Banca Generali

Banca Generali S.p.A. uses the traditional governance model with a Shareholders' Meeting, Board of Directors and Board of Statutory Auditors. The Board, appointed on 18 April 2024, has 9 members: 3 Non-Independent Directors (including the Chairperson and the CEO) and 6 Independent Directors (66.7%). Gender split is 5 male (55.6%) and 4 female (44.4%). Five Board committees operate: Remuneration, Nomination and Governance, Sustainability and Innovation, Internal Audit and Risk, and Credit. The Board of Statutory Auditors has three Acting and two Alternate Auditors (2 male, 40%; 3 female, 60%). The CEO, who is also General Manager, holds managing functions and is supported by the Managing Committee, which oversees sustainability at Banking Group level. Since 2018 the General Counsel and Sustainability Area has been responsible for sustainability matters through a hybrid organisational model. Board members received ESG induction, and a Sustainability Policy was approved on 21 June 2024 and updated 19 December 2024. The double materiality outcome was approved by the Board on 7 November 2024 after the Sustainability and Innovation Committee's opinion.

The Board of Directors and Board Committees receive regular updates on sustainability matters through reports including performance analyses and indicators tied to individual impacts, risks and opportunities. In 2024, in line with Bank of Italy supervisory expectations, the frequency, content and owners of two ESG reports, the Sustainability Dashboard and the Climate Risk Assessment, were formalised in the Rules on information flows to Corporate Bodies. The Sustainability Dashboard serves the Managing Committee, the Sustainability and Innovation Committee and the Board for half-year monitoring of ESG KPIs. The Climate Risk Assessment is an annual presentation to the Board on the financial materiality of climate and environmental risks (heatmap). The Tableau de Bord, presented quarterly by the Chief Risk Officer, includes ESG indicators and goes to the Board, the Internal Audit and Risk Committee and the Board of Statutory Auditors. In 2024 the Board resolved on the Action Plan for climate and environmental risks and the Sustainability Policy update. An induction on CSRD, double materiality, Taxonomy, SFDR and ESG risks was held in October 2024. A table maps 2024 sustainability topics (Strategy, Policies, ESG risk, DEI, Monitoring, ESG induction, Remuneration) across committees.

Sustainability is integrated into the Banking Group's remuneration and incentive strategy. The 2024 Remuneration Policy is linked to the 2022-2024 Strategic Plan, which counts sustainability among its objectives. The Bank uses short- and long-term incentive systems supported by performance management, applying a risk-adjusted remuneration structure that discourages excessive risk-taking, including on sustainability risks. The CEO/General Manager's Balanced Scorecard mixes financial and non-financial objectives; ESG objectives account for 20% of the overall scorecard, split as People Value (10%) and Sustainability Commitment (10%). Sustainability Commitment covers four pillars: sustainable products, sustainable processes, sustainable plans and sustainable people. The Long-Term Incentive Plan links vesting to Banking Group objectives with weights of 40% tROE, 40% Adjusted EVA and 20% a sustainability index (ESG AUM 15% and average rating 5%); maximum performance is 100% for Top Managers and 87.5% for other beneficiaries. Incentive schemes are revised annually. Members of the Board of Directors and Board of Statutory Auditors receive fixed remuneration plus an attendance fee and no variable pay, so sustainability objectives do not directly affect their remuneration.

In its Sustainability Policy, Banca Generali Group has formalised a Sustainability Framework to identify, assess and manage the impacts, risks and opportunities associated with ESG factors, together with supporting elements including the governance model, internal regulations, the risk framework, remuneration, monitoring and reporting. The disclosure maps the core elements of due diligence to sections of the Sustainability Statement. Embedding due diligence in governance, strategy and business model maps to GOV-2, GOV-3 and SBM-3. Engaging with affected stakeholders maps to GOV-1, GOV-2, SBM-2 and IRO-1. Identifying and assessing adverse impacts maps to IRO-1, SBM-3 and the topical SBM-3 and IRO-1 sections for E1, S1, S4, G1 and the entity-specific topic. Taking actions to address adverse impacts and tracking effectiveness map to the paragraphs on actions and on each material topic (E1, S1, S4, G1 and the entity-specific topic). The Sustainability Policy of the Banca Generali Banking Group is referenced throughout as the underlying framework.

