Intesa Sanpaolo SpA

Intesa Sanpaolo has implemented a defined governance process for its climate lobbying and engagement activities, with the Chief Institutional Affairs and External Communication Officer (CIAECO) taking a central role to "regularly monitor the numerous and profound changes in the regulatory framework" and to ensure that "all the positions expressed by the Group are consistent and in line with the strategy." The process includes structured coordination of responses to public consultations - where "every reply to public consultations on climate issues are coordinated by the CIAECO Area ... [with] up to 4 subsequent drafts before the definition of the final position" - and active involvement in both direct advocacy and indirect engagement through trade associations, as illustrated by the fact that "the Intesa Sanpaolo Group expressed its position responding to public consultations ... and proposing amendments both directly and through the relevant trade associations." Oversight is further reinforced by a Steering Committee that "meets on a quarterly basis to examine climate change issues, including new regulation" and by a dedicated internal platform "where progress and results achieved are monitored," demonstrating that both direct and indirect lobbying are managed and tracked against its climate change strategy. However, the company does not disclose a publicly available audit or third‐party review explicitly evaluating the alignment of its climate-related lobbying, and we found no evidence of formal criteria for reassessing or exiting trade associations whose positions may conflict with its climate objectives.