in accordance with Legislative Decree 254/2016 (NFS)
CONSOLIDATED NON-FINANCIAL 
STATEMENT 
2022 
Sustainability 
Report

INDEX

LETTER FROM THE CEO	
4
METHODOLOGICAL NOTE	
6
1.	
GROUP PROFILE	
9
1.1. 	 Highlights	
10
1.2. 	Who we are, strategy and business model	
11
1.3. 	Sustainable Development Goals 	
and commitments subscribed	
17
1.4. 	ESG Ratings and Indices	
28
1.5. 	ESG Prizes and Awards	
29
1.6. 	Membership of associations	
30
2.	
STAKEHOLDER RELATIONS	
AND MATERIALITY ANALYSIS	
33
2.1. 	 Stakeholder Engagement 	
34
2.2. 	Material topics	
39
3.	
OUR CUSTOMERS	
43
3.1. 	 Cybersecurity and Information Security	
45
3.2. 	Responsible Products and Investments	
49
3.3.	 Financial inclusion	
55
3.4.	Fairness and transparency	
in customer communications	
56
4.	
INNOVATION	
59
4.1. 	 Technological innovation	
and digital transformation	
60
4.2. 	Business model innovation	
61
5.	
SOLIDITY AND RESILIENCE	
63	
5.1. 	 Governance system	
66
5.2. 	Management of ESG risks	
76
5.3. 	Performance and capital strength	
89
5.4. 	Economic value generated and distributed	
90
5.5. 	Environmentally sustainable assets	
93
5.6. 	Protection of corporate reputation	
95
6.	
ETHICS AND COMPLIANCE	
CULTURE	
97
6.1. 	 Compliance culture	
99
6.2. 	Ethics and integrity in business conduct	
101
7.	
OUR PEOPLE	
111
7.1.	 Management of our people	
112
7.2. 	Diversity and inclusion	
118
7.3. 	Promoting and developing human resources	121
7.4. 	Welfare and Industrial Relations	
127
7.5. 	Health and safety	
129
8.	
COMMUNITY	
133
8.1. 	 Financial Education	
134
8.2 	Community Support	
136
8.	
ENVIRONMENT	
141
8.1. 	 The EMAS Environmental	
Management System	
142
8.2 	Environmental performance	
145
GRI CONTENT INDEX	
159
EXTERNAL AUDITORS’ REPORT	
165
ANNEX I
Principles for Responsible Banking
Reporting and Self-Assessment Template	 168
ANNEX II 
SDGs and related relevant targets	
178
ANNEX III
Organisational chart	
180

4
LETTER FROM THE CEO

Dear Stakeholders,
In a complex global scenario with new challenges, the year 2022 was marked by the outbreak of the military 
conflict between Russia and Ukraine, which generated an international diplomatic crisis with significant geopo­
litical, economic and social repercussions worldwide. 
In this context of uncertainty, the crisis did not have a significant impact on the Fineco Group, due to the ab­
sence of direct and indirect exposures in assets whose value is affected by the conflict. There were no signifi­
cant impacts either in terms of management of liquidity, which remained solid and stable, or in terms of strategic 
objectives and direction, characterised by an increasing integration of sustainability into the business mod­
el. Established from the outset as a company oriented towards long-term sustainable growth, Fineco has in fact 
continued to operate in line with its corporate purpose: “to support clients in the responsible management of 
their savings in order to create the conditions for a more prosperous and fairer society”. 
This goal is pursued through the Group’s continuous investment in the three pillars of transparency, efficiency 
and innovation, which have always guided our strategy and our growth journey, offering customers excellent 
services and products at a fair price within the three integrated business areas of banking, investing and bro­
kerage.
The constant look to the future that guides business decisions is also the cornerstone of our approach to sus­
tainability. Accordingly, in 2022 we adopted the Net Zero Commitment, setting ourselves the important goal 
of achieving net zero CO2 emissions by 2050. 
The commitment to combating climate change is part of the Group’s subscription to the United Nations sus­
tainability initiatives – namely the Principles of the Global Compact, the Principles for Responsible Banking 
and the Principles for Responsible Investment – and is part of the ESG Plan, which saw the achievement of 
important milestones during the year. In terms of client offering, Fineco Asset Management has strengthened 
its range of ESG products and the integration of environmental, social and governance criteria into its invest­
ment management activities. The Bank has also expanded the availability of ESG-rated funds and the range of 
ESG-rated financial products, meeting the important challenge of offering customers products and services that 
are increasingly aligned to their sustainability preferences. 
In September 2022, FinecoBank obtained EMAS Registration, a recognition that certifies the excellence of the 
Environmental Management System, implemented throughout the Italian offices and Fineco Centers accord­
ing to the requirements of the European EMAS Regulation. 
In the knowledge that the ability to innovate and continuous evolution cannot be separated from the nurturing

5
of human capital and the richness derived from the diversity of its composition, we have continued to invest in 
the growth of our employees and personal financial advisors and the development of their talents and profes­
sional skills. For the fourth year running, the Bank has won the Top Employer Italia award, standing out for the 
focus on its staff and on the development of their skills, creating a positive and stimulating workplace.           
This fourth Non-Financial Statement reports on the commitments and actions taken to continue to accompany 
our Stakeholders in the journey towards ever greater sustainability, which we will all have to take. We are proud 
to say that social responsibility is part of who we are, and is consistently a cornerstone of our process of cre­
ating long-term sustainable value for our current and future stakeholders.
	
	
	
	
	
	
	
 Alessandro Foti
	
	
	
	
	
	
	
CEO and General Manager

6

This document represents Consolidated Non-Financial Statement (below also “NFS” or “Non-Financial 
Statement”) of the FinecoBank Group (below also “Group” or “Fineco”), prepared in accordance with Articles 3 
and 4 of Legislative Decree 254/2016 and the GRI Standards for the period 1 January 2022 to 31 December 
2022. Specifically, the 2021 version of the GRI Universal Standards and the 2016 versions of the GRI Topic 
Standards have been adopted, taking into account the GRI G4 “Financial Services” Sector Disclosures. 
A new addition to this NFS is the data and information to meet the requirements of Annex IV of Regulation 
1221/2009/EC (EMAS Regulation1), and those arising from the adoption of the United Nations Principles for Re­
sponsible Banking (PRB), as set out in the related reporting template.
The NFS is a separate report from the consolidated management report and its purpose is to provide a proper 
representation of the Group’s activities, performance, results, and impacts for 2022 with respect to the main 
sustainability topics. The reporting period (1 January to 31 December 2022) is the same as that of the Consoli­
dated Financial Statements.
The process of preparing and publishing the NFS, including the assignment of roles and responsibilities to the 
corporate units and bodies involved, is implemented in accordance with the procedures set out in the internal 
Global Operational Regulation on the “Preparation and publication of the consolidated Non-Financial State­
ment of the FinecoBank Group”. In addition, the collection of non-financial information and data is based on a 
defined flow involving the corporate functions engaged in the preparation of the NFS, via a specially developed 
information system.
To ensure the utmost transparency to the market and to stakeholders, this NFS describes the Group’s key 
policies, management models, and results for 2022 in relation to the topics expressly cited in Legislative De­
cree 254/2016 (environment, society, personnel, human rights, anti-corruption and bribery), as well as the main 
risks associated with these topics and the management approach. 
The content of the NFS and the related indicators reported have been defined taking account of the topics 
identified in Legislative Decree 254/2016, starting from the results of the materiality analysis approved by the 
Board of Directors on 11 October 2022, which identified the main topics considered material for the Group and 
its stakeholders. While ensuring a fair representation and proper understanding of the Group’s activities, it 
should be noted that:
·	given the operational and regulatory environment in which Fineco operates, the topic of respect for human 
rights is addressed by the Group in the management of relations with its employees and suppliers, in line 
with the principles and values set out in the Bank’s Code of Ethics and in the “Commitment to Human Rights” 
policy; 
·	in the same  context, the Group’s activities do not entail significant impacts on the health and safety of employ­
ees, as they are mainly office-based. Even though this topic was not found to be material following the update 
of the Materiality Analysis carried out in 2022, it has been reported in this NFS, as it is referred to  in Article 3 
paragraph 2 of Legislative Decree 254/2016;
·	given the nature of its operations and its specific business sector, the Group’s activities do not result in signifi­
cant water consumption, as it is mainly related sanitation and office cleaning activities. This topic, even though 
METHODOLOGICAL NOTE
1	
The data and information contained in this document meeting the requirements of the EMAS Regulation for the preparation of the Environmental Statement will be formally 
validated by the environmental verifier during the EMAS verification by June 2023.

