2022 Communication on Progress

FinecoBank SpA

Published date

June 17, 2022

No. of questions

62

CEO Statement

Signed

  • Governance

    Policies and Responsibilities

    1. Does the Board / highest governance body or most senior executive of the company:

    2. Does the company have a publicly stated commitment regarding the following sustainability topics?

    No, this is not a current priority

    No, but we plan to have a commitment within 2 years

    Yes, and the commitment is focused on our own operations

    Yes, and the commitment includes our own operations and the value chain

    Yes, and the commitment includes our own operations and the value chain along with communities and society

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    Optional comment
    The Human Rights commitment defines the roles and responsibilities, principles, rules, procedures and reporting systems that FinecoBank adopts in order to create a corporate culture that is capable of guaranteeing human dignity and a working environment that is free of any form of discrimination. Our Labour Rights commitment is included in the Human Rights commitment. The Environmental Policy applies to all the activities carried out by FinecoBank Group, in Italy and abroad, and is structured with the definition of a series of General Principles - which express the organization's guidelines and orientations - and of Main Areas of Intervention, which constitute the reference framework for establishing specific environmental objectives and targets, in the pursuit of continuous improvement of our environmental performance. The Anti-Corruption Policy articulates the Group's commitment to both the fight against corruption and compliance with the anti-corruption provisions in force; it defines the principles for the identification and prevention of potential corruption incidents in order to protect the Group's integrity and reputation; it clearly communicates the anti-corruption principles to stakeholders both internal and external to the Group; it provides the general framework for the Group's Anti-Corruption Programme.

    3. Does the company have in place a code of conduct regarding each of the following sustainability topics?

    No, this is not a current priority

    No, but we plan to have a code of conduct within two years

    Yes, focused on employee conduct

    Yes, focused on employees and suppliers

    Yes, focused on employees, suppliers, and other business relationships

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    Optional comment
    The Code of Conduct sets out the general principles that must be observed by all members of the executive, strategic and control bodies, employees and third parties. Employees who violate or engage in conduct that is not in line with the obligations arising from this document may be subject to disciplinary action by the Human Resources function. Serious violations of the provisions of this Code of Conduct and of the local laws and regulations referred to in the Code may instead result in termination of employment. There are chapters dedicated to Protection of the environment, human rights and anti-corruption. The desired conduct on labour rights is described within Human Rights section. The code of conduct document is integrated with the integrity charter and is published on the institutional website. For further information please refer to the following link: https://images.finecobank.com/common/pub/pdf/corporate/cartaintegrita_codicecondotta_en.pdf

    4. Has the company appointed an individual or group responsible for each of the following sustainability topics?

    No one is specifically responsible for this topic

    Yes, with limited influence on outcomes (e.g., limited access to internal information, limited decision-making authority)

    Yes, with moderate influence on outcomes (e.g., has access to relevant information, reports to senior manager)

    Yes, with direct influence of some outcomes (e.g., has access to relevant information, includes one or more senior manager with decision making rights

    Yes, with direct influence at the highest levels of the organization (e.g., has access to relevant information, includes most senior members of organization)

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    Optional comment
    The Sustainability Office reports directly to the CFO and is responsible for supporting the bodies in charge of defining the ESG strategy, drafting the Consolidated Non-Financial Statement and coordinating around 30/35 corporate functions in carrying out the sustainability-related activities set out in the ESG strategic plan; the Sustainability Management Committee, whose members include FinecoBank's top managers, defines a proposal for the Bank's sustainability strategy and the related objectives to be achieved, to be submitted to Corporate Governance and Environmental and Social Sustainability Committee for consideration. The Management Committee is also in charge of monitoring the progress of the defined ESG strategy; We also have a Committee at Board of Directors level (Corporate Governance and Environmental and Social Sustainability Committee), which has been assigned the task of overseeing sustainability issues related to the Bank's operations and interaction with all stakeholders, as well as the evolution of the company's sustainability strategy on the basis of the relevant international guidelines and principles; The Risk and Related Parties Committee also has specific responsibilities in the field of Sustainability: in fact, it has the task of supporting the Board of Directors in assessing periodic reports of a non-financial nature, in addition to financial reports. The Board of Statutory Auditors, as a control body, is responsible for supervising compliance with the requirements of the Decree regulating the preparation of the Non-Financial Statement. Finally, the Directors are responsible for deciding on the strategic direction of the Bank and the Group, with the aim of pursuing sustainable success and creating long-term value for stakeholders.

    5. Does the company have a formal structure(s) (such as a cross-functional committee) to address each of the following sustainability topics?

    No formal structure

    Yes, and with limited influence on outcomes (e.g., limited access to internal information necessary to understand risks, poor representation from relevant departments or functions)

    Yes, with moderate influence on outcomes (e.g., it includes representatives of some functions, departments, or business units most relevant for addressing the risks concerned, has access to relevant information, reports to senior manager)

    Yes, with direct influence on some outcomes (e.g., it includes representatives of functions, departments, or business units most relevant for addressing the risks concerned, has access to relevant information, it involves one or more members of senior management)

    Yes, and with direct influence at the highest level of the organization (e.g., full access to relevant information, it involves members at highest level of organization)

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    Optional comment
    The Sustainability Office reports directly to the CFO and is responsible for supporting the bodies in charge of defining the ESG strategy, drafting the Consolidated Non-Financial Statement and coordinating around 30/35 corporate functions in carrying out the sustainability-related activities set out in the ESG strategic plan; the Sustainability Management Committee, whose members include FinecoBank's top managers, defines a proposal for the Bank's sustainability strategy and the related objectives to be achieved, to be submitted to Corporate Governance and Environmental and Social Sustainability Committee for consideration. The Management Committee is also in charge of monitoring the progress of the defined ESG strategy; We also have a Committee at Board of Directors level (Corporate Governance and Environmental and Social Sustainability Committee), which has been assigned the task of overseeing sustainability issues related to the Bank's operations and interaction with all stakeholders, as well as the evolution of the company's sustainability strategy on the basis of the relevant international guidelines and principles; The Risk and Related Parties Committee also has specific responsibilities in the field of Sustainability: in fact, it has the task of supporting the Board of Directors in assessing periodic reports of a non-financial nature, in addition to financial reports. The Board of Statutory Auditors, as a control body, is responsible for supervising compliance with the requirements of the Decree regulating the preparation of the Non-Financial Statement. Finally, the Directors are responsible for deciding on the strategic direction of the Bank and the Group, with the aim of pursuing sustainable success and creating long-term value for stakeholders.

