into company processes and related projects; iii) preparation of the Consolidated Non-Financial Statement (CNFS) in order to report on the results achieved by the Group in the ESG sphere in line with the stated objectives and commitments; iv) interaction with Group companies and trade associations with the aim of supporting the Group in its sustainable development process.

The ESG Ambassador

The position of ESG Ambassador established by the Sustainability Policy represents the lead person for ESG issues within each Parent Company Area and each Group company.

The ESG Ambassador plays the role of coordinating ESG initiatives and the reporting process in the relevant function/company and liaising with the Parent Company Sustainability Function.

The Commitment Charters

The BCC Iccrea Group has confirmed its mission with the Charter of Commitments on Environment and Climate Change and the Charter of Commitments on Human Rights, thus renewing its concrete, responsible commitment to environmental, social and human rights issues in order to ensure the pursuit of the UN Sustainable Development Goals (SDGs) set out in the 2030 Agenda

Consistent with the Sustainability Plan, the Commitment Charters outline a positive evolutionary process in the area of sustainability starting from the Group's common values and principles, fundamental both to continue to ensure the historical support offered to local communities by BCCs over the years, and to achieve objectives consistent with the current strengthened regulatory framework in this domain.

Indeed, the Charter of Commitments on Environment and Climate Change defines the Group's commitment to direct and indirect environmental impacts through the development of a management process and the promotion of constructive actions and behaviours – especially among employees, customers, suppliers of participating BCCs and perimeter companies – and the dissemination of an environmental culture within its spheres of influence.

The Charter therefore identifies guidelines aimed at reducing direct environmental impacts (resulting from company activities that determine the consumption of resources, waste production and emissions of harmful substances) and indirect environmental impacts (generated by the behaviour of third parties, as well as by the company as a supplier of goods and services).

The Charter of Commitments on Human Rights enshrines the Group's commitment to the promotion and protection of human rights, both internally – thanks to an effective integration of aspects relating to these rights in its various strategies and operations – and with counterparts (shareholders, customers, suppliers), encouraging virtuous behaviour along the entire value chain.

The Group's Sustainability Policies

Today, sustainability is a compulsory choice for companies and financial institutions. This isn’t a temporary approach, but rather a principle that will guide future growth and economic and social development.

In this new context, the BCC Iccrea Group – which has always been committed to promoting the sustainable development of local communities – considers it a priority to make this commitment concrete also through policies aimed at integrating sustainability into its strategies, business model, operational procedures and controls.

Current policies include:

The Group Sustainability Policy which defines the principles and guidelines aimed at fostering the integration of ESG factors into the Group's company processes, and details the governance structure and sustainability management model. The Policy consists of two annexes dealing with the integration of ESG metrics in the provision of investment services and the reporting process of non-financial information
See the excerpt from the Group Sustainability Policy
The Group Diversity and Inclusion Policy, approved in January 2022, aimed at promoting a corporate culture free of all forms of discrimination and supporting the principles of diversity and inclusion.
See the excerpt from the Group Diversity, Equity and Inclusion Policy
The Group Policy on Credit Granting and Closing updated to include the assessment of creditworthiness in light of ESG factors.
The updated Group Product Management Policy providing for the inclusion and integration of ESG factors in Product Approval processes. The purpose of the Policy is to define the general principles, guidelines, roles and responsibilities of the Functions involved in the Product Management model adopted by the Group.
Risk Management Policies. As part of the definition/update of the internal set of regulations concerning the management of climate and environmental risks, the Group defined its policy on the Identification and Assessment of Climate and Environmental Risks and updated the Operational Risk Self Assessment and Loss Data Collection policies.
The Group Whistleblower Policy, updated in 2022, which defines the general principles, roles and responsibilities related to the Whistleblower System, illustrates the principles of the procedure adopted by the Group and outlines the safeguards put in place to guarantee the confidentiality of the personal data of the whistleblower and the alleged perpetrator of the violation.
The Group Remuneration and Incentive Policy. In view of the Group's strong focus on and commitment to an increasingly sustainable and responsible long-term development, specific initiatives aimed at integrating ESG factors and risks have also been defined with regard to remuneration and incentive systems. Information on the consistency of remuneration policies with the integration of sustainability risks is included in the “Remuneration and Incentive Policies” document, published annually on this website;
The Travel Policy, approved in November 2022, provides guidelines and establishes operating procedures for the Parent Company and the Immediate Perimeter Companies to manage employee travel, put in place to pursue maximum efficiency and the reduction of CO2 emissions.