7
not material, falls within the scope of  the Environmental Management System implemented by FinecoBank in 
accordance with EMAS Regulation and is referred to in Article 3, paragraph 2 of Legislative Decree 254/2016, 
and is subject to limited reporting in this NFS. 
The GRI content index, which lists the indicators relevant to the Group based on the materiality analysis, is pro­
vided in the appendix to this document.
In line with the 2022 Consolidated Financial Statements of the FinecoBank Group, the reporting scope includes 
the Parent Company FinecoBank S.p.A. and its subsidiary Fineco Asset Management DAC, a fully consolidated 
company based in Ireland, and excludes the newly formed Fineco International Ltd, based in England, a fully 
owned subsidiary of FinecoBank S.p.A. but not yet operational at the end of the reporting year.
Vorvel SIM S.p.A.2, with registered office in Italy, a company subject to significant influence, in accordance with 
IAS 28, has been accounted for using the equity method within the 2022 Consolidated Financial Statements 
and is excluded from the scope of this NFS. 
Moreover, health and safety data refer to Group employees only and not to other non-employee professionals, 
a category comprised mostly of personal financial advisors, self-employed workers who provide intellectual 
services in places outside the Bank’s direct control and towards whom FinecoBank does not have the specific 
health and safety obligations that Legislative Decree 81/2008, as amended, demands of employers. Any other 
limitations in the scope of the data are duly noted in the text.
Data and information in this document, unless otherwise specified, refer to the year 2022; where available, 
prior-year figures are reported for comparison and to enable assessment of changes in performance from year 
to year. Any restatements of previously published comparative information are clearly indicated. To provide an 
accurate view of performance and ensure the reliability of data, estimates have been used as little as possible; 
where employed, they are duly noted as such and are based on the best available methods. 
This Non-Financial Statement was submitted for review and assessment by the Corporate Governance and 
Environmental and Social Sustainability Committee and the Risk and Related Parties Committee on 23 Febru­
ary 2023 and approved by the Board of Directors of FinecoBank S.p.A. on 14 March 2023. 
This document has undergone a limited assurance engagement (as defined by ISAE 3000 Revised) by KPMG 
S.p.A., which in a separate report has certified the information presented in accordance with Article 3, para­
graph 10 of Legislative Decree 254/2016. 
For further information on Fineco’s Non-Financial Statement, please contact: sostenibilita@fineco.it.
The NFS is available online, from the date of publication of 27 March 2023, in the following sections of the 
Fineco website:
1)	 Sustainability: https://about.finecobank.com/en/sustainability/;
2)	Investors - Corporate sustainability reporting: 
https://about.finecobank.com/en/investors/rendicontazione-societaria-di-sostenibilita/ 
2	 With effect from 12 December 2022, the company Hi-Mtf SIM S.p.A. changed its name to Vorvel SIM S.p.A..

01

9
GROUP PROFILE
1.1. 	
HIGHLIGHTS
1.2. 	
WHO WE ARE, STRATEGY AND BUSINESS MODEL
1.3. 	
SUSTAINABLE DEVELOPMENT GOALS AND COMMITMENTS SUBSCRIBED
1.4. 	
ESG RATINGS AND INDICES
1.5. 	
ESG PRIZES AND AWARDS
1.6.	
MEMBERSHIP OF ASSOCIATIONS

10
2,918
Personal Financial Advisor
HIGHLIGHTS
1.1.	
3	 The number of customers refers to individuals with a Fineco current account, not to the number of accounts. Individuals with more than one account are considered just 
once. The number is different from that listed in the consolidated management report (1,487,250) because it does not include customers who own products other than 
current accounts and the holders of technical accounts for which the corresponding ordinary account is closed.
4	 Common Equity Tier 1 capital ratio.
5	 Net profit adjusted for non-recurring items recognised in 12M22.
6	 Market-based.
7	 The figure refers to electricity consumption related to the buildings where the utilities are registered to Fineco.
1,336
Employees
564
772
Women
Men
20.8%
CET14
426
Fineco Center
1,456,8293
Customers
47.7 TJ
Energy consumption
44 tonnes
Paper saved through 
dematerialisation initiatives
10.3 bn €
Total net sales
106.6 bn €
Total Financial Asset
428.8 mn €
Net profit adjusted5
100%
Electricity7 from renewable 
sources
of which: 
30.6 bn € direct
52.1 bn € Asset Under 
Management
23.9 bn € Asset Under 
Custody
-16% emissions 
of CO2e
vs. 2021 (Scope 1 e 26)

11
WHO WE ARE, STRATEGY AND BUSINESS MODEL
FinecoBank was founded in 1999 with the aim 
of building a new concept of banking, offering 
an integrated business model combining direct banking 
and financial advice.
FinecoBank S.p.A. is a joint-stock company listed on 
the Mercato Telematico Azionario in Italy, organised 
and managed by Borsa Italiana S.p.A. Since April 
2016 it has been included in the FTSE Mib stock in­
dex and in the Stoxx Europe 600 index since 2017. 
It is the parent company of the FinecoBank Banking 
Group (below also “Fineco” or “Group”), which in­
cludes the Irish asset management company, Fineco 
Asset Management Designated Activity Company 
(below also “Fineco Asset Management DAC” or “Fi­
neco AM”), and the newly incorporated company Fi­
neco International Ltd.
The subsidiary Fineco Asset Management DAC 
has allowed the Group to increase its competitive 
strength in the wealth management sector by in­
sourcing the creation and management of invest­
ment funds, specifically designed to better meet 
customer needs. Its establishment in 2018 made it 
possible to diversify and improve the Bank’s range 
of asset management products and offer customers 
a diversified range of UCITS (Undertakings for Col­
lective Investment in Savings), focusing the strategy 
on asset allocation and the selection of the best in­
ternational asset managers.
During the year, Fineco saw an increase in the share­
holdings of major institutional investors: at the end 
1.2.	 
1999 
Birth of 
Fineco
2001 
One-stop-solution: 
Brokerage, Banking, 
Investing from one single 
account with a Multibrand 
Open Platform
2008 
Digital + PFA 
Platform 
(first and only one 
players in the market)
2014 
IPO
2018 
Fineco Asset Management 
To enhance risk management, 
time-to-market and product 
quality
Smart 
repricing
New generation 
of investing 
products
Banking 
platform 
upgrade
Assisted Selling 
platform
2019 
Fineco now a 
public company
2017 
Launch of UK 
operations 
1st online 
trading 
platform 
launched in 
Europe
Multicurrency 
immediately 
available online
Mobile 
banking sim 
tool kit
Launched trading  
on forex
First ones to use 
Security disposable 
Pin instead of Token
Customer care 
internalized
Digital signature
Sistematic 
internalizer
First Italian 
bank to offer 
CFD
Biometrical 
recognition
Mobile App  
5* rating
Cyborg Advisory 
Platform (X-Net) to 
enhance our PFAs’ 
productivity
Fee-only advisory 
service
Reshape of 
brokerage offer
Plus: multiasset 
advisory with fee 
on top
2021 
TFA exceeds €100bn 
and Fineco acquires 20% 
Hi-MTF shareholding
FAM launches 
new products 
including 
passive funds, 
ETFs and 
Smart Global 
Defence
2022