    Prevention

    6. Does the company have a process or processes to assess risk?

    No, this is not a current priority

    No, but we are planning to develop one in the next two years

    Yes, related to our own operations

    Yes, related to our own operations and entire value chain and other business relationships

    Human rights risks

    Labour rights risks

    Environmental risks

    Corruption risks

    Optional comment
    FinecoBank S.p.A. has adopted an Organisation and Management Model, in accordance with Legislative Decree 231/2001 (“Model” or “Model 231”), concerning the administrative liability of entities, companies and associations. The aim of adopting the Model is to ensure that the Bank provide its own customers with banking and financial services with respect for the values and principles of integrity, professionalism, diligence, honesty, fairness and responsibility. Although organisations are not legally obliged to implement the Model, it nonetheless performs the important function of preventing offences on corruption, human rights, environmental misconduct and labour rights that could give rise to the Bank’s administrative liability. The principles and contents of the Model are addressed to all members of corporate bodies, all Fineco's employees and collaborators (including, for example, agents or financial advisors authorised to offer their services outside their offices and business partners). The documents are published on the institutional website at the following link: modello-organizzazione-gestione.pdf (finecobank.com) https://images.finecobank.com/common/pub/pdf/corporate/governance/codice-etico-finecobank.pdf

    6.1. During the assessment of risk, which business relationships are reviewed?

    A few suppliers or business relationships [approximately less than 25 %]

    Several suppliers / business relationships (i.e., first tier or other high priority) [approx. 25 - 50 %]

    Most suppliers / relevant business relationships [approx. 51 - 99 %]

    All suppliers / relevant business relationships outside the supply chain

    Human rights risks

    Labour rights risks

    Environmental risks

    Corruption risks

    Optional comment
    All suppliers must take note of the Code of Ethics, which requires compliance with the principles of the International Labour Organisation on fundamental human rights, child labour, freedom of association, working conditions, equal pay, health, safety and business ethics; during the qualification phase, suppliers are asked, where applicable, to provide - DURC (Single Document of Contributory Regularity) and CCIAA (Chamber of Commerce, Industry, Handicrafts and Agriculture) certificate; - regulations on social security, accident prevention and insurance and on health and safety at work; - ISO 9001 and ISO 14001 certifications; - self-declaration on worker exploitation (e.g. illegal recruitment and abuse of labour). In the area of corruption, the compilation of a questionnaire is mandatory for all suppliers. With regard to additional sustainability requirements for suppliers, in 2021 Contract Managers, who are the company contact persons responsible for supplier relations, were asked to submit the ESG questionnaire to monitor possible risks related to the procurement process, mainly related to the possible selection of suppliers involved in illegal operations or who have been involved in social and environmental responsibility disputes. Since the ESG questionnaire was set up, 10.4% of suppliers have been covered. this is because only suppliers invoicing FinecoBank for a total annual amount of 25,000 euros or more (VAT included) and only newly accredited suppliers or those with an expired or expiring contract were considered.

    7. Does the company have a due diligence process through which it identifies, prevents, mitigates, and accounts for actual and potential negative impacts on sustainability topics?

    No, this is not a current priority

    No, but we are planning to develop one in the next two years

    Yes, related to our own operations

    Yes, related to our own operations and entire value chain and other business relationships

    Human rights risks

    Labour rights risks

    Environmental risks

    Corruption risks

    Optional comment
    The materiality analysis is the core process of preparing the Non-Financial Statement. Its aim is to select the economic, environmental and social issues that are most significant for the Group and its stakeholders. Fineco conducted its first materiality analysis in 2018 and it has been updated over the years.

    7.1. During the due diligence process, which business relationships are reviewed?

    A few suppliers or business relationships [approximately less than 25 %]

    Several suppliers / business relationships (i.e., first tier or other high priority) [approx. 25 - 50 %]

    Most suppliers / relevant business relationships [approx. 51 - 99 %]

    All suppliers / relevant business relationships outside the supply chain

    Human rights risks

    Labour rights risks

    Environmental risks

    Corruption risks

    Optional comment
    In 2020, the materiality analysis was updated taking into account investors' expectations.

    Concerns and grievance mechanisms

    8. Are there any processes through which members of the company’s workforce can raise concerns about the company’s conduct related to human rights, labour rights, environment, or anti-corruption?

    Optional comment
    FinecoBank has adopted a system through which employees, personal financial advisors and third parties can report any conduct that violates the law or the Bank’s internal rules. This process is designed to guarantee the maximum possible confidentiality with regard to the identity of the whistleblower and the person accused/reported and to prevent any possible retaliation or discriminatory behaviour as a result of the report. Fineco provides employees, personal financial advisors and third parties with specific channels, available 24 hours a day, 7 days a week, for reporting irregularities, also anonymously. The whistleblowing policy is published on the institutional website at the following link https://images.finecobank.com/common/pub/pdf/corporate/sostenibilita/global-policy-whistleblowing_en.pdf

    8.1. Please provide additional detail regarding the process(es) the company has through which members of the company’s workforce can raise concerns about the company’s conduct.

    No

    Yes

    Is the process communicated to all employees/workers in local languages?

    Is the process available to non-employees (e.g., contractors, vendors, suppliers)?

    Is the process confidential (e.g., whistleblowing process)?

    Are there processes in place to avoid retaliation?

    Can concerns be raised about suppliers or other business relationships (e.g., clients, partners, etc.)

    Other (Please provide additional information)

    Optional comment
    FinecoBank has adopted a system through which employees, personal financial advisors and third parties can report any conduct that violates the law or the Bank’s internal rules. This process is designed to guarantee the maximum possible confidentiality with regard to the identity of the whistleblower and the person accused/reported and to prevent any possible retaliation or discriminatory behaviour as a result of the report. Fineco provides employees, personal financial advisors and third parties with specific channels, available 24 hours a day, 7 days a week, for reporting irregularities, also anonymously. The whistleblowing policy is published on the institutional website at the following link https://images.finecobank.com/common/pub/pdf/corporate/sostenibilita/global-policy-whistleblowing_en.pdf

    9. Does the company provide or enable access to effective remedy to right holders / stakeholders where it has caused or contributed to the adverse impact?

