Intesa Sanpaolo SpA

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	Intesa Sanpaolo provides a high level of transparency on its climate-related public-policy engagement. It explicitly names multiple measures it has worked on, including the Directive on Corporate Sustainability Due Diligence (COM/2022/71), the revision of the EU Emissions Trading System (COM/2021/551), the Regulation on an EU Green Bond Standard (COM/2021/391), the EU Taxonomy Regulation and delegated acts, the Non-Financial Reporting Directive revision and the Corporate Sustainability Reporting Directive. The bank also sets out how it engages: it describes “various sessions of training and presentations directed to Members of the European Parliament, European Commission, the European Council and trade associations,” notes that it “participated to several meeting with relevant policy makers” and “reply[ed] to public consultations (directly and/or through the relevant associations),” as well as channelling input through the European Banking Federation and other industry groups—clearly identifying both the mechanisms and the targets of its lobbying. Finally, it details the concrete outcomes it seeks, such as proposing changes to the CSDDD’s value-chain definition and directors’ duties to avoid legal uncertainty, opposing the exclusion of financial institutions from direct access to the EU ETS because it would “undermine the functioning of the market itself,” backing an EU Green Bond Standard that remains voluntary while preserving bond status until maturity, and advocating that the CSRD extend to all large companies, require limited assurance and align with established market frameworks like GRI. By specifying the policies, the methods of influence, the decision-makers addressed and the precise policy changes it supports or opposes, the company demonstrates comprehensive disclosure of its climate lobbying activities.	4

Lobbying Governance

Overall Assessment	Comment	Score
Moderate	Intesa Sanpaolo outlines a structured, climate-focused governance process for its own policy engagement, stating that "through its Chief Institutional Affairs and External Communication Officer (CIAECO), Intesa Sanpaolo regularly monitors the numerous and profound changes in the regulatory framework ensuring that all the positions expressed by the Group are consistent and in line with the strategy," and that every response to climate consultations "is coordinated by the CIAECO Area in a drafting procedure that includes up to 4 subsequent drafts before the definition of the final position." A named executive therefore oversees alignment, and the "Steering Committee, composed of the first organizational line, meets on a quarterly basis to examine climate change issues, including new regulation," adding an additional management layer. The bank records that engagement work is "tracked and managed through a dedicated internal platform where progress and results achieved are monitored," and confirms "a public commitment to conduct your engagement activities in line with the goals of the Paris Agreement." These disclosures show concrete mechanisms, monitoring tools and accountable bodies for keeping direct lobbying in line with its climate strategy, indicating moderate governance strength. Nevertheless, the company does not disclose a procedure for reviewing, challenging or exiting trade associations whose climate positions may conflict with its own, nor does it publish an external climate-lobbying alignment report or describe board-level sign-off specific to lobbying activities; thus the governance of indirect lobbying and the breadth of public transparency remain limited.	2