12
DISTRIBUTION OF FINECO CENTERS IN ITALY
5
21
28
2
34
4
7
36
11
27
16
6
33
79
39
16
2
11
10
39
of 20228 the largest shareholders were BlackRock 
Inc. (9.201%), Wellington Management Group LLP 
(5.441%), Capital Research and Management Com­
pany (5.050%) and FMR LLC (4.464%).
Fineco’s fully subscribed and paid-up share cap­
ital amounts to €201,339,553.80, divided into 
610,119,860 ordinary shares with a nominal value of 
€0.33 each, while the market capitalisation at the 
end of the year was €9,469 million. 
At national level, as at 31 December 2022, the Fi­
necoBank Group, with 1,336 employees, was ope­
rating through its registered office and head office 
located in Milan and Reggio Emilia9 respectively and 
two Data Processing Centres (DPCs) located in Pero 
(MI) and Milan. FinecoBank operates in 20 Italian 
regions, with 426 Fineco Centers (offices where 
financial advisors carry out their activities) distribu­
ted throughout Italy and 2,918 Personal Financial 
Advisors (PFAs) Outside Italy, the subsidiary Fineco 
Asset Management DAC is based in Dublin. The sub­
sidiary Fineco International Ltd is based in London.
8	 Source: Consob, Significant Shareholdings – 27 December 2022.	  
9	 Registered Office: 20131 Milan - Piazza Durante, 11; Head Office: 42123 Reggio Emilia - Via Rivoluzione d’Ottobre, 16.

13
10	 Source: Assosim.
FinecoBank is one of the most important FinTech 
banks in Europe and has one of the largest financial 
advisory networks. It is one of the leading banks in 
brokerage in Europe and No. 1 in Italy10 in terms of 
number of transactions and equity trading volumes. 
The Bank’s transactional platforms and advisory ser-
vices are developed in-house using state-of-the-art 
proprietary technologies to make the customer ex-
perience more fluid and intuitive on all channels.
It is also one of the major players in Private Banking 
in Italy, with an advisory approach built around the 
needs of individual customers that includes trustee 
services, protection and transfer of personal and 
corporate assets. 
In 2022, the number of customers stood at over 1.4 
million, an increase of over 56,000 net new custom-
ers compared to last year.
2022
2021
2020
NUMBER OF CUSTOMERS 
BY TYPE
Number
%
Number
%
Number
%
Retail
1,350,533
93%
1,302,412
93%
1,258,785
94%
Private
86,047
6%
78,759
6%
65,502
5%
Legal persons (such as institutional 
bodies or associations)
20,249
1%
19,182
1%
17,606
1%
Total
1,456,829
100%
1,400,353
100%
1,341,893
100%
Since its foundation, Fineco’s mission has been to 
provide top quality services to customers by focus-
ing on two key concepts: simple banking and con-
tinuous innovation, both applied to the financial in-
struments offered and services provided.
The Group is based on three main pillars: efficien-
cy, innovation and transparency, the key principles 
of its strategy, leading the way towards sustainable 
growth.
TRASPARENCY
Fairness and transparency towards 
all stakeholders
Integrity and transparency, also through 
fair pricing, are part of Fineco’s DNA. The 
Group strongly believes that these key 
elements underpin the creation of long-term 
sustainable value for all its stakeholders.
EFFICIENCY
IT and operations are the Bank’s strong points, 
supporting business, greater flexibility 
and lower costs 
Efficiency is a distinctive feature of the Bank and 
characterises every activity: thanks to its proprietary 
back-end systems, internal development and 
automated processes, Fineco benefits from a lean 
and efficient cost structure as well as rapid 
time-to-market for new products and services.

14
The business model is structured into three areas 
of integrated activities: Banking & Credit, Invest­
ing and Brokerage. The Bank offers its services 
(banking and investment) mainly to retail customers 
through its network of personal financial advisors 
and through online and mobile channels, which op­
erate together in a coordinated and integrated man­
ner. The main products and services by area of activ­
ity are described below.
INNOVATION
Anticipating new needs 
to simplify customers’ lives
Innovation is the path taken by Fineco 
to achieve its mission. 
From the outset a pioneer in anticipating clear 
structural trends generated by the increasing 
digitisation of customers and consumers, 
who increasingly choose their banks 
according to the quality of services offered.
BANKING & CREDIT
The Group offers its customers a portfolio of products that includes credit and payment services asso­
ciated with a current account. These include current and deposit accounts, all payment services (credit 
transfers, postal orders, payments by advice, Pago PA and CIBILL payments) including payment cards (debit, 
credit and prepaid) issued by the Bank, mortgages, credit facilities (both secured and unsecured), and per­
sonal loans. 
Special services include the possibility, thanks to the customer identification performed by the Bank when 
opening an account, of obtaining SPID (public digital identity) credentials, which allow holders of a digital 
identity easy and immediate access a range of public services, such as medical appointments, school en­
rolments, and requests to the national social security and tax authorities. The payment services offered by 
Fineco include the distinctive proprietary Fineco Pay service, which allows customers to make micro-pay­
ments securely and quickly with just the counterparty’s mobile phone number, without needing to know their 
bank details.
The range of Banking, Credit and Payment Card products and services continues to grow and evolve, in line 
with market competition and customer needs.
Long-term organic and sustainable growth is the 
cornerstone of Fineco’s development strategy and 
is achieved through the practical implementation of 
the strategic pillars. Maintaining and developing the 
customer base is pursued by continuously providing 
high-quality services, contractual transparency and 
fair prices aligned to the services offered. Opera­
tional efficiency is the key to Fineco’s competitive 
advantage thanks to the Bank’s solid and extensive 
internal IT culture and its core systems developed 
and managed in-house. The Bank has a sound, sus­
tainable and low risk capital structure, with highly 
liquid assets. Attention to ESG matters is an integral 
part of the corporate governance. The Bank has set 
up Sustainability Committees at board and manage­
ment level, together with a dedicated Unit, with the 
aim of developing and overseeing the sustainability 
strategy.

15
INVESTING
The Group uses a guided open architecture business model to offer customers an extremely wide range of 
asset management products – comprising collective asset management products, such as units of UCITS 
and SICAV shares from 70 leading Italian and international investment firms, as well as pension and insur­
ance products and investment advisory services, through the network of personal financial advisors. This 
includes, in particular, the asset management business carried out by the subsidiary Fineco AM, through a 
vertically integrated business model. 
The main services/products offered are:
·	 Advice11: personalised advisory services to meet complex customer needs and monitor portfolio perfor­
mance over time;
·	 Plus: an innovative advisory service whereby personal financial advisors facilitate the achievement of 
customers’ objectives by exploring all available opportunities, such as funds, SICAV shares, shares, bonds, 
ETFs and ETCs, always providing global and detailed investment reports;
·	 Private Banking Solutions: construction of customised portfolios and active monitoring; Wealth & Private 
Insurance; Private Placement and Private Markets;
·	 Wealth management services for private customers;
·	 Insurance solutions and pension funds;
·	 Funds managed by the asset management company of the Fineco Group.
BROKERAGE
The Group provides execution services on behalf of customers, with direct access to major global equity 
markets and the ability to trade CFDs (on currencies, indices, shares, bonds, commodities and cryptocurren­
cies), futures, options, bonds, ETPs, certificates and covered warrants.
In this area, the Bank coordinates and oversees the development of trading products and services to be 
offered on the domestic and international markets according to the needs of the customer base and to 
changes in the target market and in regulations. 
Lastly, another key element of the Fineco Group’s 
value chain is the supply chain. FinecoBank’s Pro­
curement Office ensures that the purchasing is man­
aged in compliance with the criteria of transparency 
and objectivity and that the suppliers are selected 
based on professional knowledge and skills that 
meet the minimum requirements of value for money, 
as well as the adoption of socially responsible be­
haviour, and requests any mandatory documentation 
examining the completeness and correctness of the 
information received.
The entire procurement process, at Group level, is 
governed by the Expenditure Regulation, which 
ensures that the supplier selection process is imple­
mented through clear procedures, using objective, 
transparent, non-discriminatory criteria linked to the 
quality of the products and services offered. Since 
2021, an ESG (Environment, Social and Govern­
ance) questionnaire has been used, in which the 
most relevant suppliers are asked to provide infor­
mation on how they manage their environmental, 
social and governance aspects, also in terms of any 
certifications held in these areas (e.g. ISO 14001 for 
the environment, ISO 37001 for anti-corruption) and 
the systems they use to control the related risks. 
The Contract Managers, who are the company con­
tacts responsible for relations with suppliers are re­
quired to submit the ESG questionnaire to suppliers 
11 	 Regarding the possible future ban on inducements, which is the subject of debate and discussion in the European Commission and among industry players, Fineco is ready 
for a possible change in regulatory approach, given that it has moved in advance by proposing a model, within the Fineco Advice service in operation since 2010, in which 
the customers pay a separate advisory fee and simultaneously receive a refund of the fund management fees.