    No process to enable remedy to stakeholders

    Remedy available to some stakeholders (i.e., some geographies, employees only)

    Remedy is available to all affected stakeholders

    Remedy is available to all stakeholders, and suppliers are expected to have similar policies

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    Optional comment
    In the event of damage in one of the area above, ascertained by the authorities, Fineco takes remedial action.

    Lessons

    10. How does the company capture lessons regarding each of the following sustainability topics?

    No lessons are regularly captured

    Conducts root cause analyses/investigation of major incidents

    Conducts root cause analyses/investigation and changes organizational policies, processes, and practices accordingly

    Systematically conducts root cause analyses/investigation and leverages learnings to influence both internal and external affairs

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    Optional comment
    The main investigations Fineco conducts concern meetings with investors, employee surveys and rating agency analyses. For each type of activity, areas for improvement are analysed and concrete actions are proposed.

    Executive Pay

    11. Is executive pay linked to performance on one or more of the following sustainability topics?

    No, and we have no intention to change

    No, but we plan to within two years

    Yes

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    Optional comment
    The 2021 Individual Scorecard for each Risk Taker maintains an appropriate balance between quantitative/strategic factors (which represent 70% of the overall scorecard) and sustainable factors (which represent 30% of the overall scorecard). The specific “Stakeholder Value” objective includes a number of ESG goals, integrated into the Group’s 2020-2023 Strategic Plan. In particular, the sustainability topics are related to Improve Fineco's environmental performance (e.g. Environmental Statement, reduction of energy consumption); Delta on Gender Pay Gap and Gender Balance (Y/Y). In the Long Term Incentive Plan 2021 – 2023 Fineco takes into account the compensation and working conditions of its employees, as is also highlighted by the specific People Engagement performance indicator. The objective relating to “Tone from the top on conduct and compliance culture” concerning integrity in conduct and the promotion of a compliance culture within the organization has been maintained. For further details on remuneration and incentive policies and compensation in the event of early termination of employment see “Section I - 2021 Report on Remuneration Policy” and the “Termination Payments Policy”, both of which are available in the Governance section of the FinecoBank website.

    Board Composition

    12. Percentage of individuals within the company’s Board / highest governance body by:

    Number/Percentage

    Not applicable (Please provide additional information)

    Total number of board members (#)

    11

    Male (%)

    45

    Female (%)

    55

    Non-binary (%)

    0

    Under 30 years old (%)

    0

    30-50 years old (%)

    27

    Above 50 years old (%)

    73

    From minority or vulnerable groups (%)

    0

    Executive (%)

    9

    Independent (%)

    91

    13. Do you produce sustainability reporting according to:

    Data Assurance

    14. Is the information disclosed in this questionnaire assured by a third-party?

    For all information please refer to the Non-Financial Statement on the Fineco Bank website at the following link: https://images.finecobank.com/common/pub/pdf/corporate/investors/2021-Consolidated-Non-Financial-Statement.pdf The pages to be considered are 160-163

  • Human Rights

    Materiality / Saliency

    1. Which of the following has the company identified as material human rights issues connected with its operations and/or value chain, whether based on their salience (i.e., the most severe potential negative impacts on people) or another basis?

    Optional comment
    The Human Rights Commitment is aimed at defining an inclusive approach to manage impacts on Human Rights and mitigate potential risks of violations by paying attention to our main stakeholders such as employees, clients, financial advisors, suppliers and local communities. For Fineco, respecting human rights means ensuring human dignity, a working environment free from any form of discrimination, promoting diversity, whether it be gender, physical, skills, sexual orientation, gender identity/expression and beliefs and opinions, and inclusion of its staff and financial advisors. We are committed to minimising the risks of human rights violations in our supply chain by communicating our values and commitments on this topic to our suppliers through our Code of Ethics and by asking each new supplier, and in case of renewal of the contract for existing suppliers, to fill in an ESG questionnaire including for example certifications on social matters. The system of reporting violations "whistleblowing" is in place with the aim not only to report unlawful conduct, the cause of a possible violation of human rights, but also the protection of confidentiality with regard to both the identity of the reporter and the person accused in order to prevent discriminatory behaviour as a result of the report.

    Commitment

    2. Does the company have a policy commitment in relation to the following human rights issues?

    No, and we have no plans to develop a policy

    No, but we plan to in the next two years

    Yes, included within a broader policy

    Yes, articulated as a stand-alone policy

    Rights of women and/or girls

    Freedom of expression

    Rights of refugees and migrants

    Digital security / privacy

    13/10/2020

    Rights of indigenous peoples

    Access to culture

    Free, prior and informed consent

    Access to water and sanitation

    Optional comment
    The human rights commitment is publicly available on Fineco's website in the Sustainability section.

    2.1. For each human rights policy, is it:

    Aligned with international human rights standards?

    Publicly available?

    Approved at most senior level of the company?

    Applied to the company’s own operations?

    Applied to the company’s supply chain and/or other business relationships?

    Developed involving human rights expertise from inside and outside the company?

    Other (Please provide additional information)

    Freedom of expression

    Digital security / privacy

    Rights of women and/or girls

    Access to culture

    Rights of indigenous peoples

    Free, prior and informed consent

    Rights of refugees and migrants

    Access to water and sanitation

    Prevention

    3. In the course of the reporting period, has the company engaged with affected stakeholders or their legitimate representatives in relation to the following human rights issues?

    No engagement on this topic

    To better understand the risks/ impacts in question

    To discuss potential ways to prevent or mitigate the risks/ impacts in question

    To agree on a way to prevent/ mitigate the risks/ impacts in question

    To assess progress in preventing /mitigating the risks/impacts in question

    To collaborate in the prevention/ mitigation of the risks/ impacts in question

    Rights of women and/or girls

    Freedom of expression

    Rights of refugees and migrants

    Digital security / privacy

    Rights of indigenous peoples

    Access to culture

    Free, prior and informed consent

    Access to water and sanitation

    Optional comment
    Fineco engage with its stakeholders on the human rights issue through the administration to employees of surveys on Engagement and Related Work Stress issues. Fineco requires suppliers to complete an initial self-assessment questionnaire on the basis of ESG criteria, including information on possible human rights certifications.

    4. What type of action has the company taken in the reporting period with the aim of preventing/mitigating the risks/impacts associated with this human rights issue?