From 2019 to 2023 the Parent Company managed non-financial reporting data in line with existing financial reporting procedures under Italian Law 262/2005, introducing Organisational Procedures with data control points; checks were non-independent and relied on evidence from the data owner. Since September 2024, following transposition of the CSRD via Legislative Decree 125, which assigns responsibilities to the Manager in Charge of preparing the Company's financial reports, Banca Generali launched a data quality process for the Sustainability Statement, integrating existing Organisational Procedures and sharing the Insurance Parent Company's control framework. Procedures used for 2023 reporting were included in the Risk Control Matrix. An independent third party tested control design and application, including a walk-through analysis. Sustainability Reporting Risks (SRR) are managed similarly to Financial Reporting Risks (FRR). At least once a year, upon publication of the Annual Integrated Report, the Manager in Charge, supported by the Law 262 OU, reports on activities and controls to the Board of Statutory Auditors. In 2025 all non-financial Organisational Procedures will be revised. The reporting and testing scope is updated each year following the Double Materiality Analysis.

Banca Generali is an Italian private bank and wealth manager focused on investment services, financial advisory and wealth management for HNW, Private and Affluent customers, mainly in Italy through its BG Network. At end-2024 it reached 359,000 customers and 103.8 billion euro AUM, with Private Customers accounting for 73.5 billion euro of the Private Banking segment. The BG Network comprises 2,353 professionals across Financial Advisor types (including 62 Relationship Managers), and the Bank has 1,104 employees; together they form the Own Workforce. The value chain is split into Upstream operational activities (suppliers, IT and financial providers, partners), Core operational activities (own workforce) and Downstream business activities (investments, holistic advisory, customers, communities and future generations). Services include banking, assets under administration, asset management (open architecture plus Luxembourg Sicavs), insurance investments and wealth management and trust services. The Bank is part of the Assicurazioni Generali Group and relies on Group companies (BG Fund Management Luxembourg, Generfid, BG Suisse Private Bank, BG Valeur). It acquired Intermonte SIM and in 2024 adopted Guidelines on Integrating Sustainability Factors into Investment Services.

Banca Generali engages with numerous stakeholders, defined as parties that can influence or be influenced by its activities. Stakeholder prioritisation follows the AccountAbility 1000 (AA1000) standard using five criteria: Responsibility, Influence, Proximity, Representation and Strategy. The main stakeholders identified are: Banca Generali Group Employees; the BG Network; national, international and financial-sector institutions; Shareholders; Supervisory authorities and rating agencies; Customers; Suppliers; financial and non-financial strategic partners; and Communities. The Group distinguishes two engagement types: stakeholder engagement, which gathers contributions for the Double Materiality Analysis, and active engagement, which identifies needs and expectations, anticipates operational and reputational risks, monitors satisfaction and seizes new opportunities. Active engagement activities are described per category, for example periodic engagement surveys and union roundtables for employees, ESG focus groups and conventions for Financial Advisors, satisfaction surveys and consumer association dialogue for customers, and university partnerships and DEI initiatives for communities. Shareholder engagement includes the General Meeting, quarterly reports, Capital Market Days, roadshows and regular meetings with the majority shareholder. Results of active engagement feed strategy definition. This section meets the SBM-2 requirements included in S1 and S4.

In 2024 Banca Generali Group conducted a Double Materiality Analysis across its whole value chain, assessing impacts on people and the environment (inside-out) and the financial materiality of ESG factors (outside-in) for each of the ten ESG topical standards. The analysis identified 9 material topics: 2 environmental, 4 social and 3 governance sub-topics. Priority topics are climate change mitigation, enhancement of Human Capital, enhancement of Financial Advisors, cybersecurity and customer data protection, and wealth protection and value of service. Material topical standards are E1 Climate change, S1 Own workforce (enhancement of Human Capital), S4 Consumers and end-users (quality of information, cybersecurity and data protection), G1 Business conduct (corporate culture), plus an entity-specific social topic on wealth protection and value of service. A value-chain IRO table maps each sub-topic to positive or negative impacts, risks or opportunities, and short, medium or long time horizons. Social and governance IROs relate mainly to Core Operational Activities, while climate change and value of service IROs sit in Downstream Business Activities; a key negative impact is potential loss of value of managed portfolio assets due to climate change.