16
who invoice FinecoBank for a total annual amount 
of €25,000 or more (including VAT), when drawing 
up pre-contractual agreements aimed at signing or 
renewing a contract. The Contract Managers are re­
sponsible for checking that the questionnaires have 
been correctly completed by the suppliers. This pro­
vision was formalised in the last update of the Ex­
penditure Regulation, in January 2022.
Additionally, the Code of Ethics and the Organi­
sation and Management Model of FinecoBank 
S.p.A., define the principles of cooperation, fairness, 
transparency and professionalism, as key principles 
in relations between FinecoBank and its suppliers. 
In particular, these principles prohibit dealing with 
counterparties for which there is a substantiated 
suspicion of their involvement in illegal activities and 
do not meet the necessary requirements of profes­
sionalism and reliability. In addition to reviewing the 
Code of Ethics – which requires compliance with the 
principles of the International Labour Organization 
regarding fundamental human rights, child labour, 
freedom of association, working conditions, equal 
pay, health, safety and business ethics – during the 
qualification phase, the following are required from 
the suppliers, where applicable:
·	 DURC (Documento Unico di Regolarità Contrib­
utiva - single document certifying payment of 
contributions) and registration with the CCIAA 
(Chamber of Commerce, Industry, Craft Trades and 
Agriculture certificate);
·	 Compliance with the regulations concerning so­
cial security, accident prevention and insurance 
and on occupational health and safety;
·	 Self-declaration concerning the exploitation of 
workers (i.e. illegal recruitment and labour abuse);
·	 ESG questionnaire.
This process enables the monitoring of risks relat­
ed to the procurement process, mainly related to 
the possible selection of suppliers involved in illegal 
operations or who have been involved in disputes 
regarding social responsibility.
In addition, with regard to service contracts, the Real 
Estate Unit retains the option of appointing external 
personnel to carry out controls during the course of 
the activities on the compliance with all the contractual 
requirements by the various suppliers engaged by it.
In addition to the procurement process, Fineco also 
uses environmental sustainability criteria in specific 
projects and supply contracts: for example, in 2022, 
the new wellbeing area for employees in the Milan 
office was designed with optimal use of natural light 
and more sustainable materials for the furnishings, 
such as recycled plastic and FSC-certified wood. 
In 2022, Fineco managed expenditure of € 141.2 
million for a total of 1,486 suppliers, the majority of 
which related to services, followed by technology 
and goods. There were no significant changes con­
cerning the supply chain, in terms of main suppliers 
and types of goods and services procured.

17
SUSTAINABLE DEVELOPMENT GOALS 
AND COMMITMENTS SUBSCRIBED

Fineco is aware that its strategy, focused on stable 
and organic growth, must be accompanied by the 
progressive integration of environmental and social 
sustainability principles in its business and operational 
management choices. 
In order to ensure the increasing integration of en­
vironmental, social and governance (ESG) aspects 
within its strategy, in January 2020 the Board of Di­
rectors approved the first proposal of Sustainability 
Goals to be pursued in the years 2020-2023, pro­
gressively complemented with quantitative targets 
on the basis of emerging needs. The ESG goals, in 
addition to progressive identification and integration 
of the main ESG risks in corporate risk management 
model, involve specific activities in six macro areas: 
human resources, responsible finance, financial ed­
ucation/community support projects, supply chain, 
shareholders and environment.
In addition, as part of the design and implementa­
tion of the Environmental Management System, 
in accordance with the requirements of the EMAS 
Regulation, in June 2021 the Board of Directors ap­
proved the 2021-2024 Environmental Programme, 
defining the environmental objectives, operation­
al actions, the company units responsible for their 
achievement, the resources allocated, the timeframe 
and, where possible, the quantitative targets to be 
achieved.
Lastly, in August 2022, the Board of Directors ap­
proved the Commitment to Net-Zero emissions 
by 2050 (below also the “Net-Zero Commitment”), 
representing the Fineco Group’s target of zero 
greenhouse gas (GHG) emissions by the year 2050, 
entailing both a significant reduction in operating 
emissions and the alignment of its balance sheet 
assets with the Paris Agreement targets, with 2021 
as the base year. This is a significant target that Fi­
neco believes it can achieve by adopting appropri­
ate actions and measures, net of a generic factor 
of uncertainty linked to the evolution of the situa­
tion over such a long time horizon. The short- and 
long-term targets were set taking into account the 
Corporate Net-Zero standard and the Foundations 
for Science-Based Net-Zero Target Setting in the 
Financial Sector guidelines of the Science-Based 
Target initiative. Specifically, the following short-
term targets have been set in relation to operating 
emissions: 
·	 an average annual linear reduction of at least 4.5% 
for Scope 1 and 2 emissions, corresponding to a 
35% reduction by 2030; 
·	 an average annual linear reduction of at least 2.5% 
for Scope 3 emissions, corresponding to a 20% re­
duction by 2030, and
·	 an overall reduction of 90% of the same emissions 
by 2050.
For financed emissions, on the other hand, an ap­
proach has been adopted to ensure that the main 
balance sheet assets, and more specifically govern­
ment and bank debt securities in the internal invest­
ment portfolio are 100% aligned with the target of net 
zero emissions by 2050.
1.3.

18
As part of Fineco’s sustainability strategy, since 2020 
the Group aligned its goals with the Sustainable De­
velopment Goals12 (SDGs), considered most rele­
vant on the basis of the commonalities between the 
169 targets and the material topics. The table below 
shows the goals and targets of the 2020-2023 Plan 
in progress as at 31 December 2022. The following 
goals have already been achieved:
·	Evolution of the welfare plan: 100% of employees 
set up for home working since 2020;
·	Sustainable Mobility: #BikeToFineco initiative active 
since 2020; 
·	dematerialisation initiatives implemented in 2021: 
introduction of digital signature on Credit Lombard 
applications entered through X-Net and the “Digital 
Courier” for the collection of mortgage documents; 
digitalisation of Loan Transparency Letters, Loan 
Acceptance Letters and the E/C Guarantee File;
·	 Reducing plastic consumption: water bottles given 
to all employees since 2021.  
12 	In September 2015, the UN approved the 17 Sustainable Development Goals (SDGs) for the period 2015-2030, divided into 169 targets and adopted by 193 countries 
worldwide. Each UN Member State is responsible for drawing up a National Sustainable Development Strategy, which sets out the most relevant SDGs for the country and 
their respective targets at local level.