    Provided internal training/ capacity building for the direct workforce

    Building capacity among relevant business relationships (e.g., partners, suppliers, clients, etc.)

    Conducting an audit process and/or corrective action plan

    Collective Action with peers or other stakeholders to address the issue

    Collaboration with governmental or regulatory bodies

    Other (Please provide additional information)

    No action within reporting period

    Rights of women and/or girls

    Freedom of expression

    Rights of refugees and migrants

    Digital security / privacy

    Rights of indigenous peoples

    Access to culture

    Free, prior and informed consent

    Access to water and sanitation

    Optional comment
    Fineco implements various actions including training for its employees and Personal Financial Advisors. The aim is to disseminate the principles, rules, procedures and reporting systems that the Bank adopts in order to create a corporate culture capable of guaranteeing human dignity, a working environment free from all forms of discrimination and promoting diversity and inclusion. FinecoBank has a Welfare System that is continuously evolving and improving. With the aim of maintaining a high level of attention on matters related to the health of workers, the monitoring of objective data regarding workloads and work patterns continued in 2021, as detailed in the Related Work Stress Assessment carried out in 2020. Suppliers are also subject to appropriate professional and technical controls. These include checks carried out on insurance cover, collective bargaining agreements applied, average annual workforce, social security compliance, and any suspension orders.

    5. Who receives training for the following human rights issues?

    No training provided

    Select employees

    All employees

    Contractors

    Direct suppliers of the organization

    Indirect suppliers of the organization

    Other – such as partners, clients, etc.

    Rights of women and/or girls

    Freedom of expression

    Rights of refugees and migrants

    Digital security / privacy

    Rights of indigenous peoples

    Access to culture

    Free, prior and informed consent

    Access to water and sanitation

    Optional comment
    Personal Financial Advisors are freelance/self-employed workers who provide intellectual services in places outside the Bank’s direct control. Training is very important for Fineco. It focuses on mandatory topics with the aim of strengthening the risk and compliance culture. In fact, the 2021 training offering for all Personal Financial Advisors and employees has been updated and customised with targeted content, and the results are constantly monitored to ensure that all PFAs and employees have mastered the topics. Human rights impacts are managed and mitigated with respect to privacy protection and the identification and mitigation of corruption risk. Fineco has participated in a series of training initiatives specifically designed to promote diversity and inclusion in the company, covering topics such as unconscious stereotyping, inclusive language, working in diverse teams, staff empowerment and sexual and gender harassment in the workplace. In addition, two online courses were launched for all employees entitled 'Unconscious Bias' and 'Combating Harassment, Sexually Inappropriate Behaviour and Bullying'.

    6. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following human rights issues?

    No monitoring of progress

    Review issues on ad-hoc basis

    Set annual targets/ goals, track progress over time (internal programs only)

    Set annual targets/ goals, track progress over time (internal and external programs)

    Other (Please provide additional information)

    Rights of women and/or girls

    Freedom of expression

    Rights of refugees and migrants

    Digital security / privacy

    Rights of indigenous peoples

    Access to culture

    Free, prior and informed consent

    Access to water and sanitation

    Optional comment
    In order to prevent risks and impacts associated with human rights Fineco has put in place a structured process for analysing accidents in the workplace, which involves the immediate monitoring of incidents that may result from work-related injuries. With the aim of maintaining a high level of attention on matters related to the health of workers, the monitoring of objective data regarding workloads and work patterns continued as detailed in the Related Work Stress Assessment. In addition, Fineco monitors cases of discrimination based on age, race, nationality, citizenship, political opinions, religion, marital status, gender, sexual orientation, sexual identity, disability, personal characteristics and experiences or any other aspect that may distinguish an individual throughout his or her life, such as personal or corporate culture. In addition, the percentage of employees covered by collective bargaining agreements is monitored.

    Response

    7. During the reporting period, has the company been involved in providing or enabling remedy where it has caused or contributed to adverse impact associated with the following human rights issue(s)?

    Yes

    No

    Choose to not disclose

    Not applicable (Please provide additional information)

    Rights of women and/or girls

    Freedom of expression

    Rights of refugees and migrants

    Digital security / privacy

    Rights of indigenous peoples

    Access to culture

    Free, prior and informed consent

    Access to water and sanitation

    Optional comment
    Over the course of 2021, the Bank received 3 substantiated complaints concerning violations of the personal data of customers which were proven to be (even if only partially) well founded, although these did not represent a risk or source of potential harm to customers and their rights and freedoms. With regard to possible data leaks, thefts or losses, following the strengthening of the detection capacity of the competent structures and in line with the results of the surveys carried out in 2021, 17 events were detected for which the Bank determined that there was no damage to the customers and put in place appropriate corrective measures.

    8. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the human rights principles, including any challenges faced and actions taken towards prevention and/or remediation.

    FinecoBank creates a corporate culture capable of ensuring human dignity, a working environment free from any form of discrimination, promoting diversity and inclusion of its employees and Personal Financial Advisors. The Bank pays particular attention to the indirect impacts on human rights that may be generated through its sales and financial advisory activities and, therefore, promotes a dialogue with clients based on clarity and transparency, as well as considering potential risks relating to respect for human rights in investment decisions. FinecoBank is also committed to promoting sustainability in its supply chain by minimising the risks of human rights violations; from this perspective, it is committed to streamlining the assessment of suppliers in relation to social and environmental impacts, evaluating the characteristics of the supply chain also taking into account the respect and protection of human rights. The Bank adopts procedures and reporting systems. The process is designed to guarantee the maximum possible confidentiality with regard to the identity of the whistleblower and the person accused/reported and to prevent any possible retaliation or discriminatory behaviour as a result of the report. Fineco provides employees, personal financial advisors and third parties with specific channels, available 24 hours a day, 7 days a week, for reporting irregularities, also anonymously. The principles and rules are shared through employee and PFA training.

  • Labour

    Commitment

    1. Does the company have a policy commitment in relation to the following labour rights principles?

    No, and we have no plans to develop a policy

    No, but we plan to in the next two years

    Yes, included within a broader policy

    Yes, articulated as a stand-alone policy

    Not applicable (Please provide additional information)

    Freedom of association and the effective recognition of the right to collective bargaining

    13/10/2020

    Forced labour

    13/10/2020

    Child labour

    13/10/2020

    Non-discrimination in respect of employment and occupation

    13/10/2020

    Occupational safety and health

    13/10/2020

    Working conditions (wages, working hours)

    13/10/2020

    1.1. For each labour rights policy, is it:

    Aligned with international labour standards?

