Code of Ethics and Governance
The application of our Code of Ethics combined with an effective Governance system allows us to integrate Sustainability in the Group’s business model.
We have created important control units: the Internal Control, Risks and Sustainability Committee at board level, the ESG Committee at executive level and the corporate Sustainability structure. They work together to stimulate and improve all activities, defined in our Sustainability Strategy, including the implementation of Policies on the various ESG aspects, the strengthening of the integration of ESG objectives in the incentive plans of Top management and the realization of a framework for issuing green, social and sustainable bonds.
CODE OF ETHICS
The Code of Ethics identifies the principles and values that
underpin our corporate culture and inspire the daily actions of
everyone in our team.
The document states that the Group and all of those that operate with us are committed to respecting human rights, job protection, and the fight against corruption, organised crime and terrorism.
BOARD OF DIRECTORS
The Group’s sustainability is monitored by the Board of Directors which defines the management and coordination policies regarding non-financial disclosure, the socio-environmental policies and approves annually the Consolidated non-financial statement and the associated materiality analysis.
INTERNAL CONTROL, RISKS AND SUSTAINABILITY COMMITTEE
It supervises, in the first instance, sustainability issues as well as – also through the Director delegated by the Committee itself on ESG, “sustainability and social responsibility” issues- the activities connected with the drafting of the Consolidated non-financial statement. The Committee also provides a preliminary opinion to the Board of Directors on said document.
ESG COMMITTEE
Established by the Board of Directors, the Environmental, Social and Governance (ESG) Managerial Committee is chaired by the Chief Executive Officer and counts two Joint General Managers among its permanent members.
Its main tasks include evaluating the Group’s positioning and coordinating all the activities required to achieve the strategic sustainability objectives.
SUSTAINABILITY STRUCTURE
It assists the ESG Committee and oversees the definition of the relevant themes and the monitoring of sustainability indicators. It also evaluates the sustainability impacts stemming from the Group’s initiatives and provides support to the corporate structures. It drafts the Consolidated non-financial statement and promotes sharing of the ESG culture within and outside the Group.
ESG AMBASSADORS
The main contacts on sustainability issues within the various corporate structures and share the main issues to be addressed with the sustainability structure.
Guidelines and commitments
In order to operate in full transparency, we upload our guidelines and commitments that guide our business and which have been developed according to the principles defined in the Code of Ethics, which is the cornerstone of our governance system.
Banco BPM, in its capacity as a financial adviser, i.e. an investment firm providing investment advisory services, declares that it does not currently take into consideration the negative impacts of investment decisions on sustainability factors pursuant to Article 4 of Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 (“SFDR Regulation”), due to a regulatory framework that has not yet been integrated with detailed provisions. Therefore, although the Bank has already undertaken an evolving path aimed at integrating sustainability risks and factors in its investment decision‑making processes, it will consider from time to time to take into account the negative impacts of investment decisions pursuant to Article 4 of the SFDR Regulation.