Banca Generali Group conducted a Double Materiality Analysis under the CSRD and ESRS, using EFRAG implementation guidance. The updated analysis covers financial materiality (risks and opportunities affecting financial performance) and an in-depth value chain assessment of impacts, risks and opportunities. Two impact perspectives were applied: an Operational Activities perspective (Upstream and Core, using sources such as GRI and SASB) and a Business Activities perspective (quantitative analysis of the investment portfolio by issuer sector via NACE codes). The process had three phases. Phase 1, preliminary analysis to identify IROs, drew on the reference context, Italian credit institution disclosures and regulations (Bank of Italy expectations, Fit for 55, EU Action Plan for Sustainable Finance). Phase 2, IRO assessment, evaluated impact severity and likelihood using UNEP FI (Irremediability Map), with internal ESG experts and validation against MSCI and S&P Global Ratings; risks and opportunities were scored by the Risk Management Function against Risk Appetite Framework categories, followed by stakeholder engagement to prioritise. Phase 3 aggregated results and obtained Board approval on 7 November 2024. E2, E3, E4 and E5 were analysed but no material IROs were detected.

This disclosure is the content index of the Sustainability Statement. Following the Double Materiality Analysis, Banca Generali identified material impacts, risks and opportunities for climate change (ESRS E1), own workforce (ESRS S1), consumers and end-users (ESRS S4) and business conduct (ESRS G1), plus one entity-specific topic not covered by the sector-agnostic standards (wealth protection and value of service). Material topics were cross-referenced to the disclosure requirements in each standard, and datapoints for metrics not applicable or not material were excluded so as to keep the document usable. A tabular content index lists all ESRS 2 general disclosures (BP-1, BP-2, GOV-1 to GOV-5, SBM-1 to SBM-3, IRO-1, IRO-2) and the topical requirements, with the status of each disclosure requirement, cross-references to Pillar 3, the Benchmark Regulation and EU Climate Law, datapoints deriving from other EU legislation per ESRS 2 Appendix B, and reference pages. For SBM-1 it is specified that Banca Generali's core activities are not linked to the sectors in ESRS 2, SBM-1, para. 40(d), such as fossil fuel, chemicals, controversial weapons and tobacco.

Banca Generali reports a transition plan for climate change mitigation. In June 2024 the Board approved an integration to its Action Plan defining a net-zero climate plan with interim 2030 targets, and on 10 February 2025 it approved a Climate Transition Plan identifying decarbonisation levers and medium/long-term targets. The Plan sets interim and long-term decarbonisation targets to be reached by 2030 and 2040 respectively, aims to align the business model with limiting global warming to 1.5C in line with the Paris Agreement, and commits to a coal phase-out by 2030 with a net-zero target by 2040. It acknowledges it has not yet implemented a science-based reduction trajectory but aims to build a science-based data framework over five years. Levers include internal regulation on sustainable finance, transition-focused products, ESG data monitoring, engagement with investees and suppliers, training and new technologies. Against the 2019 baseline, at 31 December 2024 it reports a 29% reduction of absolute Scopes 1 and 2 operational emissions (market-based) and a 51% reduction of the investment carbon footprint (Scopes 1 and 2 of corporate issuers, per million euros invested).

Banca Generali reports policies related to climate change mitigation and adaptation. It cites its Policy for the Environment and Climate introduced in 2018, and in June 2024 the Board approved environmental and climate-related principles within the Sustainability Policy, consistent with commitments under the UN Global Compact and aligned with the UN Sustainable Development Goals. For mobility, its Guidelines on Business Trips and Travel encourage less polluting public transport such as trains over planes, although no specific mobility targets are set. For investments, the Guidelines on Integrating Sustainability Factors into Investment Services, Collective Asset Management and Active Ownership, adopted in July 2024, integrate ESG criteria through an ESG score capturing climate mitigation and adaptation performance, apply counterparty and asset-manager controls, and set an active ownership approach exercising voting rights on climate resolutions and GHG disclosure. The Group commits to mitigating principal adverse impacts (PAIs) including GHG-related indicators, and incorporates ESG factor analysis into the corporate lending process covering physical and transition risk.

Banca Generali reports actions and resources in relation to climate change policies, framed around the Climate Transition Plan and its decarbonisation levers. In 2024 it strengthened internal regulations, updating the Sustainability Policy in June and introducing restrictions on Oil and Gas companies using unconventional extraction methods such as tar sands. It reports promoting ESG products, reaching and exceeding its 2022-2024 Strategic Plan target of a 40% ratio of ESG products to total managed solutions at the end of 2024. Other actions include launching a project to map non-financial KPIs and monitor CO2 emissions, completing the first year of engagement with investee companies, extensive climate-related people training, deployment of new technologies including generative AI programmes, confirmation of the Next Normal hybrid working model with office closures on Fridays and around holidays, and a sustainable approach to the branch and advisor office logistics network. The Group states it has allocated a multi-year budget for implementing the Transition Plan.

