Compliance

Compliance plays a leading role in promoting a culture which reflects the Group's fundamental values and principles, including ESG dimensions.

 

Group Compliance monitors the management of the non-compliance risk according to a risk-based approach, that focuses its activities and priorities on the areas, standards, processes and procedures most at risk of noncompliance, based on the ongoing assessment of Group activities and the regulatory framework and corporate environment.

FOCUS ON CUSTOMERS

  • Transparency to customers
  • Consumer safeguard regulation
  • Risks concerning banking and financial activities

ADVISORY TO BANK FUNCTIONS ON REGULATORY REQUIREMENTS

  • New products
  • Processes
  • Business initiatives
  • Commercial campaigns
  • Marketing materials

RULES AND REGULATIONS

  • Set rules of conducts
  • Set guidelines and standards
  • Conflicts of interests management

ESG considerations are embedded within the three strategic pillars of the Compliance Plan.

GOVERNANCE

  • Definition of compliance roles and responsibilities in the ESG framework
  • Issuing internal guidelines integrating ESG topics into the current compliance framework
  • Training and workshop on ESG Greenwashing risk.

RISK PRESIDIUM

  • Interpret, analyse and strengthen regulatory areas impacted by new ESG regulations
  • Amended MiFID II and Insurance Distribution Directive questionnaires to allow clients to express their sustainability preferences
  • Monitor on new rules related to target market identification of correct products
  • Consistency and coherency checks on specialised sustainability supervision unit.

CULTURE

  • Integration of ESG principles in the reviewed Code of Conduct (see focus)
  • Internal and external training sessions on ESG topics to compliance colleagues
  • Top Management round table on ESG Greenwashing Risk whose videos and scripts have been cascading to local management Board
  • In 2022 UniCredit employees received more than 317,000 hours of Compliance training and in particular more than 7,000 hours of Anticorruption trainingA. More than 90k training attended.

A The number of hours was significantly lower than last year due to an update course layout, also including the possibility to skip modules in case of a positive pre assessment test on the specific subject.