GOVERNANCE

Since the Regulation (EU) 2019/2088 on the Sustainable Finance Disclosure Regulation (SFDR - information on sustainability in the financial services sector) entered into force in March 2021, Compliance carried out the following activities throughout the year:

• the issuance of an internal Group regulation regarding Information on sustainability in the financial services sector, which aimed to:
  • detail the requirements established by Regulation (EU) 2019/2088, translating them into Group principles and rules
  • define the roles and responsibilities across the Group and its companies with respect to the implementation of the above mentioned requirements and definition of the related processes
• the support to business in terms of advisory on the production and/or distribution of financial instruments and/or products to ensure consistency with ESG sustainability regulations, e.g. SFDR
• in continuity with the past and in accordance with the Bank of Italy Circular no. 285/2013, the specialist supervision relating to the sustainability of UniCredit S.p.A, carries out second-level checks on activities to obtain environmental sustainability certification. Group Compliance subsequently carries out consistency and coherency checks on the work of the specialist supervision and collaborates with it in monitoring the corrective actions opened or in progress and prepares the specific summary report on a quarterly basis.

RISK PRAESIDIUM

To ensure a correct monitoring of the risk of noncompliance with ESG principles, Compliance:

• has provided for the inclusion at Group level of the SFDR in the Compliance Risk Assessment and related second level controls. In particular,
  • a new risk matrix called SFDR was developed with risk scenarios applicable for financial advisors and financial market participants. UniCredit S.p.A. is impacted both as a financial advisor (for the provision of the investment advisory service) and as a participant in financial markets (for the provision of the portfolio management service). The related catalogue of second level SFDR controls was defined and both were shared with all the companies of the Group in order to ensure a correct adoption, in line with local regulations and the business lines of each company, and consequent execution
• carried out consistency and coherency checks on the work of the specialist supervision unit, as mentioned above.

COMPLIANCE CULTURE

Among the main initiatives undertaken by Compliance in 2021 to promote and spread an accurate awareness of ESG principles and related SFDR regulations within the Group, the following are highlighted:

• Compliance Customer Protection Workshop on ESG: a live webinar for all Group colleagues in which experts provided an overview of the evolving regulatory framework of the ESG landscape and the related risks and main challenges associated with the introduction of the concept of sustainability in the world of investments
• Related publication of the news on the internal portal How digitalisation and sustainability are reshaping our Bank, also containing the material shared during the workshop
• as part of the Tone from the Top Programme (aimed at ensuring a correct dissemination of the compliance culture throughout the Group thanks to the involvement of top management at the forefront), a broad sharing of the topics of the workshop was carried out to increase awareness on ESG issues in relation to customer protection
• Compliance Ambassadors: cascading of the initiatives undertaken in relation to Customer Protection in the field of Sustainability and Digitalisation was spread by all the ambassadors (approximately 140) present in the companies of our Group (senior managers of the Group from different company divisions, jointly selected by Group Compliance and People & Culture, with a key role in disseminating and improving Compliance messages throughout the Group).
• Compliance m@tters yammer community: new Compliance communication channel with the aim of promoting risk awareness and insights into compliance issues among the Group's colleagues, including initiatives regarding the introduction of the concept of sustainability in the world of investments and digitalisation.

Furthermore, in addition to the above mentioned initiatives, during 2021 the following web-based mandatory trainings with final tests were rolled out: i) Anti-Money Laundering, ii) Financial Sanctions, iii) Antitrust, iv) GDPR Update - addressed to all employees of the Group - v) Unfair Commercial Practices, for specific targets depending on the roles/activities, vi) Antitrust courses addressed to specific high risk areas identified in the Antitrust Program, in specific legal entities, vii) FS Classrooms for specific targets (Compliance, Markets, Regional Managers & Branch Managers and Trade Finance).

In 2021 UniCredit employees received more than 219,000 hours of Compliance training and in particular more than 9,000 hours of Anti-corruption training.