Communication on Progress 2015

Participant
Published
  • 06-Jul-2016
Time period
  • January 2015  –  December 2015
Files
Format
  • Part of a sustainability or corporate (social) responsibility report
Differentiation Level
  • This COP qualifies for the Global Compact Advanced level
Self-assessment
  • Includes a CEO statement of continued support for the UN Global Compact and its ten principles
  • Description of actions or relevant policies related to Human Rights
  • Description of actions or relevant policies related to Labour
  • Description of actions or relevant policies related to Environment
  • Description of actions or relevant policies related to Anti-Corruption
  • Includes a measurement of outcomes
  • Meets all criteria for the GC Advanced level
Verification
and Transparency
  • How is the accuracy and completeness of information in your COP assessed by a credible third-party?
  • Information is assured by independent assurors (e.g., accounting or consulting firm) against recognized assurance standard (e.g., ISAE3000, AA1000AS, other national or industry-specific standard)

  • Other established or emerging best practices

    Report subject to the limited review of DELOITTE & TOUCHE S.p.A. in accordance with the criteria established in the International Standard on Assurance Engagement 3000 - Assurance Engagements other than Audits or Reviews of Historical Financial Info

  • The COP describes any action(s) that the company plans to undertake by its next COP to have the credibility of the information in its COP externally assessed, including goals, timelines, metrics, and responsible staff

  • Information is reviewed by multiple stakeholders (e.g., representatives of groups prioritized in stakeholder analysis)

  • Information is reviewed by a panel of peers (e.g., members of the same industry, competitors, benchmarked leaders, others organized via Global Compact Local Network)

  • Information is assured by independent assurors (e.g., accounting or consulting firm) using their own proprietary methodology

 
  • The COP incorporates the following high standards of transparency and disclosure:
  • Applies the GRI Sustainability Reporting Guidelines or the GRI Standards

  • Is 'in accordance - core' with GRI Standards

  • Applies elements of the International Integrated Reporting Framework

  • Is 'in accordance - comprehensive' with GRI Standards

  • Provides information on the company’s profile and context of operation

Strategy, Governance
and Engagement
  • Criterion 1: The COP describes mainstreaming into corporate functions and business units
  • Place responsibility for execution of sustainability strategy in relevant corporate functions (procurement, government affairs, human resources, legal, etc) ensuring that no function is conflicting with company sustainability commitments and objectives

  • Assign responsibility for corporate sustainability implementation to an individual or group within each business unit and subsidiary

  • Design corporate sustainability strategy to leverage synergies between and among issue areas and to deal adequately with trade-offs

  • Ensure that different corporate functions coordinate closely to maximize performance and avoid unintended negative impacts

  • Other established or emerging best practices

    Group Sustainability - part of the Group Identity & Communication dept - reports directly to the CEO and is responsible for supporting the management in developing strategies that integrate sustainability considerations into the value creation process.

  • Any relevant policies, procedures, and activities that the company plans to undertake by its next COP to fulfill this criterion, including goals, timelines, metrics, and responsible staff

  • Align strategies, goals and incentive structures of all business units and subsidiaries with corporate sustainability strategy

  • Criterion 2: The COP describes value chain implementation
  • Implement monitoring and assurance mechanisms (e.g. audits/screenings) for compliance within the company’s sphere of influence

  • Undertake awareness-raising, training and other types of capacity building with suppliers and other business partners

  • Other established or emerging best practices

    At UniCredit suppliers must meet minimum sustainability requirements and are selected according to the standards of conventions of the ILO.Suppliers must also comply with the standards set forth in our Environmental Policy (2015 IR p.84)

  • Any relevant policies, procedures, and activities that the company plans to undertake by its next COP to fulfill this criterion, including goals, timelines, metrics, and responsible staff

  • Analyze each segment of the value chain carefully, both upstream and downstream, when mapping risks, opportunities and impacts

  • Communicate policies and expectations to suppliers and other relevant business partners

Human Rights
  • Criterion 5: The COP describes effective monitoring and evaluation mechanisms of human rights integration
  • System to monitor the effectiveness of human rights policies and implementation with quantitative and qualitative metrics, including in the supply chain (BRE3 + ARE3)