19
Initiatives in partnership with Valore D on issues such as: unconscious 
stereotyping, inclusive language, working in diverse teams, empowering 
staff, and gender and sexual harassment in the workplace
DIVERSITY AND EQUAL OPPORTUNITY
Objective: Monitoring and ongoing attention to the Gender Pay Gap issue; focus on issues such as the pro­
motion of women in managerial roles, equal gender representation and the monitoring of how the return 
from maternity leave is managed
% female employees by 
employment category
KPI
Executives: 21%
Managers: 30%
Professionals: 50%
2022
Executives: 17%
Managers: 29%
Professionals: 50%
2021
Executives: 17%
Managers: 28%
Professionals: 51%
2020
2022
2021
2020
HUMAN RESOURCES
Objective: Implementation of an employee training and awareness plan on Diversity & Inclusion and 
sustainability
Diversity and inclusion and 
sustainability training initiatives
KPI
CAREER DEVELOPMENT E PERFORMANCE MANAGEMENT
Objective: Performance management programme aimed at all employees
% of employees receiving regular perfor­
mance and career development reviews13
KPI
- see note 14
2022
97%
2021
97%
2020
13	 The percentage not assessed refers to people who did not work at least 3 months during the year, either due to long periods of absence or because they were hired at the 
end of the year.
14	 Figure not available at the time of publication of this document because the assessments are carried out at the beginning of the year after the year being assessed.
15	 The figure refers to the Engagement & Reputation Survey conducted in 2020..
16	 No. of new hires/no. of employees at period end.
17	 No. of terminations/no. of employees at period end.
Engagement index 
KPI
82%15
2021
77%
2022
82%
2020
Hiring rate16
7%
8%
6%
Termination rate17
3%
5%
3%
ENGAGEMENT / RETENTION
Objective: Initiatives for consultations and turnover monitoring

20
·	 Development of green 
lending:
to be initiated
·	 Transfer of tax credits:
offering available since 
November 2020
LENDING
Objective: Increased offering of products with social and environmental value within the mortgages and 
loans sector
RESPONSIBLE FINANCE
Integration of 
environmental 
aspects into the 
various credit 
solutions offered
KPI
By 2023: 
·	 Development of green 
lending
·	 Offering relating the 
assignment of tax 
credits connected to the 
renovation of buildings 
(110% Superbonus and 
other tax credits)
Target
2021
·	 Development 
of green 
lending:
to be initiated
·	 Transfer of tax 
credits:
offering 
available until 
June 2022
2022
% capital disbursed for 
green mortgages out of total 
granted during the year for 
purchase mortgages
KPI
21%
2021
20%
2022
21%
2020
2020
FUNDS/INVESTMENTS
Objective: Introduction of ESG criteria in product evaluation 
% of new ESG-rated funds 
out of total new ISINs entered 
into the platform since 2021
KPI
% ESG-rated funds out of 
total ISINs in the platform
€/mln assets under 
management ESG-rated 
funds
% SFDR20 Article 8 funds
 in the platform
% SFDR Article 9 funds 
in the platform
100%18 
by 2023
Target
Positive 
change  Y/Y19
100%
2021
83%
30,151
45%
4%
100%
2022
87%
29,372
56%
5%
85% 
(within 2020)
2020
57%
13,667
n.a.21
n.a.
18	 Excluding the UK, which is a newly opened market for Fineco, and extraordinary transactions.
19	 Fineco will be able to provide better coverage on the funds it distributes as the data provided by product houses to ESG rating providers evolves.
20	Regulation (EU) 2019/2088 (Sustainable Finance Disclosure Regulation, SFDR). 
21	 The monitoring was initiated after the entry into force of the SFDR 2019/2088.

21
RESPONSIBLE FINANCE
22	Due to an improvement in the collection and calculation process, the figure has been restated with respect to the figure published in the 2020 Sustainability Report. See the 
2020 Sustainability Report, for the previously published historical figure. 
23	The quantitative targets for the Net-Zero Commitment were set using 2021 as the base year. Consequently, the quantification of the KPIs for the year 2020 is not available..
24	For the sovereign issuers, the source for mapping the Net-Zero targets is: https://www.climatewatchdata.org/. In “Policy Document” and “In law” targets are accepted, while 
“In Political Pledge” targets are not. For the bank emissions, Net-Zero targets on financed emissions were mapped.
Integration 
of ESG aspects 
into different 
investment 
solutions 
in the platform
KPI
Range of insurance solutions expanded 
with the addition of SFDR
 Article 8 and 9 funds
2021
2022
By 2023, design/
enhancement of 
ESG investment 
solutions in advi-
sory:
·	insurance 
·	benchmark certi-
ficates
Target
ESG investment 
solutions 
designed in 
insurance 
advisory: 
FIA ESG
2020
Objective: Promotion and design of new investment solutions integrating ESG criteria
2.1%
2020
% exposure to ESG bonds 
out of total FinecoBank 
portfolio
KPI
€/mln exposure in ESG 
bonds
Positive 
change  Y/Y
Target
3.8% 
2021
892
6.8% 
2022
1,745
47722
INTERNAL INVESTMENT PORTFOLIO
Objective: Increased coverage of green and social bonds in FinecoBank’s portfolio
64.5%
2021
93.8%
2022
·	 95% by 2030
·	 100% by 
2050
Target
n.a.
2020
% exposure in debt 
securities of sovereign and 
bank issuers with a Net-Zero 
in 2050 target24
KPI
Objective: Net-Zero Emissions by 2050 Commitment - Alignment of internal investment portfolio to Paris 
Agreement targets23

22
FINANCIAL EDUCATION/COMMUNITY SUPPORT PROJECTS
25	The figures for donations by customers in 2022 and 2020 were significantly higher than in 2021 as a result of the highly successful fundraising campaigns in support of 
associations in relation to the Russia-Ukraine conflict and the Covid-19 epidemic, in the respective years.
FINANCIAL EDUCATION
Objective: Promotion of specific training and awareness-raising courses on topics such as savings, which 
in future will particularly involve targeted groups such as young people
TRAINING OF PERSONAL FINANCIAL ADVISORS
Objective: Provision of specific training on ESG issues for personal financial advisors in order to meet 
the demands of customers who are more attentive to these issues and, at the same time, to promote 
sustainability among less interested customers
COMMUNITY SUPPORT
Objective: Allocation of annual investments in projects that benefit the community, according to different 
local needs (e.g. schools, universities, hospitals and health and cultural associations) and allocation of 
natural disaster funds (to postpone mortgage and loans payments, and suspend debt collection actions for 
insolvent customers in the event of disasters or natural disasters)
No. of ESG training hours 
provided to the personal 
financial advisors
KPI
20,395
2022
19,804
2021
Financial 
education 
initiatives carried 
out
KPI
Participation in EduFin 2022; 
Two webinars organised in 
collaboration with LifeGate 
on the UN Days
2022
Participation in 
EduFin 2020
2020
-
Activity started in 2021
2020
Charitable donations by Fineco [€]
KPI
Charitable donations by customers 
made through Fineco25 [€]
Sponsorships for social or 
environmental purposes [€]
313,000
2020
2,153,000
366,000
Participation in EduFin 2021;
“Financial Education” section 
created in the video library 
of the website
2021
692,995
2022
406,149
1,169,955
179,000
2021
301,950
250,862

23
·	Valore D
·	UN Global Compact (FinecoBank)
·	UN Principles for Responsible 
Banking (FinecoBank)
·	UN Principles for Responsible In­
vestment (Fineco AM)
SUPPLY CHAIN
SHAREHOLDERS
Objective: Evaluation of suppliers on the basis of ESG criteria, through an initial self-assessment 
questionnaire26
Objective: Strengthening dialogue with socially responsible investors (SRI) and sustainability rating 
agencies
Objective: Participation in external initiatives that support the company’s commitment to ESG matters 
(such as: “Valore D” and UN Global Compact)
% of annual supply volumes 
assessed on the basis of 
ESG criteria out of the total 
annual volumes of suppliers 
with an expenditure ≥ 
€25,000 (incl. VAT)
KPI
12.6%27
2021
21.6%
2022
50%  
by 2023
Target
-
Activity 
started in 
2021
2020
No. of investors engaged in 
ESG-related dialogue
KPI
27
2022
33
2021
29
2020
26	The assessment focuses, for example, on compliance with environmental and occupational health and safety regulations and on the presence of any certifications (ISO 14001, 
ISO 45001, SA8000, ISO 50001 and ISO 37001).
27	Due to an improvement in the collection and calculation process, the figure has been restated with respect to the figure published in the 2021 Sustainability Report. See the 
2021 Sustainability Report, for the previously published historical figure.
List of active 
participations in 
external initiatives
KPI
By 2022, 
subscription to 
the UN Global 
Compact by 
Fineco AM
Target
2021
·	Previous participa­
tions maintained
·	2022 Results: 
subscription to UN 
Global Compact 
(Fineco AM)
2022
2020