    Publicly available?

    Approved at most senior level of the company?

    Applied to the company’s own operations?

    Applied to the company’s supply chain and/or other business relationships?

    Developed involving labour rights expertise from inside and outside the company?

    Other (Please provide additional information)

    Freedom of association and the effective recognition of the right to collective bargaining

    Forced labour

    Child labour

    Non-discrimination in respect of employment and occupation

    Occupational safety and health

    Working conditions (wages, working hours)

    Prevention

    2. In the course of the reporting period, has the company engaged with affected stakeholders or their legitimate representatives in relation to the following labour rights issues?

    No engagement on this topic

    To better understand the risks/ impacts in question

    To discuss potential ways to prevent or mitigate the risks/ impacts in question

    To agree on a way to prevent/ mitigate the risks/ impacts in question

    To assess progress in preventing/ mitigating the risks /impacts in question

    To collaborate in the prevention/ mitigation of the risks/ impacts in question

    Other (Please provide additional information)

    Freedom of association and the effective recognition of the right to collective bargaining

    Forced labour

    Child labour

    Non-discrimination in respect of employment and occupation

    Occupational safety and health

    Working conditions (wages, working hours)

    Optional comment
    The employment relationships where Professional Areas, Middle Managers and Executives are concerned, are regulated by the respective National Collective Bargaining Agreements (NCBAs) for the credit sector. FinecoBank wants to support the well-being of its employees and their families, which is why its Welfare System is continuously evolving and improving. The activities of the Joint Committee on Work Life Balance, Innovation and Welfare continued, whose meetings are guided by the principles of mutual dialogue, promotion and improvement of work-life balance, in the belief that an appropriate balance between working and private life has a positive impact on the work environment, employee engagement, productivity and loyalty, also helping to improve people’s quality of life and well-being.

    3. What type of action has the company taken in the reporting period with the aim of preventing/mitigating the risks/impacts associated with this labour rights issue?

    Provided internal training/ capacity building for the direct workforce

    Building capacity among relevant business relationships (e.g., partners, suppliers, clients, etc.)

    Conducting an audit process and/or corrective action plan

    Collective Action with peers or other stakeholders, in particular workers' organizations, to address the issue

    Collaboration with governmental or regulatory bodies

    Other (Please provide additional information)

    No action within reporting period

    Freedom of association and the effective recognition of the right to collective bargaining

    Forced labour

    Child labour

    Non-discrimination in respect of employment and occupation

    Occupational safety and health

    Working conditions (wages, working hours)

    4. Who receives training for the following labour rights issues?

    No training provided

    Select employees

    All employees

    Contractors

    Direct suppliers of the organization

    Indirect suppliers of the organization

    Other – such as partners, clients, etc.

    Freedom of association and the effective recognition of the right to collective bargaining

    Forced labour

    Child labour

    Non-discrimination in respect of employment and occupation

    Occupational safety and health

    Working conditions (wages, working hours)

    Optional comment
    Personal Financial Advisors working within buildings managed by FinecoBank receive appropriate training on health and safety. In addition, the Bank has decided to carry out specific inspections in the Fineco Centers, to check that the premises and equipment comply with current health and safety regulations, accompanied by training for the managers of the financial shops, to properly instruct them on how to maintain and run the Fineco Centers, in compliance with the provisions of Legislative Decree 81/2008.

    5. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following labour rights issues?

    No monitoring of progress

    Review issues on ad-hoc basis

    Set annual targets/ goals, track progress over time (internal programs only)

    Set annual targets/ goals, track progress over time (internal and external programs)

    Other (Please provide additional information)

    Freedom of association and the effective recognition of the right to collective bargaining

    Forced labour

    No impact based on Fineco's business model and context of operations.

    Child labour

    Fineco minimises the risks in of labour violations through specific policies and practices. Suppliers and contractors must meet certain minimum requirements and are subject to appropriate review and assessment, before being taken on and on an ongoing basis. In relation to this, suppliers are required to send specific documentation certifying compliance with the rules on social security, accident prevention and insurance, and on occupational health and safety; ISO 9001 and ISO 14001 certifications and a self-declaration on labour exploitation (so-called Caporalato). The Code of Ethics and the Organisation and Management Model of FinecoBank S.p.A. define the principles of cooperation, fairness, transparency and professionalism, as key principles in relations between FinecoBank and its suppliers. In particular, these principles prohibit dealing with counterparties for which there is a substantiated suspicion that they are involved in illegal activities and do not meet the necessary requirements of professionalism and reliability.

    Non-discrimination in respect of employment and occupation

    Occupational safety and health

    Working conditions (wages, working hours)

    Optional comment
    In order to ensure the increasing integration of environmental, social and governance (ESG) aspects within its strategy, in December 2019 the former Corporate Governance, Appointments and Sustainability Committee approved a first proposal of sustainability goals to be pursued in the years 2020-2023. In 2021, these were partially complemented with quantitative targets and other quantitative targets will be progressively integrated as the needs arise. The process of defining and monitoring sustainability targets and the environmental programme was formalised in a specific Group procedure. Targets are monitored on a quarterly basis and progress is reviewed by the governance bodies. Status is also reported on an annual basis and published through the Non-Financial Statement.

    Performance

    6. What is the percentage of employees covered under collective bargaining agreements?

    Percent of employees (%)

    Unknown

    Employees covered under collective bargaining (%)

    100

    7. What is the percentage of employees in a trade union or other workers' organization?

    Percent of employees (%)

    Unknown

    Not applicable (Please provide additional information)

    Employees in a trade union or on a worker committee (%)

    29

    8. In the course of the reporting period, what was the percentage of women in:

    Percent of women (%)

    Unknown

    Senior leadership level position

    0.48

    Non-executive board

    55
    Optional comment
    Number woman senior leadership in Italy: 6 Number employees in Italy: 1261 6/1261= 0,48%

    9. What was the average ratio of the basic salary and remuneration of women to men (comparing jobs of equal value) during the reporting period?