  • Monitoring draws from internal and external feedback, including affected stakeholders

  • Leadership review of monitoring and improvement results

  • Process to deal with incidents the company has caused or contributed to for internal and external stakeholders (BRE 4 + ARE 4)

  • Grievance mechanisms that are legitimate, accessible, predictable, equitable, transparent, rights-compatible, a source of continuous learning, and based on engagement and dialogue (BRE4 + ARE4)

  • Outcomes of integration of the human rights principles

  • Other established or emerging best practices

    We monitor the HR Committment effectiveness by leveraging existing monitoring processes linked to the related practices monitored by the owning functions. Eg. Compliance policies include disciplinary actions applied for potential breaches (p. 93 2015 IR)

  • Any relevant policies, procedures, and activities that the company plans to undertake by its next COP to fulfill this criterion, including goals, timelines, metrics, and responsible staff

  • Criterion 3: The COP describes robust commitments, strategies or policies in the area of human rights
  • Commitment to comply with all applicable laws and respect internationally recognized human rights, wherever the company operates (e.g., the Universal Declaration of Human Rights, Guiding Principles on Human Rights) (BRE1 + ARE1)

  • Integrated or stand-alone statement of policy expressing commitment to respect and support human rights approved at the most senior level of the company (BRE 1 + BRE5 + ARE 1 + ARE 5)

  • Statement of policy stipulating human rights expectations of personnel, business partners and other parties directly linked to operations, products or services (BRE 1)

  • Statement of policy publicly available and communicated internally and externally to all personnel, business partners and other relevant parties (BRE 1 + BRE 5 + ARE 1 + ARE 5)

  • Other established or emerging best practices

    See definition since 2011 of our HR Committment updated in 2015 and with a draft action plan to be finalized by 2016, and implementation of our Policy on Gender Equality in 13 countries.

  • Any relevant policies, procedures, and activities that the company plans to undertake by its next COP to fulfill this criterion, including goals, timelines, metrics, and responsible staff

  • Criterion 4: The COP describes effective management systems to integrate the human rights principles
  • Process to ensure that internationally recognized human rights are respected

  • On-going due diligence process that includes an assessment of actual and potential human rights impacts (BRE 2 + BRE 3 + ARE 2 + ARE 3)

  • Internal awareness-raising and training on human rights for management and employees

  • Operational-level grievance mechanisms for those potentially impacted by the company’s activities (BRE 4 + ARE 4)

  • Allocation of responsibilities and accountability for addressing human rights impacts

  • Processes to provide for or cooperate in the remediation of adverse human rights impacts that the company has caused or contributed to (BRE 3+ BRE 4 + ARE3 + ARE 4)

  • Process and programs in place to support human rights through: core business; strategic philanthropic/social investment; public policy engagement/advocacy; partnerships and/or other forms of collective action (BRE 6 + ARE 6)

  • Other established or emerging best practices

    Our approach on Human Rights was reinforced by a special program overseen by the GESC established to support and improve our Environmental and Social strategy. As per our HR Committment almost 13,000 people were trained.(2015IR pag 17)

  • Any relevant policies, procedures, and activities that the company plans to undertake by its next COP to fulfill this criterion, including goals, timelines, metrics, and responsible staff

  • Internal decision-making, budget and oversight for effective responses to human rights impacts

Labour
  • Criterion 6: The COP describes robust commitments, strategies or policies in the area of labour
  • Reference to principles of relevant international labour standards (ILO Conventions) and other normative international instruments in company policies

  • Reflection on the relevance of the labour principles for the company

  • Written company policy to obey national labour law, respect principles of relevant international labour standards in worldwide company operations and engage in dialogue with representative organization of the workers (international, sectoral, national).

  • Inclusion of reference to the principles contained in the relevant international labour standards in contracts with suppliers and other relevant business partners

  • Specific commitments and Human Resources policies, in line with national development priorities or decent work priorities in the country of operation

  • Structural engagement with a global union, possibly via a Global Framework Agreement

  • Participation and leadership by employers’ organizations (international and national) to jointly address challenges related to labour standards in the countries of operation, possibly in a tripartite approach (business – trade union – government).

