Engagement Policy

As an asset owner, Intesa Sanpaolo Assicurazioni integrates environmental, social and governance (ESG) aspects into the investment process for insurance portfolios across all asset classes, with the aim of optimising financial returns and contributing to social value.

From this perspective, the Company is committed to influencing the companies in which it invests, through voting and engagement activities, in order to encourage the adoption of responsible conduct within them, in line with ESG criteria, reduce long-term risks and improve the long-term financial performance of investment portfolios.

The Company has therefore adopted an ‘Engagement Policy’ pursuant to:

• Directive (EU) 2017/828 of the European Parliament and of the Council of 17 May 2017 amending Directive 2007/36/EC as regards the encouragement of long-term shareholder engagement (the ‘Shareholder Rights II Directive’),
• IVASS Regulation 46 containing provisions on the transparency of the engagement policy and elements of the equity investment strategy of insurance or reinsurance undertakings, pursuant to Article 124 novies, paragraph 3 of the consolidated financial intermediation act,
• Commission Delegated Regulation (EU) 2022/1288 of 6 April 2022 supplementing Regulation (EU) 2019/2088 of the European Parliament and of the Council on sustainability disclosures in the financial services sector

and also in keeping with the commitments undertaken by the Intesa Sanpaolo Group and in compliance with the sustainability guidelines defined by the Sustainability Policy adopted by the Intesa Sanpaolo Assicurazioni Group.

Pursuant to Article 35-decies of Legislative Decree no. 58 of 24 February 1998 (the Consolidated Finance Act - TUF) Intesa Sanpaolo Assicurazioni has adopted a set of procedures and measures to:

• monitor corporate events related to financial instruments held by managed portfolios, where required by the characteristics of the financial instruments incorporating the rights to be exercised;
• evaluate, also through active engagement, the methods and timing for the possible exercise of participation and voting rights, on the basis of a cost-benefit analysis that also considers the objectives and investment policy;
• prevent or manage any conflicts of interest that may arise from the exercise of voting rights on behalf of the assets managed.

Intesa Sanpaolo Assicurazioni participates in the shareholders' meetings of selected companies listed on the Italian Stock Exchange and international markets, taking into account voting strategies, the usefulness of participating in the interests of the assets managed, the specific circumstances, and the possibility of influencing decisions based on the voting rights held, or according to specific instructions provided by the Finance and Sustainability Department. 

Intesa Sanpaolo Assicurazioni promotes proactive interaction with issuers. This also takes place through a process of engagement with participating companies.

The tools that ISPA uses, also through Delegated Managers, to carry out engagement activities may include, among others, conference calls, webcast presentations, letters, and, when possible, in-person meetings.

Engagement, also carried out through Delegated Managers, can be activated in three main ways:

• on the initiative of the individual portfolio manager of the Delegated Manager,
• collectively with trade associations (e.g.: Assogestioni),
• in a collaborative manner with other international associations of which the Group is a member

promoting dialogue with less advanced issuers from the point of view of climate protection and sectors with the greatest environmental impact.

Intesa Sanpaolo Assicurazioni pays particular attention to the policies implemented by the issuers in which it invests, in the belief that sound corporate governance policies and practices (incorporating environmental, social and corporate governance issues) can create long-term shareholder value. In this context, the ISPA Group and ISPA have adopted specific methodologies for selecting financial instruments that take into account environmental, social and corporate governance (ESG) factors  and SRI (sustainable responsible investment) principles.

Below is an  Overview of the Company's Engagement Policy.