Banca Generali reports quantified GHG targets against a 2019 base year. For Investments, the main emissions source, the Climate Transition Plan sets a target to reduce the investment carbon footprint (Scopes 1 and 2 emissions per million euros invested) by 55% versus 2019 by 2030, then reach net zero by 2040; the metric moves from 108 tCO2eq per EUR million in 2019 (100%) to 53 in 2024 (-51%) with a 2030 target of 48 (-55%). A coal phase-out by 2030 is also set for this scope, supported by restrictions on carbon-intensive and unconventional Oil and Gas companies. For Operational Activities, a residual source, a medium-term target of -40% by 2030 is set on absolute Scopes 1 and 2 emissions in tCO2eq, with net zero by 2040 and the possibility of offsetting residual emissions through carbon credits from 2030; the metric moves from 628 tCO2eq in 2019 (100%) to 444 in 2024 (-29%), with a 2030 target of 377 (-40%). The carbon footprint is calculated using MainStreet Partners data.

Banca Generali reports gross Scopes 1, 2, 3 and total GHG emissions following the GHG Protocol Corporate Standard, covering CO2, CH4 and N2O expressed in CO2eq, with data collected via the Sphera software for its Milan (Generali Hadid Tower) and Trieste head offices, which host 73% of the workforce. For 2024 versus 2023: gross Scope 1 was 325.1 tCO2eq (from 432.6, -24.86%); gross location-based Scope 2 was 595.2 tCO2eq (from 643.2, -7.47%) and market-based Scope 2 was 119.3 tCO2eq (from 141.9, -15.92%). Total gross indirect Scope 3 emissions were 964,243.4 tCO2eq (from 961,716.5, +0.26%), of which Category 15 Investments (financed emissions of corporate and government portfolios, calculated using EVIC-based attribution and the PCAF protocol for sovereigns) accounted for 963,806.0 tCO2eq (from 961,254.0). Five Scope 3 categories were assessed as material (Categories 1, 3, 5, 6 and 15); the others were deemed not material. Total GHG emissions were 964,687.8 tCO2eq market-based and 965,163.7 location-based for 2024.

Banca Generali addresses GHG removals and mitigation projects financed through carbon credits. It states that, in line with its Sustainability Policy and first Transition Plan, it monitors GHG emissions from direct and indirect activities and implements specific decarbonisation levers, but that to date these actions do not include removal or storage of emissions. Consistent with its E1-4 target for Operational Activities, the Bank foresees the possibility of offsetting residual operational emissions through the purchase of carbon credits starting from 2030. No GHG removals or carbon credits are reported for the 2024 reporting year.

Banca Generali reports policies related to its own workforce (employees) anchored in the BG People Strategy 2022-2024, of which 2024 was the third and final year, structured around Culture, Diversity Equity and Inclusion, Skills and Organization. The Banking Group operates in Italy, Luxembourg and Switzerland and commits to the UN Universal Declaration of Human Rights, ILO Conventions, the UN Global Compact and the European Social Charter, rejecting forced and child labour, harassment, mobbing and discrimination and recognising freedom of association and collective bargaining. Key instruments include the Internal Code of Conduct, the Sustainability Policy, the DEI Guidelines Circular, the General Principles for Gender Equality and the Whistleblowing Policy. In 2024 Banca Generali S.p.A. obtained Gender Equality Certification under UNI/PdR 125:2022, formalised by RINA, and set up an Operating DEI Committee with a Three-year Gender Equality Strategic Plan. The gender-neutral Remuneration Policy and a workplace accident prevention framework under Legislative Decree No. 81/08 are also described.

Banca Generali describes its processes for engaging with employees. It considers listening and engagement strategic tools. In October 2024 it conducted the fifth edition of the Generali Global Engagement Survey (GGES), a triennial listening tool, complemented by the annual Generali Global Pulse Survey. An initial GGES report was delivered in October 2024 with first results presented in December 2024 and next activities outlined. Engagement outcomes feed managers' annual scorecards. Engagement is also pursued through trade union relations and dialogue with workers' representatives.

Banca Generali reports channels for own workers to raise concerns and processes to remediate negative impacts. The Bank adopted a Whistleblowing Policy in 2023 and updated it in 2024; it is publicly available on the corporate website. All reports are processed with the highest confidentiality and personal data protection, and whistleblowers acting in good faith are protected against retaliation, discrimination or penalisation. The Bank provides formal, well-founded responses and feedback within appropriate timing set by the Policy, conducts professional investigations respecting rights of defence, and monitors corrective measures to ensure implementation on agreed timescales. Breaches of high severity must be reported immediately to Top Managers. Employees are informed about internal whistleblowing channels through communication and training initiatives.