  • Other established or emerging best practices

    The role of the Diversity Manager was created in 2013 with the approval of the Gender Equality Policy. By the end of 2015 we had 24 people in the job across the Group (pag 65 2015IR)

  • Any relevant policies, procedures, and activities that the company plans to undertake by its next COP to fulfill this criterion, including goals, timelines, metrics, and responsible staff

  • Criterion 8: The COP describes effective monitoring and evaluation mechanisms of labour principles integration
  • System to track and measure performance based on standardized performance metrics

  • Dialogues with the representative organization of workers to regularly review progress made and jointly identify priorities for the future

  • Process to positively engage with the suppliers to address the challenges (i.e., partnership approach instead of corrective approach) through schemes to improve workplace practices

  • Outcomes of integration of the Labour principles

  • Other established or emerging best practices

    In 2014 we implemented ourPolicy on Gender Equality in line with the Joint Declaration on Equal Opportunities and Non Discrimination signed by our Group and the EWC in 2009 (please visit our website unicreditgroup.eu "key milestones section")

  • Any relevant policies, procedures, and activities that the company plans to undertake by its next COP to fulfill this criterion, including goals, timelines, metrics, and responsible staff

  • Audits or other steps to monitor and improve the working conditions of companies in the supply chain, in line with principles of international labour standards

  • Criterion 7: The COP describes effective management systems to integrate the labour principles
  • Risk and impact assessments in the area of labour

  • Dialogue mechanism with trade unions to regularly discuss and review company progress in addressing labour standards

  • Allocation of responsibilities and accountability within the organization

  • Internal awareness-raising and training on the labour principles for management and employees

  • Grievance mechanisms, communication channels and other procedures (e.g., whistleblower mechanisms) available for workers to report concerns, make suggestions or seek advice, designed and operated in line with the representative organization of workers

  • Other established or emerging best practices

    To manage structural changes in our organization and their impacts on our colleagues in a responsible way we support social dialogue with employee representatives at the international level through the European Works Council (EWC) (pg48 Supplement 2015IR)

  • Any relevant policies, procedures, and activities that the company plans to undertake by its next COP to fulfill this criterion, including goals, timelines, metrics, and responsible staff

  • Active engagement with suppliers to address labour-related challenges

Environment
  • Criterion 11: The COP describes effective monitoring and evaluation mechanisms for environmental stewardship
  • System to track and measure performance based on standardized performance metrics

  • Leadership review of monitoring and improvement results

  • Process to deal with incidents

  • Audits or other steps to monitor and improve the environmental performance of companies in the supply chain

  • Outcomes of integration of the environmental principles

  • Other established or emerging best practices

    Under our environmental management systems, we are conducting second party audits of our suppliers and tours of their facilities(https://www.unicreditgroup.eu/en/a-sustainable-bank/our-capitals/natural-capital/environmental-management-system-.html)

  • Any relevant policies, procedures, and activities that the company plans to undertake by its next COP to fulfill this criterion, including goals, timelines, metrics, and responsible staff

  • Criterion 10: The COP describes effective management systems to integrate the environmental principles
  • Environmental risk and impact assessments

  • Assessments of lifecycle impact of products, ensuring environmentally sound management policies

  • Allocation of responsibilities and accountability within the organisation

  • Internal awareness-raising and training on environmental stewardship for management and employees

  • Grievance mechanisms, communication channels and other procedures (e.g. whistleblower mechanisms) for reporting concerns or seeking advice regarding environmental impacts

  • Other established or emerging best practices

    Environmental Management Systems across the Group ensure the implementation of environmental programs in order to reduce impacts related to our operations and lending practices (ref to pag. 83-84 2015IR).