    Salary ratio (%)

    Unknown

    Choose to not disclose

    Women / Men (%)

    100
    Optional comment
    The indicated data refers to employees, that are the majority of the population in Fineco. We decided to use the GRI 405-2 standard methodology, also use in Sustainability Report. The ratio of women’s to men’s basic salaries in 2021 totalled 87% for executives, 96% for managers and 101% for professional employees, while in 2020 the figures were 88%, 94% and 100% respectively. The ratio of women’s to men’s total remuneration in 2021 totalled 71% for executives, 95% for managers and 101% for professional employees, while in 2020 the figures were 76%, 94% and 99% respectively.

    10. In the course of the reporting period, how frequently were workers injured (injuries per hour worked)?

    Frequency of injury

    Unknown

    Choose to not disclose

    Frequency of injury

    0

    11. In the course of the reporting period, what was the company’s incident rate?

    Incident rate

    Unknown

    Choose to not disclose

    Incident rate

    0

    Response and Reporting

    12. In the course of the reporting period, has the company been involved in providing or enabling remedy where it has caused or contributed to the adverse impact associated with the following labour rights issues?

    Yes

    No

    Choose to not disclose

    Not applicable (Please provide additional information)

    Freedom of association and the effective recognition of the right to collective bargaining

    Fineco did not cause or contribute to any adverse impact associated with labour rights issues

    Forced labour

    Fineco did not cause or contribute to any adverse impact associated with labour rights issues

    Child labour

    Fineco did not cause or contribute to any adverse impact associated with labour rights issues

    Non-discrimination in respect of employment and occupation

    Fineco did not cause or contribute to any adverse impact associated with labour rights issues

    Occupational safety and health

    Fineco did not cause or contribute to any adverse impact associated with labour rights issues

    Working conditions (wages, working hours)

    Fineco did not cause or contribute to any adverse impact associated with labour rights issues

    13. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the labour rights principles, including any challenges faced and actions taken towards prevention and/or remediation.

    Through the approval of policies such as the Human Rights Commitment, Code of Ethics and the Organisation and Management Model, Fineco governs the main labour issues in accordance with national and international regulations and standards. For Fineco, respecting human rights and labour rights means ensuring human dignity, a working environment free from any form of discrimination. Its employees are protected both by the national collective bargaining agreement and by the general occupational health and safety measures in accordance with Legislative Decree no. 81/2008. Added to this is the work carried out by the Joint Committee for the reconciliation of work and life times, innovation and welfare, whose meetings are inspired by the principles of joint confrontation, promotion and improvement of the work-life balance, in the belief that an appropriate work-life balance has a positive influence on the work environment, employee involvement, productivity and sense of belonging, also contributing to improving the quality of life and wellbeing of people. We are also committed to minimising the risks of labour violations in our supply chain by communicating our values and commitments on this topic to our suppliers through our Code of Ethics and by asking each new supplier, and in case of renewal of the contract for existing suppliers, to fill in an ESG questionnaire including for example certifications on social matters. In addition to reading the Code of Ethics, which requires compliance with the principles of the International Labour Organisation on fundamental human rights, child labour, freedom of association, working conditions, equal pay, health, safety and business ethics, during the qualification phase all suppliers are asked for certain documents, when applicable, such as the DURC (Single Document of Regularity) and CCIAA (Chamber of Commerce, Industry, Crafts and Agriculture); social security, accident prevention and insurance provisions and health and safety at work regulations; ISO 9001 and ISO 14001 certifications; self-declaration regarding the exploitation of workers (c. c. Caporalato).

  • Environment

    Commitment

    1. Does the company have a formal policy on the following environmental topics?

    No, and we have no plans to develop a policy

    No, but we plan to in the next two years

    Yes, included within a broader policy

    Yes, articulated as a stand-alone policy

    Not applicable (Please provide additional information)

    Climate Action

    December 2020

    Water

    It's not a material issue within the banking sector.

    Oceans

    It's not a material issue within the banking sector.

    Forests / Biodiversity / Land Use

    It's not a material issue within the banking sector.

    Air Pollution

    It's not a material issue within the banking sector.

    Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)

    December 2020

    Energy & Resource Use

    December 2020
    Optional comment
    The document called "Global Policy - FinecoBank Group Environmental Policy" is an integral part of the documentation that makes up the Environmental Management System that Fineco implemented in compliance with the EU Eco-Management and Audit Scheme (EMAS) (Reg. no. 1221/2009/EC). The Environmental Policy applies to all the activities carried out by FinecoBank Group, in Italy and abroad, and is structured with the definition of a series of General Principles - which express the organization's guidelines and orientations - and of Main Areas of Intervention, which constitute the reference framework for establishing specific environmental objectives and targets, in the pursuit of continuous improvement of our environmental performance.

    1.1. For each environmental policy, is it:

    Aligned with international environmental standards?

    Publicly available?

    Approved at most senior level of the company?

    Applied to the company’s own operations?

    Applied to the company’s supply chain and/or other business relationships?

    Developed involving environmental expertise from inside and outside the company?

    Other (Please provide additional information)

    Climate Action

    Water

    Oceans

    Forests / Biodiversity / Land Use

    Air Pollution

    Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)

    Energy & Resource Use

    Prevention

    2. In the course of the reporting period, has the company engaged with affected stakeholders or their legitimate representatives in relation to the following environmental issues?

    No engagement on this topic

    To better understand the risks/ impacts in question

    To discuss potential ways to prevent or mitigate the risks/ impacts in question

    To agree on a way to prevent/ mitigate the risks/ impacts in question

    To assess progress in preventing/ mitigating the risks/ impacts in question

    To collaborate in the prevention/ mitigation of the risks/ impacts in question

    Other (Please provide additional information)

    Climate Action

    Water

    No impact based on Fineco's business model. The water supply is from the aqueduct and is mainly used for sanitary facilities and office cleaning. Wastewater is discharged into the public sewerage system, in accordance with the applicable regulations.

    Oceans

    No impact based on Fineco's business model.

    Forests / Biodiversity / Land Use

    No impact based on Fineco's business model

    Air Pollution

    No impact based on Fineco's business model.

    Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)

    No impact based on Fineco's business model. The waste produced at FinecoBank’s sites mainly consists of non-hazardous materials such as paper and cardboard, toner and other waste that can be considered municipal waste (plastic, organic, various packaging).