Banca Generali describes actions on material impacts, structured around Diversity, Equity, Inclusion and Ecosystem, with a 2024 DEI Strategy. Initiatives focus on generations (under 35) and gender: selection processes ensure at least 25% female short-listed candidates and target over 50% new hires under 35. Programmes include Do You Speak Inclusion (five vertical sessions), women's empowerment courses, and a 25 November 2024 webinar on violence against women attended by over 370 people. The Bank signed the ABI Women's Charter, Women&Tech and the UN Women's Empowerment Principles. Work-life balance measures include the Smart Working Next Normal model extended to 31 March 2025 with up to 12 remote days per month and three per week, a 400 euro gross one-off bonus in 2024, paternity leave increased from 10 to 12 days, flexible hours, mandatory part-time options, and Quiet Rooms in Milan, Mogliano Veneto and Trieste. Benefits include welfare credit, preferential-rate mortgages with a 3.25% rate cap, healthcare and supplementary pensions.

Banca Generali reports targets for its own workforce, set within the 2022-2024 Strategic Plan which included employees among main stakeholders for the first time. Three KPIs were defined: 50% of hires under 35, 75% of employees involved in projects on digital transformation and sustainability impact, and 100% of employees in hybrid work (excluding front office and sales). At the end of 2024 achievements were: 60% of hires under 35; 95% of employees involved in sustainability-related initiatives and 99% in digital-related initiatives; and 100% of employees eligible for hybrid work. Efficacy is monitored through quantitative indicators on training participation, engagement, DEI, workforce composition and health and safety, some included in the Sustainability Dashboard.

At 31 December 2024 Banca Generali had 1,104 employees (573 male, 531 female), a net increase of 39 versus 1,065 in 2023. By geography, 1,020 were in Italy and 84 abroad, so 92% worked in Italy and 8% in Luxembourg and Switzerland. By contract type, 1,054 held permanent contracts (95% of the workforce) and 50 fixed-term; there were no non-guaranteed-hours employees. By working time, 1,055 were full-time and 49 part-time (45 female, 4 male). Over the 2022-2024 period the headcount rose by 82, including 91 contracts transformed from fixed to permanent (36 in 2024, 17 in 2023). Combined Italy and abroad turnover in 2024 showed 124 hirings and 84 terminations, with a positive turnover rate of 11% and a negative turnover rate of 8%. Turnover figures include intra-group transfers and maternity-leave replacements.

Banca Generali reports on non-employee workers within its own workforce. At 31 December 2024 there were 4 non-employee workers (3 male, 1 female), up from 3 (2 male, 1 female) in 2023. The Bank states it sometimes uses non-employee workers to deal with peak workloads or specific projects, and notes these workers are included in its own workforce but not counted among employees.

Banca Generali reports collective bargaining coverage and social dialogue. In Italy 100% of employees are subject to the National Collective Labour Agreement (CCNL) for the Credit sector or for Credit Managers, with 1,021 employees covered (100%) at 31 December 2024 versus 991 in 2023. Employees of BGFML, BG Valeur S.A. and BG Suisse Private Bank S.A. are covered by local legislation. Workplace representation in Italy covered 346 employees (34%) in 2024 versus 330 (33%) in 2023. The CCNL for the Credit sector renewal was signed on 23 November 2023 by ABI and national trade unions and is valid until 31 March 2026, featuring an approximately 15% increase in contractual minimums over 2023-2026 and a reduction to 37 weekly working hours for Employees. Supplementary company bargaining (CIA) expired in June 2024 and continues in ultra-activity pending renewal negotiations starting in 2025.

Banca Generali reports diversity metrics. At 31 December 2024, by professional position: 78 Managers (63 male, 15 female), 397 Executives (240 male, 157 female) and 629 Employees (270 male, 359 female), totalling 1,104 (52% male, 48% female). Women held 36% of positions of responsibility (Managers and Executives), in line with 36% in 2023. By age: 98 employees under 30 (9%), 631 aged 30-50 (57%) and 375 over 50 (34%); the workforce average age was 45 (Managers 53, Executives 48, Employees 42). The 3 Top Managers, namely the Chief Executive Officer/General Manager and two Deputy General Managers, are all male (100%).

Banca Generali reports on adequate wages. All employees of Banca Generali S.p.A. and Generfid S.p.A. are ensured at least the wages and remuneration provided by the National Collective Labour Agreement (CCNL) for the Credit sector or for Credit Managers, thereby complying with the principle of Article 36 of the Italian Constitution on remuneration ensuring a free and dignified existence. Employees at the Luxembourg and Switzerland subsidiaries earn adequate remuneration benchmarked to the specific legal provisions or collective bargaining agreements in force in those countries, such as the law of the Canton of Ticino in Switzerland.