  • Any relevant policies, procedures, and activities that the company plans to undertake by its next COP to fulfill this criterion, including goals, timelines, metrics, and responsible staff

  • Criterion 9: The COP describes robust commitments, strategies or policies in the area of environmental stewardship
  • Reference to relevant international conventions and other international instruments (e.g. Rio Declaration on Environment and Development)

  • Reflection on the relevance of environmental stewardship for the company

  • Written company policy on environmental stewardship

  • Inclusion of minimum environmental standards in contracts with suppliers and other relevant business partners

  • Specific commitments and goals for specified years

  • Other established or emerging best practices

    We are committed to acting responsibly related to procurement activities.(https://www.unicreditgroup.eu/content/dam/unicreditgroup-eu/documents/en/sustainability/environment-suppliers/environmental-management-system/Environmental_Commitment-160615.pdf)

  • Any relevant policies, procedures, and activities that the company plans to undertake by its next COP to fulfill this criterion, including goals, timelines, metrics, and responsible staff

Anti-Corruption
  • Criterion 13: The COP describes effective management systems to integrate the anti-corruption principle
  • Support by the organization’s leadership for anti-corruption (B4)

  • Carrying out risk assessment of potential areas of corruption (D3)

  • Human Resources procedures supporting the anti-corruption commitment or policy, including communication to and training for all employees (B5 + D8)

  • Internal checks and balances to ensure consistency with the anti-corruption commitment (B6)

  • Actions taken to encourage business partners to implement anti-corruption commitments (D6)

  • Management responsibility and accountability for implementation of the anti-corruption commitment or policy (D7)

  • Communications (whistleblowing) channels and follow-up mechanisms for reporting concerns or seeking advice (D9)

  • Internal accounting and auditing procedures related to anticorruption (D10)

  • Other established or emerging best practices

    Mechanisms to effectively manage:escalation procedures, quarterly management information requested from hub entities(Italy, Germany, Austria, Poland);Compliance Risk Assessment processes performed for each regulatory area in all legal entities (supp pg32)

  • Any relevant policies, procedures, and activities that the company plans to undertake by its next COP to fulfill this criterion, including goals, timelines, metrics, and responsible staff

  • Criterion 14: The COP describes effective monitoring and evaluation mechanisms for the integration of anti-corruption
  • Leadership review of monitoring and improvement results (D12)

  • Process to deal with incidents (D13)

  • Outcomes of integration of the anti-corruption principle

  • Other established or emerging best practices

    Mechanisms to effectively monitor: quarterly management information requested and periodically (at least once a year) report to BoD.

  • Any relevant policies, procedures, and activities that the company plans to undertake by its next COP to fulfill this criterion, including goals, timelines, metrics, and responsible staff

  • Public legal cases regarding corruption (D14)

  • Use of independent external assurance of anti-corruption programmes (D15)

  • Criterion 12: The COP describes robust commitments, strategies or policies in the area of anti-corruption
  • Publicly stated formal policy of zero-tolerance of corruption (D1)

  • Commitment to be in compliance with all relevant anti-corruption laws, including the implementation of procedures to know the law and monitor changes (B2)

  • Detailed policies for high-risk areas of corruption (D4)

  • Policy on anti-corruption regarding business partners (D5)

  • Other established or emerging best practices

    UniCredit has zero tolerance towards acts of corruption, prohibts facilitation payments and does not permit any transfer of value to pubblic officals without approval, also forbids political donations (Supp. pg 32-33 2015IR)

  • Any relevant policies, procedures, and activities that the company plans to undertake by its next COP to fulfill this criterion, including goals, timelines, metrics, and responsible staff

  • Statement of support for international and regional legal frameworks, such as the UN Convention against Corruption (D2)

UN Goals and Issues
  • Criterion 16: The COP describes strategic social investments and philanthropy
  • Pursue social investments and philanthropic contributions that tie in with the core competencies or operating context of the company as an integrated part of its sustainability strategy

  • Coordinate efforts with other organizations and initiatives to amplify—and not negate or unnecessarily duplicate—the efforts of other contributors

  • Take responsibility for the intentional and unintentional effects of funding and have due regard for local customs, traditions, religions, and priorities of pertinent individuals and groups

  • Other established or emerging best practices

    The UC Foundations deal with philantropy/social innovation and support young generations, in parnterships and joint actions with other companies/institutions (pag 78-79 2015IR)