24
28	For the year 2022, the methodology for calculating the consumption of the Milan and Reggio Emilia sites was fine-tuned. As a result, the figures for 2020 and 2021 were 
restated. For more details, see Chapter 9 “Environment”. See the 2021 Sustainability Report, for the previously published historical figure. 
29 Here “Worker” refers to employees and personal financial advisors. This figure reflects the number of workers as at 31 December who used the buildings included in the 
reporting scope.
Objective: Implementation of the Environmental Statement
Objective: Energy consumption/emissions: monitoring of internal company consumption with the aim of 
reducing consumption and emissions
ENVIRONMENT
Preparation/updating 
of the Environmental 
Statement pursuant to 
the EMAS Regulation
KPI
The 2021 Environmental 
Statement was drafted 
and approved by the 
Board of Directors on 
12 July 2022
2022
The 2020 Environmental 
Statement was drafted 
and approved by the 
Board of Directors on 
8 July 2021
2021
In progress
2020
Total energy 
consumption 
[GJ]28
Energy intensity 
[GJ/worker29]
KPI
50,606
2021
12
47,686
2022
11
49,679
2020
13

25
30	In 2022, the activities focused on the analysis and design of efficiency measures to be implemented in the coming years. The reported figure refers to the energy savings 
related to the scheduled switch-off of the fan-coils in the building in unused areas on Mondays and Fridays in November and December 2022 (16 working days).
31	 The scope includes the registered office in Milan and the Fineco Centers where Fineco is the registered user of the utilities (15% of all the Fineco Centers and 56% of the 
corporate Fineco Centers in 2022).
32	The figure as at 31/12/2020 also includes the recovery site discontinued in February 2021.
33	For the year 2022, the methodology for calculating the consumption and emissions of the Milan and Reggio Emilia sites was fine-tuned. As a result, the figures for 2020 and 
2021 were restated. For more details, see Chapter 9 “Environment”. See the 2021 Sustainability Report, for the previously published historical figure.
ENVIRONMENT
Objective: Net-Zero Emissions in 2050 Commitment - Reduction of net operating Scope 1, 2 and 3 
greenhouse gas emissions33
Scope 1 and 
2 emissions 
(market-based) 
[tCO2e]
KPI
344
(-16% vs 2021)
2022
410
2021
424
2020
· - 35% vs 2021
	 by 2030
· - 90% vs 2021
	 by 2050
Target
Operational 
Scope 3 
emissions [tCO2e]
· - 20% vs 2021
	 by 2030
· - 90% vs 2021
	 by 2050
1,279
(-4% vs 2021)
1,336
1,356
% electricity 
consumption from 
renewable sources, 
for buildings in which 
the electric utilities 
are registered to 
Fineco31
Emission intensity 
(Scope 1, 2 and 3) 
[tCO2e/worker]
Energy saved 
through efficiency 
measures [kWh]
KPI
214,560 kWh
2021
2,262 kWh30
2022
5,540 kWh
2020
Targets set in the 
energy efficiency 
plan for the company 
registered office, 
which is continuously 
updated
Target
100% 
by 2022
-
99.6%
0.69
100%
0.61
96.8%32
0.77

26
Objective: Material/waste management: reduction of plastic consumption by creating digital credit cards; 
replacement of plastic bottles by installing water dispensers and providing all employees with water bottles; 
purchase of recycled or certified paper and provision of separate collection facilities to all offices
Company offices 
where water 
dispensers have 
been installed
Per capita paper 
consumption [kg/
employee]
% of FSC-
certified paper
Creation of digital 
payment cards
KPI
Target
By 2023:
·	 Registered 
Office - Milan 
·	 Head Office - 
Reggio Emilia
10
2021
57%
-
10
2022
59%
Digital debit and 
reloadable cards 
created
First water 
dispensers 
installed in the 
Milan office
Pilot project launched at Milan 
registered office
12
2020
52%
-
ENVIRONMENT
Objective: Company Fleet – Modernisation of the car fleet with hybrid/electric cars (with the possibility of 
recharging in the parking lot of company offices)
% of hybrid/elec­
tric cars in the 
total car fleet
KPI
28.3%
2021
61.9%34
2022
100% 
by 2024
Target
17.4%
2020
34	Figure net of commercial vehicles.

27
The FinecoBank Group is committed to actively participating in national and international sustainability initi­
atives, with a view to promoting a long-term sustainable business able to manage the challenges of climate 
change and future socio-economic impacts.
COMMITMENTS SUBSCRIBED
FinecoBank has been a signatory to the Principles of the United Nations Global Compact 
(GC) and a member of the respective Italian Network since September 2020, adhering 
to the Ten Fundamental Principles on human and labour rights, environmental protec­
tion and combating corruption. In 2022, Fineco has again used the GC online platform 
for the reporting of the Communication on Progress, therefore further information on 
how the Bank applies the 10 Principles will be available on the GC website following the 
publication of this document. Since March 2022, Fineco AM has also subscribed to the 
Global Compact Principles, aligning its strategies and operations and, in March 2023, it 
will present its first Communication on Progress in relation to its implementation of the 
Principles on the GC platform. 
In 2019, FinecoBank signed an Association Agreement with Valore D, an organisation 
with a network of over 180 companies committed to ensuring an inclusive culture within 
organisations. Thanks to this partnership, Fineco participates in specific training courses 
aimed at promoting female talent within the company (Young Talent, Middle Management 
and Senior Management programme).
Since 2019 FinecoBank has subscribed to the ABI (Italian Banking Association) “Women 
in banking: Enhancing Gender Diversity” Charter, sets out the commitment to enhanc­
ing, promoting and strengthening diversity, including gender diversity, at every level of 
the organisation.
Since December 2020, FinecoBank S.p.A. has been a signatory to the United Nations 
Principles for Responsible Banking (UN PRB), formalising the objective of committing to 
analysing the consequences of its activities from an environmental and social perspec­
tive, and setting goals capable of bringing about measurable improvements in the most 
significant aspects. More information on how Fineco is implementing the Principles for 
Responsible Banking is provided in Annex I of this document.
Since October 2020, Fineco Asset Management DAC has been a signatory to the United 
Nations Principles for Responsible Investments (UN PRI), in the “Investment Manager” 
category, reinforcing its commitment to the development of a sustainable financial sys­
tem by integrating social, environmental and good governance criteria into its investment 
practices. As a signatory to the PRI, Fineco AM will report on its responsible investment 
activities through the UN PRI Reporting Framework by August 2023.

28
* The “MSCI Implied Temperature Rise” rating has been provided by the rating agency since 2021.
** In 2021, FinecoBank responded to the “minimum” version of the CDP Climate Change questionnaire, aimed 
at companies completing it for their first year. The response to the questionnaire was published on CDP’s ded­
icated portal, but it has not generated the CDP scoring. 
*** The ESG Risk Rating from Sustainalytics measures the level of residual ESG risk that companies are ex­
posed to, on a scale of 100 (worst performance) to 0 (best performance).
ESG RATINGS AND INDICES
1.4.	
In recognition of its ESG performance, as certified 
by the main rating agencies, FinecoBank is includ­
ed in the FTSE4Good, Bloomberg Gender Equali­
ty Index (GEI) 2023, S&P Global 1200 ESG Index, 
Standard Ethics Italian Banks Index, Standard Eth­
ics Italian Index and the Euronext MIB ESG Index.
In 2022, the leading ESG rating agencies improved the ratings assigned to the Group.
54
35
18.7
65
54
85
16.0
68
57
13.2
S&P Corporate
Sustainability
Assessment
Moody's ESG
solutions
Reﬁnitiv
MSCI ESG
Rating
MSCI Implied
Temperature
Rise *
CDP Climate
Change**
Standard
Ethics
Sustainalytics
***
Best attainable score
A 
AA 
B 
EE+ 
1.5°C aligned
- 
-
-
Low risk
Very strong  
compliance 
Management 
Leader 
Excellent ESG performance
Robust 
performance 
Sustainability 
Yearbook member 
0 
100 
Best performance 
Best performance 
100 
0 
2020 
2021 
2022 
Key
0-100 
0-100 
0-100 
CCC-AAA 
From D-  
to A 
F-EEE 
100-0 
Rating scale
- 1.5°C Aligned 
Strongly Misaligned

