Unipol Gruppo SpA – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Limited	Unipol Gruppo SpA establishes formal structures for policy engagement but provides limited evidence of processes to align its lobbying activities with climate objectives. For example, “The Unipol Group’s Regulation Function reports to the Chief Regulation and Economic Studies Officer and conducts regulatory oversight, advocacy and Top Management support activities,” and through this function the Group “oversees and participates in the work of some important trade associations such as Assonime, Assogestioni, ABI, AMICE and of the most important national and European stakeholder groups.” The company highlights that it is enrolled in the “Parliamentary Register of Representatives of Interest since 2017 and the EU Voluntary Transparency Register since 2014” and that it “actively and transparently engages in relations with institutional stakeholders” via “public consultation processes” and bilateral meetings. The disclosures note that “On Climate Change, where protection from climate risks is becoming increasingly urgent, the Unipol Group engages in dialogue with national and EU policy makers, regulators, supervisory authorities and industrial associations,” but clarify that the aim is “not to influence the pursuit of the Paris Agreement targets.” We found no evidence of any policy or procedure to review or align these lobbying activities with the company’s climate goals, no board or committee sign-off on climate advocacy, nor any dedicated climate-lobbying audit or third-party review, indicating limited governance over climate-related lobbying. View Sources	D

Overall Assessment

Analysis

Score

Limited

Unipol Gruppo SpA establishes formal structures for policy engagement but provides limited evidence of processes to align its lobbying activities with climate objectives. For example, “The Unipol Group’s Regulation Function reports to the Chief Regulation and Economic Studies Officer and conducts regulatory oversight, advocacy and Top Management support activities,” and through this function the Group “oversees and participates in the work of some important trade associations such as Assonime, Assogestioni, ABI, AMICE and of the most important national and European stakeholder groups.” The company highlights that it is enrolled in the “Parliamentary Register of Representatives of Interest since 2017 and the EU Voluntary Transparency Register since 2014” and that it “actively and transparently engages in relations with institutional stakeholders” via “public consultation processes” and bilateral meetings. The disclosures note that “On Climate Change, where protection from climate risks is becoming increasingly urgent, the Unipol Group engages in dialogue with national and EU policy makers, regulators, supervisory authorities and industrial associations,” but clarify that the aim is “not to influence the pursuit of the Paris Agreement targets.” We found no evidence of any policy or procedure to review or align these lobbying activities with the company’s climate goals, no board or committee sign-off on climate advocacy, nor any dedicated climate-lobbying audit or third-party review, indicating limited governance over climate-related lobbying.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Strong	Unipol Gruppo SpA provides a high level of transparency around its climate-related advocacy. The group identifies several specific regulatory initiatives it seeks to influence, including the EU Sustainable Finance Disclosure Regulation (SFDR), the Corporate Sustainability Reporting Directive (CSRD), the EU Taxonomy delegated acts and the Italian insurance supervisor IVASS’s draft letter on Product Oversight and Governance (POG). It also explains how it engages, describing participation in public consultations, bilateral meetings and technical working groups and naming the targets of those actions – for example, the European Commission, ESMA, IVASS and other national ministries – while noting that it is listed on both the Italian Parliamentary Register of Representatives of Interest and the EU Transparency Register. On desired outcomes, the company states that it wants regulations “better aligned with sustainability goals,” that it supports improved insurance product governance and that it backed the adoption of CSRD so that “large enterprises … disclose information on how they manage social and environmental challenges,” demonstrating clear positions on at least two concrete policy changes. Together, these disclosures show strong detail on the policies addressed and the channels used, and provide a reasonably clear picture of the outcomes the company seeks.	B