  • Any relevant policies, procedures, and activities that the company plans to undertake by its next COP to fulfill this criterion, including goals, timelines, metrics, and responsible staff

  • Criterion 17: The COP describes advocacy and public policy engagement
  • Publicly advocate the importance of action in relation to one or more UN goals/issues

  • Commit company leaders to participate in key summits, conferences, and other important public policy interactions in relation to one or more UN goals/issues

  • Other established or emerging best practices

    CEO commitment to UN Global Compact support (pag 5 2015IR) and - in general - company commitments to issues related to labor, anti-corruption, human rights and environment. Among others, Group CEO formally endorses Natural Capital Declaration

  • Any relevant policies, procedures, and activities that the company plans to undertake by its next COP to fulfill this criterion, including goals, timelines, metrics, and responsible staff

  • Criterion 15: The COP describes core business contributions to UN goals and issues
  • Align core business strategy with one or more relevant UN goals/issues

  • Develop relevant products and services or design business models that contribute to UN goals/issues

  • Adopt and modify operating procedures to maximize contribution to UN goals/issues

  • Other established or emerging best practices

    UniCredit promotes social inclusion and helps communities thrive through our colleagues' volunteer efforts and our Group's long term commitments to and cooperation with non profit entities (pag 78 2015IR)

  • Any relevant policies, procedures, and activities that the company plans to undertake by its next COP to fulfill this criterion, including goals, timelines, metrics, and responsible staff

  • Criterion 18: The COP describes partnerships and collective action
  • Develop and implement partnership projects with public or private organizations (UN entities, government, NGOs, or other groups) on core business, social investments and/or advocacy

  • Join industry peers, UN entities and/or other stakeholders in initiatives contributing to solving common challenges and dilemmas at the global and/or local levels with an emphasis on initiatives extending the company’s positive impact on its value chain

  • Other established or emerging best practices

    Main partnerships and affiliations , supp 2015IR pag 4-5

  • Any relevant policies, procedures, and activities that the company plans to undertake by its next COP to fulfill this criterion, including goals, timelines, metrics, and responsible staff

Governance
  • Criterion 19: The COP describes CEO commitment and leadership
  • CEO leads executive management team in development of corporate sustainability strategy, defining goals and overseeing implementation

  • CEO publicly delivers explicit statements and demonstrates personal leadership on sustainability and commitment to the UN Global Compact

  • CEO promotes initiatives to enhance sustainability of the company’s sector and leads development of industry standards

  • Make sustainability criteria and UN Global Compact principles part of goals and incentive schemes for CEO and executive management team

  • Other established or emerging best practices

    Compensation policy aligns business needs and sustainable goals.Goal setting process for Group executives based on specific guidelines for performance management (https://www.unicreditgroup.eu/en/governance/compensation.html?topmenu=INT-TM_GOV9_en031)

  • Any relevant policies, procedures, and activities that the company plans to undertake by its next COP to fulfill this criterion, including goals, timelines, metrics, and responsible staff

  • Criterion 21: The COP describes stakeholder engagement
  • Publicly recognize responsibility for the company’s impacts on internal and external stakeholders

  • Define sustainability strategies, goals and policies in consultation with key stakeholders

  • Consult stakeholders in dealing with implementation dilemmas and challenges and invite them to take active part in reviewing performance

  • Establish channels to engage with employees and other stakeholders to hear their ideas and address their concerns

  • Other established or emerging best practices

    Stakeholder engagement pagg 26-27 2015IR and Social and Relationship Suppl to 2015IR pagg 58 to 61

  • Any relevant policies, procedures, and activities that the company plans to undertake by its next COP to fulfill this criterion, including goals, timelines, metrics, and responsible staff

  • Criterion 20: The COP describes Board adoption and oversight
  • Board of Directors (or equivalent) assumes responsibility and oversight for long-term corporate sustainability strategy and performance

  • Board (or committee), where permissible, approves formal reporting on corporate sustainability (Communication on Progress)

  • Other established or emerging best practices

    We established the Group Environmental and Social Council (GESC) to oversee the implementation of UniCredit’s environmental and social initiatives and commitments in cooperation with all relevant counterparts (pag 11;17;82 2015IR)

  • Any relevant policies, procedures, and activities that the company plans to undertake by its next COP to fulfill this criterion, including goals, timelines, metrics, and responsible staff

  • Board establishes, where permissible, a committee or assigns an individual board member with responsibility for corporate sustainability.