    Energy & Resource Use

    Optional comment
    Fineco participates in meetings with investors and according to their requests disclosure is given. We gather their expectations on these issues in order to structure initiatives in this regard.

    3. What type of action has the company taken in the reporting period with the aim of preventing/mitigating the risks/impacts associated with these environmental topics?

    Provided internal training/ capacity building for the direct workforce

    Building capacity among relevant business relationships (e.g., partners, suppliers, clients, etc.)

    Conducting an audit process and/or corrective action plan

    Collective Action with peers or other stakeholders to address the issue

    Collaboration with governmental or regulatory bodies

    Other (Please provide additional information)

    No action within reporting period

    Climate Action

    Water

    Oceans

    Forests / Biodiversity / Land Use

    Air Pollution

    Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)

    Energy & Resource Use

    4. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following environmental topics?

    No monitoring of progress

    Review issues on ad-hoc basis

    Set annual targets/ goals, track progress over time (internal programs only)

    Set annual targets/ goals, track progress over time (internal and external programs)

    Other (Please provide additional information)

    Climate Action

    Water

    Oceans

    Forests / Biodiversity / Land Use

    Air Pollution

    Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)

    Energy & Resource Use

    Optional comment
    In order to ensure the increasing integration of environmental, social and governance (ESG) aspects within its strategy, in December 2019 the former Corporate Governance, Appointments and Sustainability Committee approved a first proposal of sustainability goals to be pursued in the years 2020-2023. In 2021, these were partially complemented with quantitative targets and other quantitative targets will be progressively integrated as the needs arise. The process of defining and monitoring sustainability targets and the environmental programme was formalised in a specific Group procedure. In addition, Fineco has prepared its own Environmental Statement pursuant to EMAS Regulation (EC) 1221/2009, a document communicating to the public and other interested parties information on its environmental impacts and performance and setting out environmental policy; environmental objectives and targets; and a description of the Environmental Management System. Targets are monitored on a quarterly basis and progress is reviewed by the governance bodies. Status is also reported on an annual basis and published through the Non-Financial Statement.

    5. In the course of the reporting period, has the company been involved in providing or enabling remedy for any actual impacts associated with the following environmental issue(s)?

    Yes

    No

    Choose to not disclose

    Not applicable (Please provide additional information)

    Climate Action

    Fineco did not cause or contribute to any significant adverse impact associated with environmental issues

    Water

    Fineco did not cause or contribute to any significant adverse impact associated with environmental issues

    Oceans

    Fineco did not cause or contribute to any significant adverse impact associated with environmental issues

    Forests / Biodiversity / Land Use

    Fineco did not cause or contribute to any significant adverse impact associated with environmental issues

    Air Pollution

    Fineco did not cause or contribute to any significant adverse impact associated with environmental issues

    Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)

    Fineco did not cause or contribute to any significant adverse impact associated with environmental issues

    Energy & Resource Use

    Fineco did not cause or contribute to any significant adverse impact associated with environmental issues

    Climate Action

    6. What were the company’s gross global greenhouse gas emissions for the reporting period?

    Scope 1 Emissions

    Emissions (tCO2e)

    461

    Scope 2 Emissions

    Emissions (tCO2e)

    12

    Scope 3 Emissions

    Emissions (tCO2e)

    2334
    Optional comment
    For indirect (Scope 2) greenhouse gas emissions according to the location-base approach, the data is 1150 t CO2e. For indirect (Scope 2) greenhouse gas emissions according to the market-base approach, the data is 12 t CO2e.

    7. What percentage of the company's revenue was invested in R&D of low-carbon products/services during this reporting period?

    Percent of revenue (%)

    Fineco does not have an R&D structure. The Global Business structure is responsible for the product and services offering.

    8. Has the organization acted to support climate change adaptation and resilience?

    Optional comment
    As part of the design and implementation of the Environmental Management System, in accordance with the requirements of the EMAS regulation 1221/2009/EC, in June 2021 the Board of Directors approved the 2021-2024 Environmental Programme, defining the environmental objectives, operational actions, the company units responsible for their achievement, the resources allocated, the timeframe and, where possible, the quantitative targets. For Fineco, the goals set out in the Environmental Programme coincide with a selection of the goals already included in the 2020-2023 Sustainability Objectives Plan, approved by the Board of Directors in January 2020, related to the environmental aspects relevant to the Group, i.e. related to the following macro-areas of intervention identified in the Environmental Policy - Responsible Finance - environmentally relevant credit products, ESG assessment of funds on the FinecoBank platform, coverage of green and social bonds within the FinecoBank portfolio; - Supply chain - assessment of suppliers also based on ESG criteria; - Environmental impacts - reduction of energy consumption and emissions, initiatives to support sustainable travel for employees, responsible consumption of paper and plastic.

    Energy / Resource Use

    9. Please report the company's renewable energy consumption as a percentage of total energy consumption in the reporting period.

    % of total energy consumption

    49
    Optional comment
    Total energy consumption from renewable sources: 26279 GJ Total energy consumption: 53764 GJ

    Technology

    10. What percent of the company's revenue came from environmentally friendly products / services during this reporting period?

    Percent of total revenue (%)

    To date, it is not required by the taxonomy for financial organisations to provide breakdown on revenues on the basis of environmentally friendly activities.

    Sector-specific Questions

    11. Which sector(s) does the company operate in? If diversified, choose top 3 by revenue.

    Overall Environment

    21. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the environment principles, including any challenges faced and actions taken towards prevention and/or remediation.

    The very nature of Fineco's business model is geared towards minimising the direct environmental impacts produced, focusing mainly on the responsible use of resources, increasingly favouring the dematerialisation processes inherent to the business, and compliance with all environmental regulations and self-discipline codes. At the end of 2019, Fineco defined the Group's ESG strategy, which was fully integrated into the Multi-Year Plan (MYP) and approved by the Board of Directors in January 2020. Among these objectives in the ESG strategy is the fight against climate change by implementing an Environmental Management System. In 2020, the Group Environmental Policy was approved, formalising the commitment to pursue a programme that, in addition to complying with regulatory provisions, is aimed at continuously improving its environmental performance. The 2021-2024 Environmental Programme was also defined and approved following the indications of the EMAS Regulation, thus indicating the objectives, operational actions, the corporate structures responsible for their achievement, the resources allocated, the timeframe and, when possible, quantitative targets. Fineco manage activities aimed at reducing its environmental impact, the first of which was to appoint an Energy Manager. The adoption of an Environmental Management System and the publication of the Environmental Declaration, offers, from this point of view, an important opportunity to address and strengthen the organisation's commitments to the environmental aspects related to the company's investment policies, as well as in the offer of its products and services.