29
ESG PRIZES AND AWARDS
1.5.	
“MF Best ESG rating Award 
2022” and “MF Investment 
Manager & Advisor Award 
2022”  
Fineco was recognised at the 
Sustainable Future Forum, where 
awards were given to companies 
that were able to place them­
selves above the international 
sustainability standards, based 
on the Standard Ethics rating. For 
the third year in a row, Fineco also 
won the “Investment Manager & 
Advisor Awards”, which this year 
again recognised the excellence 
in the Italian asset management 
industry. 
“Top Employer Italia 2022”
For the fourth year running, the 
Bank stood out for its focus on 
empowering human resources 
and on skills development, cre­
ating a positive and stimulating 
workplace.           
World’s Most Socially 
Responsible Banks 2022
Ranked among the most respon­
sible banks in terms of resource 
use, transparency, anti-corrup­
tion, and customer and employee 
management
“Sustainability 
Leader 2022”
Awarded 
by 
Statista/Forbes/Il 
Sole 24 Ore: inclusion of the Bank 
among the 150 companies in Italy 
that stand out for their genuinely 
sustainability-oriented choices.
“Best company in ESG” 
(Mid Cap) for the Italian Investors 
Relations Awards 
Nominated as  
S&P’s Sustainability 
Yearbook Member

30
MEMBERSHIP OF ASSOCIATIONS

Fineco’s commitment is also expressed through close and 
trusting partnerships with leading financial bodies and 
institutions. Major memberships and collaborations include:
ABI: industry association aimed at protecting the interests of banks by organising studies and debates on par­
ticular topics and providing assistance and information;
ASSIOM FOREX: international financial association that promotes training and the dissemination of technical 
information and market practices, contributing to the development and integrity of European and international 
financial markets;
ASSOAML: association whose objective is to establish the first and sole “aggregation centre” for obliged enti­
ties and experts on regulations for the prevention of the use of the financial system for the purpose of money 
laundering and terrorist financing;
ASSOGESTIONI: Italian Association of Savings Managers; represents the main Italian and foreign asset man­
agement companies operating in Italy, as well as banks and insurance companies operating in asset manage­
ment and supplementary pensions. Since 2019, membership fees to Assogestioni have been paid by Fineco 
Asset Management DAC;
ASSONIME: Italian association of Italian joint-stock companies that deals with issues connected to the inter­
ests and development of the Italian economy. The association provides its members all the tools they need to 
navigate a complex legislative scenario through studies, research, in-depth analysis and opinions, in addition 
to providing an exclusive advisory service;
ASSORETI: an association of banks and investment firms that provide investment advisory services, keeping 
up-to-date with the planning and evolution of related regulations, ensuring contact with institutions, and pro­
moting and organising studies, publications, conferences and any other related research;
ASSOSIM: one of the main Italian associations of financial market intermediaries that carries out research and 
training activities and represents members in consultations on regulatory and financial issues promoted by 
Italian and international regulatory authorities;
Associazione Italiana Private Banking (Italian private banking association): association representing com­
panies that operate in the private banking sector in Italy, aiming to bring together, share and develop private 
business culture;
CBI: the association for interbank corporate banking, which provides a wide range of financial, informational 
and commercial functions, using a single standard of communication and guaranteeing a service based on the 
cooperation of banks but without reducing the competitive space;
Conciliatore Bancario Finanziario (Banking and Financial Arbitrator): a non-profit association specialised in 
financial and corporate banking disputes;
Fondo Interbancario di tutela depositi (Interbank Deposit Protection Fund): obligatory consortium recog­
nised by the Bank of Italy that covers nominative deposits in the event of bank default. The Bank also partici­
pates in the Voluntary Scheme of the Interbank Deposit Protection Fund;
Fondo Nazionale di Garanzia (National Guarantee Fund): a fund whose members are financial intermediar­
ies, with the purpose of guaranteeing compensation to investors that are customers of its members (such as 
banks, brokerage companies, asset management companies) in the event of compulsory administrative liqui­
dation, bankruptcy or composition with creditors;
PRI.Banks: association of Italian Private Banks, which is the key organisation for banking firms with a solid own­
ership structure, often family and management based, strongly focused on operational management;
UPA: a membership body that brings together important industrial, commercial and service companies that 
invest in advertising and communication in order to make their products and services better known.
For 2022, the membership contributions paid amounted to €1,071,442. In addition, no contributions were made for 
lobbying activities or for local, regional or national political campaigns or to political organisations and candidates.
1.6.

31
31
31

32
02

33
STAKEHOLDER RELATIONS 
AND MATERIALITY ANALYSIS
2.1.	
STAKEHOLDER ENGAGEMENT 
2.2.	
MATERIAL TOPICS

34
STAKEHOLDER ENGAGEMENT 
Doing business responsibly means working to create 
value for all stakeholders, as well as understanding how 
Fineco’s actions can be influenced or influence those 
stakeholders. 
The updating of the Stakeholder Map, started in 
2021, was completed in 2022. This process was 
based on a benchmarking exercise designed to 
identify a complete list of Fineco’s internal and exter­
nal stakeholders, followed by a questionnaire sent 
to identify the Bank’s Top Management, with the aim 
of prioritising the engagement of the stakeholders 
identified. Through the questionnaire, the manage­
ment involved assessed the importance to and in­
terest in Fineco, for each stakeholder, as well as the 
willingness of the various stakeholders to be en­
gaged and the method of engagement most aligned 
to their needs, capabilities and expectations. Com­
pared to the previous map (2020), which included 
Customers, Employees, Personal Financial Advisors, 
Regulators and Shareholders, the assessments con­
ducted identified “Money Savers” as a new category 
of relevant stakeholder, while the Shareholders cat­
egory was more precisely defined as the “Financial 
Community”, including Shareholders, Investors, An­
alysts and Proxy advisors. The priority stakeholders 
identified were involved in the update of the Materi­
ality Analysis, as described in the paragraph below. 
In order to engage stakeholders in its activities, mak­
ing the most of their roles and potential, over the 
years Fineco has developed numerous listening and 
interaction initiatives that involve the Bank’s many 
stakeholders on an ongoing basis, so as to better 
manage their mutual relations. Through a careful 
analysis of the needs and opinions of each stake­
holder, the Group can develop more targeted strat­
egies and improve its decision-making process and 
range of products and services.
The categories of stakeholders (internal and exter­
nal) assessed as being material to Fineco and the 
main related dialogue tools used are set out below.
2.1.