Banca Generali reports on social protection. The legislation of the countries where Group companies are located provides mandatory social protection against loss of income due to sickness, unemployment, employment injury, parental leave and retirement. For employees based in Italy (Banca Generali S.p.A. and Generfid S.p.A.) additional measures include healthcare reimbursements for expenses such as major surgery, hospitalisation, dental, specialist and oncology treatment; a supplementary pension via Generali Group pension funds; an economic indemnity for death, permanent total disability and dread disease calculated on age, remuneration and family composition; a professional accident policy covering death and permanent total disability; and Long-Term Care benefits for employees who are no longer self-sufficient.

Banca Generali reports the share of employees with disabilities. At 31 December 2024 employees with disabilities represented 4% of the total own workforce (5% of female employees and 4% of male employees), unchanged from 4% (5% female, 4% male) at 31 December 2023.

Banca Generali reports training and skills development metrics. In 2024 a total of 70,749 training hours were delivered, up 9.7% versus 65,995 in 2023, of which 1,406 hours were provided to young interns. Average training hours per employee rose to 63 (61 in 2023): 62 for female and 64 for male employees, 96 per Manager, 68 per Executive and 55 per Employee. Programmes are open to the entire population including part-time employees, fixed-term contracts and interns, covering regulatory and safety training, technical skills (Power BI, AI-powered Copilot Edge), and managerial and behavioural skills. Named initiatives include Digital Minds, the AI Ambassador Program (31 colleagues, with Microsoft), Motivation@Work and MAP Forward. On performance assessment, in 2024 the share of eligible employees who underwent a performance review was 99% of women and 100% of men overall, with Employees at 100% for both genders.

Banca Generali reports health and safety metrics. In 2024 there were 6 accidents in Italy, involving 1 woman and 5 men, of which 5 occurred while commuting and were not work-related. The number of work days lost to work-related accidents was 5. The rate of recordable work-related accidents was 0.56 in 2024 (0.00 in 2023), calculated as recordable work-related accidents divided by worked hours multiplied by 1,000,000. There were no fatalities and no cases of permanent disability or occupational diseases. Under Legislative Decree No. 81/2008, 100% of employees of Banca Generali S.p.A. and Generfid S.p.A. are covered by general measures to protect workers' health and safety. The Risk Assessment Document underwent its eighth revision on 9 December 2024, including a new Gender Equality risk assessment annex appended on 7 November 2024.

Banca Generali reports work-life balance metrics. At 31 December 2024 all 1,104 employees (100%), comprising 531 female and 573 male, were entitled to take family-related leave. During the year 137 entitled employees actually took family-related leave (85 female, 52 male), equal to 12% of entitled employees (16% of women and 9% of men). Entitlement is subject to the relevant conditions set by the applicable framework.

Banca Generali reports remuneration metrics. The unadjusted gender pay gap at 31 December 2024 was 36.64%, calculated as the difference between the average gross hourly pay of male and female employees divided by the average gross hourly pay of male employees, times 100. The total remuneration ratio at 31 December 2024 was 36.25 (a ratio of 1:36.25), calculated as the annual total remuneration of the highest paid individual divided by the median employee annual total remuneration excluding the highest paid individual. The Remuneration Policy reflects principles of gender neutrality, basing evaluation and remuneration criteria on merit and professional skills.

Banca Generali reports on incidents, complaints and severe human rights impacts. It states that any confirmed episodes of discrimination could give rise to disciplinary measures and penalties, but in 2024 there were no such events or circumstances to report, nor any internal complaints or penalties in this regard. In addition, given the nature of the Company's business and the location of its operations, no transactions subject to auditing or human rights impact assessment were performed during the period.

Banca Generali reports policies covering two material sub-topics: quality of customer information and cybersecurity/data protection. Customer relations follow principles in the Internal Code of Conduct (lawful conduct, sustainability culture, data protection, conflict-of-interest management, accurate financial disclosures). In 2024 the Bank applied the Commercial and Product Governance Policy and the Policy on the Provision of Investment Advisory Service to keep its offering aligned with regulation and customers' needs, including sustainability preferences per MiFID II. Transparency controls address Regulation (EU) 2019/2088 (SFDR) for Article 8 or Article 9 ESG products; the Sustainability Policy defines ESG investment controls. For data protection, the Group follows GDPR principles, acts as Controller, and applies firewalls, antimalware, training, risk assessment and fraud-monitoring (since 2019). Cybersecurity policies include the Security Policy (updated early 2025 to align with DORA, Regulation (EU) 2022/2554), the Strategic Guidance Policy on ICT, the ICT and Cyber-Security Risk Analysis and Management Policy, and Business Continuity Management. A security process follows the NIST Cybersecurity framework's five phases (identify, protect, detect, respond, recover), overseen by a Chief Security Officer.

