UniCredit SpA

UniCredit SpA has established a structured process to ensure its engagement activities align with its climate change strategy, embedding "20 key workstreams" in its Group ESG Roadmap that are led by colleagues across functions acting as "ESG Reference points for the entire organization." Its public positioning on climate-related advocacy follows "a structured internal process that starts with a bottom-up analysis of rules and regulation performed by relevant company structures ... followed by a top-down alignment with the overall Group guidelines," and responsibilities are split between the Group Regulatory Affairs department, which is described as the "owners of the formal institutional positioning vis-Ã -vis regulators and public institutions," and Group Sustainability, referred to as "the knowledge point on climate change." However, the company does not disclose any process for reviewing or auditing this lobbying alignment, nor does it identify a named individual or formal oversight body responsible for governance, and we found no evidence of specific measures to manage indirect lobbying through trade or industry associations.