  • Anti-corruption

    Commitment

    1. Does the company have an anti-corruption compliance programme?

    2022
    Optional comment
    The Anti-Corruption Policy articulates the Group's commitment to fighting against corruption and compliance with the anti-corruption provisions in force; it defines the principles for the identification and prevention of potential corruption incidents in order to protect the Group's integrity and reputation; it clearly communicates the anti-corruption principles to stakeholders both internal and external to the Group; it provides the general framework for the Group's Anti-Corruption Programme. The addressees of the document are all the members of the bodies of strategic supervision, management and control, employees, Personal Financial Advisors and occasional collaborators of the FinecoBank Group and must be applied in conjunction with the current Group Charter of Integrity and Code of Conduct, the Code of Ethics pursuant to Legislative Decree 231/2001 (where applicable) and the Global Policy Whistleblowing. FinecoBank confirms zero tolerance for acts of corruption and prohibits them from being committed in any form, whether direct or indirect; it is also committed to proactively combating corruption in the context in which it operates, promoting integrity of behaviour and corruption-free ways of conducting business among all its stakeholders.

    2. Does your company have policies and recommendations for employees on how to act in case of doubt and/or in situations that may represent a conflict of interest, e.g. with regard to gifts and hospitality, donations, sponsorship, or interactions with public officials?

    Prevention

    3. Who receives training on anti-corruption and integrity?

    Optional comment
    In order to ensure a minimum level of anti-corruption knowledge on the part of its recipients, FinecoBank and its Legal Entities organize a compulsory training programme, which all recipients are required to attend at least every two years, while new resources of the Group must attend a training course within three months of being hired. Both types of training must cover the Company's internal anti-corruption rules, including details of the contacts provided for whistleblowing. Each Group company shall also ensure ad hoc training for the various business areas, key senior management and front office and/or support staff, according to office and/or support staff, as identified in terms of their greater exposure to the dangers of corruption, or as they are involved in the management of key anti-corruption controls.

    3.1. How often is such training provided?

    One time only

    Every year

    Every two or more years

    We do not collect this data

    All employees

    Select employees

    Contractors

    Direct suppliers of the organization

    Other – such as partners, clients, etc.

    Indirect suppliers of the organization

    Optional comment

    4. Does the company monitor its anti-corruption compliance programme?

    Each Group Legal Entity shall systematically inform the Anti-Bribery Officer of FinecoBank on the status of implementation of the local Anti-Bribery Programme and on all events related to anti-corruption activities (to the extent permitted by local law). Reporting will be at least quarterly. Each Group Company must inform the relevant local governing body on the status of the Anti-Bribery Programme at least annually. At Group level, the report on the status of implementation and effectiveness of the Group Anti-Bribery Programme is submitted to the relevant Committee and Board of Directors annually.
    Optional comment
    In order to mitigate corruption risks, FinecoBank Group Companies perform regular first and second level controls. The minimum set of first level controls that the Companies of the FinecoBank Group must carry out relate to ex ante controls on corporate gifts and hospitality offered and received; ex ante controls on mergers, acquisitions, significant investments; ex ante controls on the conferral of mandates to third parties; ex ante controls on charitable contributions, sponsorships and donations; ex ante controls on activities related to job offers, such as recruitment, apprenticeships, promotions, etc.. First-level controls are performed either by the contract manager or by a manager of the relevant competence line (e.g. Procurement, HR, etc.). Second-level controls are performed by the local compliance function. Each Group company, on the basis of its local corruption risk assessment and in accordance with the locally applicable legal requirements, may introduce controls in addition to the minimum requirement of the Anti-Bribery Policy. Each Group Legal Entity shall systematically inform the Anti-Bribery Officer of FinecoBank on the status of implementation of the local Anti-Bribery Programme and on all events related to anti-corruption activities (to the extent permitted by local law). Reporting will be at least quarterly. Each Group Company must inform the relevant local governing body on the status of the Anti-Bribery Programme at least annually. At Group level, the report on the status of implementation and effectiveness of the Group Anti-Bribery Programme is submitted to the relevant Committee and Board of Directors annually.

    Response and Reporting

    5. Please report the company's total number and nature of incidents of corruption during the reporting year.

    Number of incident(s)

    Unknown

    Choose to not disclose

    Confirmed during the current year, but related to previous years

    0
    No incidents of corruption were recorded in 2020

    Confirmed during the current year, and related to this year

    0
    No incidents of corruption were recorded in 2021

    6. Within the reporting period, what measures has the company taken to address suspected incidents of corruption independently or in response to a dispute or investigation by a government regulator?

    7. Does your company engage in Collective Action against corruption?

    8. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the anti-corruption principle, including any challenges faced and actions taken towards prevention and/or remediation.

    Fineco has a “zero tolerance” approach to corruption and prohibits facilitation payments. Political donations in all intangible and tangible forms are also prohibited, as specified in the Anti-Corruption Policy. The Bank’s activities and organisational structures are subject to anti-corruption controls, as per implementation of the Organisation and Management Model in accordance with Legislative Decree 231/2001. The Group has also adopted specific mechanisms to monitor the effectiveness of the adopted anti-corruption and anti-bribery approach, including: escalation procedures for significant and strategic issues, quarterly information requests from management, analysis and testing of the results of activities relating to managing second-level controls, compliance risk assessment processes carried out for each regulatory area of the Compliance Function, and Internal Audit inspections. The last two mechanisms (the Compliance Risk Asssessment and Internal Audit inspections) result in risk mitigation actions that need to be completed on time to ensure the management of the risks identified. Fineco’s approach to preventing corruption and bribery is defined in the Anti-Corruption Global Policy The document has been updated to May 2022 and is published on the Fineco website. These documents set minimum standards for anti-corruption compliance and apply to all members of Fineco’s strategic, control and executive bodies, employees, personal financial advisors and casual collaborators. The Anti-Corruption Policy aims to define principles and rules aimed at identifying and preventing potential acts of corruption in order to protect the integrity and reputation of the Group and to provide recipients with general information on the measures taken to identify, mitigate and manage the risks of corruption.