The business model centres on the relationship of trust between the Customer and the Financial Advisor, which is the main channel for gathering customers' views on an ongoing basis and representing them within the Company. The Bank also collects indirect feedback through data analytics processes aimed at better understanding customer needs, and develops specific products and services at the customer's request, mainly for Institutional Customers and High Net Worth Individuals (HNWI). On cybersecurity, in 2024 raising awareness among the company's population was a priority: targeted anti-phishing campaigns were strengthened and intensified with ad-hoc emails, alongside regular emails on cybersecurity and fraud giving updates on threats and protection advice. Customer-facing engagement included pop-up messages on the website and ad hoc emails to inform and raise awareness among customers about cyber risks and how to protect their data.

Banca Generali offers customers several channels to raise concerns or lodge complaints, specified in pre-contractual documentation and on the Bank's website. Customers can seek assistance from Financial Advisors, the free Phone Banking and email service (BG Vale), and the Contact Center (Customer Care and Network Support units). A complaints notice on the website links to dispute-resolution bodies, the Banking and Financial Ombudsman (ABF) and the Securities and Financial Ombudsman (ACF); complaints may also be filed in writing by post, fax, email, certified mail or by hand. The Legal Affairs Network Litigation and Complaints structure verifies complaints and responses. For data protection, a Data Protection Officer (DPO) oversees processing and protection of personal data, with the Compliance Function as second-line control. In 2024, 8 complaints concerning data protection were made regarding Banca Generali, with no need to compensate the parties involved. Also in 2024 a limited case of data breach regarding customer data was recorded; the Group activated communication channels with the Data Protection Authority and advised customers to watch for fraud. IT incident reporting is formalised in the Business Continuity Management Policy.

To manage the downstream risk, the Bank monitors customers' sustainability preferences and integrates them into product governance and commercial strategy. Product governance identifies target markets, provides ongoing product assessment and blocking controls where a customer is incompatible with a product's target market, with outcomes reported to top managers. Advertising and promotional materials undergo an approval process with Legal and, where needed, Compliance verification, plus ex-post checks and greenwashing mitigation (verifying ESG information and engaging management companies or issuers). On cybersecurity, the Security and BCP Service reinforced fraud management, strengthening the AI-powered RSA AAoP antifraud engine and participating in CERTFin working groups. Security solutions included SIEM, SOC and Incident Response Team monitoring, endpoint security (encryption, EDR, vulnerability assessment), MFA and cloud proxy for remote working, and two risk-assessment campaigns (Cyber Risk Assessment and IT Risk Assessment). Penetration tests and supplier audits (CSE, Accenture Song, TXT, Avaloq, Post) were conducted. Corporate/physical security, travel safety and business continuity work (DORA projects, ISO 22301, updated Business Impact Analysis) and the 2024 Awareness Plan (aligned with Bank of Italy Circular No. 285 and DORA) were also delivered.

Banca Generali Group did not identify specific targets related to the potential risk linked to quality information, nor define specific quantitative objectives on cybersecurity and data protection, but ensures constant attention and structured monitoring. For quality information, the Bank provides informative and educational communications and dedicated training to the BG Network, monitors sustainability preferences expressed in the MiFID questionnaire, and reports half-yearly to the Managing Committee, the Sustainability and Innovation Committee and the Board of Directors via the Sustainability Dashboard. The Board receives a quarterly report on litigation and complaints, and the Sustainability Dashboard includes an indicator on the number of complaints and disputes on ESG matters, shared half-yearly with the Board. For data protection, the DPO delivers a yearly DPO Report to the Board of Directors, attended also by the Board of Statutory Auditors. Cybersecurity activities are monitored and reported annually to the Board of Directors, the Internal Audit and Risk Committee and the Board of Statutory Auditors through a reporting tool called Summary.