Women's Empowerment
  • The COP describes policies and practices related to supporting women's empowerment and advancing gender equality in the workplace
  • Achieving and maintaining gender equality in senior management and board positions

  • Achieving and maintaining gender equality in middle management positions

  • Equal pay for work of equal value

  • Flexible work options

  • Access to child and dependent care

  • Support for pregnant women and those returning from maternity leave

  • Recruitment and retention, including training and development, of female employees

  • Gender-specific health and safety issues

  • Education and training opportunities for women workers

  • Creating and maintaining workplace awareness of gender equality and, inclusion and non-discrimination for all workers

  • Mentoring and sponsorship opportunities for women workers

  • Other established or emerging best practices

    Our Gender Balance Program received a further boost in 2015 with the CEO signing the Statement of Support for the UN Women's Empowerment Principles - please refer to pag 65 of our 2015 Integrated Report

  • Gender-based violence and harassment

  • No practice for this criterion has been reported

  • Any relevant policies, procedures, and activities that the company plans to undertake by its next COP to address this area, including goals, timelines, metrics, and responsible staff

  • The COP describes policies and practices related to supporting women's empowerment and advancing gender equality in the marketplace
  • Support for women business owners and women entrepreneurs

  • Supplier monitoring and engagement on women's empowerment and gender equality including promotion of the Women's Empowerment Principles to suppliers

  • Gender-sensitive marketing

  • Gender-sensitive product and service development

  • Other established or emerging best practices

    In our Global Policy on Gender Equality we state that each Legal Entity will also have to circulate the document to its suppliers and subcontractors

  • Supplier diversity programme

  • Composition of supplier base by sex

  • No practice for this criterion has been reported

  • Any relevant policies, procedures, and activities that the company plans to undertake by its next COP to address this area, including goals, timelines, metrics, and responsible staff

  • The COP contains or refers to sex-disaggregated data
  • Achieving and maintaining gender equality in senior management and board positions

  • Achieving and maintaining gender equality in middle management positions

  • Equal pay for work of equal value

  • Recruitment and retention, including training and development, of female employees

  • Education and training opportunities for women workers

  • Mentoring and sponsorship opportunities for women workers

  • Other established or emerging best practices

    Please refer to the 2015 Supplement to the 2015 Integrated Report (Human Capital section)

  • Flexible work options

  • Access to child and dependent care

  • Support for pregnant women and those returning from maternity leave

  • Gender-specific health and safety issues

  • Gender-based violence and harassment

  • Creating and maintaining workplace awareness of gender equality and, inclusion and non-discrimination for all workers

  • No practice for this criterion has been reported

  • Any relevant policies, procedures, and activities that the company plans to undertake by its next COP to address this area, including goals, timelines, metrics, and responsible staff

  • The COP describes policies and practices related to supporting women's empowerment and advancing gender equality in the community
  • Designing community stakeholder engagements that are free of gender discrimination/stereotyping and sensitive to gender issues

  • Gender impact assessments or consideration of gender-related impacts as part of its social and/or human rights impact assessments

  • Ensuring female beneficiaries of community programmes

  • Community initiatives specifically targeted at the empowerment of women and girls

  • Other established or emerging best practices

    In Germany in 2015 we offered mentoring programs for startups run by experienced businesswomen from the HVB Women’s Council and startup experts from the bank to encourage new entrepreneurial ventures by women (pag 77 2015IR)

  • Strategies to ensure that community investment projects and programmes (including economic, social and environmental) positively impact women and girls

  • Strategies to ensure that community investment projects and programmes (including economic, social and environmental) include the full participation of women and girls

  • No practice for this criterion has been reported

  • Any relevant policies, procedures, and activities that the company plans to undertake by its next COP to address this area, including goals, timelines, metrics, and responsible staff