Banca Generali reports its business conduct policies and corporate culture. It has adopted an Internal Code of Conduct drawn up in line with the Generali Group Code of Conduct, which prohibits the offering or acceptance of undue payments, gifts, entertainment or other improper benefits and forms an integral part of the 231 Organisational and Management Model under Italian Legislative Decree No. 231/2001 on vicarious corporate liability. The Bank also adheres to Borsa Italiana's Corporate Governance Code for Listed Companies. Beyond the Anti-Bribery & Corruption Policy, it has adopted an Anti-Money Laundering, Counter-Terrorist Financing and International Sanction Policy (AML/CTF/IS Policy) and a Tax Compliance Policy. On whistleblower protection, a Whistleblowing Policy was adopted in 2023 and updated in 2024, in compliance with EU Directive 2019/1937 and Italian Legislative Decree No. 24 of 10 March 2023; dedicated electronic channels are available, reports are managed with protection against retaliation, and the Bank prepares an annual Report on the proper functioning of the whistleblowing system. The report notes Banca Generali did not adopt ad-hoc processes to identify and assess business conduct impacts, risks and opportunities (G1 IRO-1).

Banca Generali reports the management of relationships with suppliers, voluntarily disclosed to help meet Borsa Italiana's corporate governance reporting requirements. It develops contractual relationships only with qualified suppliers, using a scoring system defined with Generali Group that weighs financial data, risk assessment and quality. Main IT service providers CSE and GOSP meet the ISO 27001 standard, and in 2024 all activities to align Group companies to the EU DORA (effective January 2025) were implemented. For purchases over 40,000 euros excluding VAT, generally at least three qualified suppliers are involved in selection. In 2024, 37 new relevant suppliers were selected and 13 suppliers already active in 2023 completed the full qualification procedure and were added to the List of Qualified Suppliers (a relevant supplier is one whose activities are estimated at over 150,000 euros per year). In collaboration with Generali Group and third-party infoprovider IntegrityNext, the Bank activated an ESG Assessment Service in 2024 covering suppliers with turnover above 100,000 euros, representing about 84% of the purchase value, assigning ESG ratings across four pillars (human and labour rights, health and safety, environmental protection, responsible supply chain).

Banca Generali reports its prevention and detection of corruption and bribery. In 2024, the Board of Directors approved a specific Anti-Bribery & Corruption Policy (ABC Policy) aligned with the standards of parent company Assicurazioni Generali, setting the framework to prevent corruption and comply with ABC international regulations. A dedicated training programme, Be Aware of Anti-Bribery & Corruption, was launched at the end of 2024, and a course on Italian Legislative Decree No. 231/2001 covering the crime of corruption was again organised in 2024. For anti-corruption and bribery training in 2024, among all employees (including managers) 1,104 were in scope and 1,047 received training (3,091.5 hours of computer-based training plus 4.5 voluntary hours); across the Financial Advisor Network 2,349 were in scope and 2,301 received training (4,602 hours). In 2024, 109 employees and 151 other own workers were trained. The Bank notes it did not conduct any assessment of the functions most at risk of corruption and bribery (ESRS G1-1 10.h). At 31 December 2024 all Board members of Group companies were informed of or acknowledged the relevant internal regulations.

Banca Generali reports on confirmed incidents of corruption or bribery. It states that no incidents of corruption or bribery, and no non-compliance events with respect to applicable laws and regulations, were confirmed in 2024. No related fines are reported for the year.

The Double Materiality Analysis did not identify political influence and lobbying activities as a material topic, so Banca Generali Group states it does not provide full disclosure on ESRS G1-5. However, the Sustainability Statement voluntarily incorporates information on this disclosure requirement to help fulfil Borsa Italiana's corporate governance reporting requirements. The Group states that it is not involved in any activity aimed at exercising political influence, as set out in its Internal Code of Conduct and Sustainability Policy. No political contributions figures are reported.

Banca Generali reports payment practices, voluntarily disclosed to help meet Borsa Italiana's corporate governance reporting requirements. In 2024 the Group engaged with 1,660 suppliers (1,546 in 2023), generating total expenditure of 156.618 million euros (152.383 million in 2023): 129.542 million euros (82.71%) to Italian suppliers and 27.076 million euros (17.29%) to foreign suppliers. The largest expenditure categories were IT consultancy and application software (46.8%), advisory and professional services (17.1%) and office rental (16.6%). The Bank offers suppliers a standard payment term of 60 days from invoice date, with special terms in line with market conditions for certain supplies such as rentals. An analysis under the Growth Decree (Italian Law No. 58 of 28 June 2019) and Article 7-ter of Italian Legislative Decree No. 231/2002 showed an average payment time of 41 days in 2024 (in line with 2023), with the few delays generally limited to about 5 calendar days, largely because payment flows are prepared weekly. In 2024 the Group was not involved in any legal proceedings for late payment of suppliers.