35
35	The increase was mainly due to complaints received concerning the tax credit assignment service and payment cards.
36 Please note that the deadline for processing the 2022 complaints that have not yet been handled is 2023.
37 The TRI*M index is produced by a proprietary algorithm that combines satisfaction and preference indicators and measures the strength of the customer relationship.
38 	Measured on a scale of 200 points, with a minimum of “minus 50” and a maximum of “plus 150” and a error margin of +/- 2%. FinecoBank’s score in the TRI*M new index 
can therefore be considered to represent a high level of satisfaction.
CUSTOMERS 
To respond to customer needs, Fineco is always 
keen to gather useful input from customers and from 
the Network, as the voice of its customers, in order 
to improve its products and services. This includes 
the use of chats and surveys arranged during digital 
meetings in education sessions, as well as exchang­
es of opinions during in-person meetings at industry 
events, as listening tools.
Communications with customers are also based 
on constant dialogue through the internal Customer 
Care service and the network of personal financial 
advisors. In order to do this, customers must have 
access to appropriate channels for sharing feed­
backs and complaints that they may have, and that 
help the Bank to gather the information necessary 
to implement the processes of continuous improve­
ment and to refine the products and services that 
lie at the heart of Fineco’s success. FinecoBank 
manages around 367,000 contacts every month 
by phone, email, chat and SMS with high levels of 
service, in which around 87% of the requests for as­
sistance from the customers are dealt with directly 
during the conversation. Customer complaints are 
analysed and recorded, with great attention placed 
on this activity in order to improve the service quality 
provided. In 2022, 3,297 complaints were received 
(compared to 2,742 in 2021)35 and 3,249 were pro­
cessed (of these, 314 were received in 2021) 36.
Another important indicator for assessing the over­
all relationship between the Bank and its customers 
is the Customer Satisfaction Index (TRI*M new in­
dex37, produced by Kantar Italia, an independent firm 
and market leader), which showed a score of 95 38
at the end of 2022. In recent years this has also 
been accompanied by the development of a more 
structured management of the Fineco profiles on 
Trustpilot, an online platform for product and ser­
vice reviews, where users can give a score of 1 to 
5 to the company they are reviewing: Fineco is the 
No. 1 bank in Italy in terms of number of ratings and 
score, at 4.7 out of 5. This score reflects a track re­
cord of satisfaction and positive feedback, with 82% 
of reviews at the top of the rating. 
In addition, to enable more precise measurement of 
the rate of customer satisfaction through the contact 
channels, a feedback system has been implement­
ed: at the end of each interaction, the customer is 
asked to provide his/her level of satisfaction with the 
assistance received, or the reasons for any dissatis­
faction. These comments are analysed on a daily ba­
sis, and are the driver for the ongoing review of the 
internal processes, to respond to changing custom­
er needs, with a view to simplifying services and ren­
dering them increasingly accessible. In this regard, 
in 2022 the percentage of customers expressing 
dissatisfaction was stable at 3% (of which less than 
1% related directly to dealings with the Customer Re­
lationship Management staff). 
EMPLOYEES 
FinecoBank measures the motivation and level of 
engagement of staff and, based on their input, de­
fines and implements specific action plans to focus 
on in subsequent years.
In 2022, the new Engagement & Reputation Survey 
was launched to determine not only the employee 
Engagement Index, but also the level of Fineco’s 
reputation among the employees. The response 
rate was 70.4%, a sign of the strong interest of em­
ployees in these issues, while the Engagement In­
dex, in a context of a general reduction within the 
Italian population sense of belonging to the compa­
nies where they work, maintained a very good per­
formance level of 77%.

36
The results of the survey identified that:
·	 the level of engagement was 75% for the female 
population and 78% for the male population;
·	 employees in the “Executives” category were the 
most engaged (95%), followed by “Middle Manag­
ers” (80%) and the “Professional Areas” (74%);
·	 in terms of age, the highest level of engagement 
(above 80%) was found in the under 25, 26 - 30, 
41 - 45 and 56 - 60 age groups. The 36 - 40 years 
and 51 - 55 years age groups ranged between 
75% and 78.5%, while the 31 - 35 and 46 - 50 age 
groups ranged between 71% and 75%. 
A specific question was also introduced in the En­
gagement & Reputation Survey 2022 to investigate 
employee perceptions of the level of inclusion in the 
company: 66.5% considered Fineco to be a compa­
ny able to guarantee an inclusive working environ­
ment, where everyone can express their potential 
regardless of gender, age, nationality, disability sta­
tus, or political views.
People Care, Working Environment, Work-Life Bal­
ance, Best Place To Work and People Development 
are the thematic “areas” that Fineco is focusing on 
as a result of the findings of various feedback initia­
tives involving all employees. Work on these topics 
continued in 2022 through the following initiatives:
·	 Induction: welcoming new employees who meet 
with Human Resources to learn about and explore 
their new working environment;
·	 Induction 1 year later: digital onboarding involving 
employees in a half-day of information/training 
sessions, a year after being hired, with the Deputy 
General Managers and Human Resources, and a 
virtual escape room game involving all the partic­
ipants. This gives employees the opportunity to 
explore topics related to the Bank’s strategy by 
talking freely with the Deputy General Managers 
and Human Resources.
·	 Focus groups aimed at engaging employees in 
issues important to the development of the busi­
ness and the implementation of products and ser­
vices, and gathering their feedback for continuous 
improvement.
PERSONAL FINANCIAL ADVISORS
The implementation of the network strategy does 
not involve a rigid top-down approach, but is always 
based on listening to the needs, suggestions and 
the variety of contributions from the advisors who 
have direct contact on the ground and are more 
aware of customer needs and how they are chang­
ing, in addition to readily coming into contact with 
alternative solutions offered by competitors, which 
Fineco has always considered as incentives for im­
provement. To this end, the Bank organises periodic 
consultations with the network: in 2022, the meet­
ings and discussion sessions continued both in per­
son and via web, aimed at sharing results, assessing 
initiatives and activities implemented or to be imple­
mented, analysing the needs of customers and ad­
visors, and discussing the launch of new products, 
projects and upcoming releases. Specifically, the 
Group organised the following:
·	 1 Area manager meetings;
·	 9 Web conferences with Area Managers to ex­
change and align results;
·	 4 Discussion sessions in small groups with area 
managers;
·	 1 Managers Convention (Area Managers, Group 
Managers and Ambassadors);
·	 1 Private Banking Convention (Private Bankers, 
Senior Private Bankers and Ambassadors);
·	 1 Kickoff and 1 in-person meeting for the Ambassa­
dors; 
·	 2 Web conferences with Ambassadors;
·	 41 days dedicated to recruiting and meetings, in­
cluding training sessions, with Area Managers and 
Group Managers to discuss methods and strate­
gies and plan activities and objectives;

37
·	 5 days dedicated specifically to the adoption of 
the recruiting platform, in which all the features 
available were presented through demos and 
practical exercises.
Additionally, 21 days were dedicated to the so-
called “area plenaries”, meetings where the Area 
Managers and a senior figure from the Bank meet 
with the personal financial advisors to take stock of 
the results achieved, the objectives to be pursued 
and the new developments in the pipeline.
All these moments of engagement give rise to ideas 
and identify needs for creating and revising prod­
ucts and processes to enhance their decisiveness 
and efficiency and achieving increasingly ambitious 
results.
REGULATORS
Under the current regulatory framework, the Bank 
must ensure that the supervisory disclosure require­
ments are met as expressed by the Regulatory Au­
thorities, as part of transparency and fairness practic­
es, in order to support the stability of intermediaries 
and a competitive and sustainable financial market.
The Regulatory Affairs Team – for the Bank and for 
the entire Fineco Group – manages relations with the 
Resolution Authority and the Supervisory Authorities, 
both at European level (ECB) and at local level (Bank 
of Italy). Specifically, in 2022, following Fineco’s clas­
sification as a Significant Institution, the Regulatory 
Affairs Team managed relations with the European 
Central Bank, the Bank of Italy and the Single Res­
olution Board (SRB). The Team also supported the 
Compliance Department in managing relations with 
the Supervisory Authorities.
The Bank is committed to ensuring that supervisory 
information requirements are met and accordingly, 
in line with its practice of transparency and fairness, 
relations with the regulatory authorities are based on 
principles of integrity, transparency, fairness, profes­
sionalism and cooperation, in accordance with the 
institutional role assigned to the various authorities 
and in compliance with the procedures established 
by the applicable regulations.
FINANCIAL COMMUNITY
Fineco promotes ongoing, transparent and com­
prehensive dialogue with the financial community 
(shareholders, investors, analysts and proxy advi­
sors). The relationship is managed through period­
ic meetings and conference calls with institutional 
shareholders and analysts. The Investor Relations 
team provides accurate, effective and timely com­
munications on the Bank’s financial performance, 
strategy and development, in order to facilitate a 
fair evaluation of the Bank and build its shareholder 
base in the long term. 
In this context, the Bank has adopted the Policy for 
managing dialogue with the Financial Commu­
nity, which sets out the rules, responsibilities and 
processes for the implementation and management 
of the dialogue, compliance with the principles of 
transparency and equal treatment of information 
provided to the financial community, and ensuring 
that the information is clear, complete, true and not 
misleading. 
As a public company, Fineco focuses particular atten­
tion on maintaining and nurturing ongoing dialogue 
with long-term investors to ensure the alignment of 
interests of the parties and create shareholder value.

38
The year 2022 was characterised by ongoing dia­
logue with the Financial Community, conducted 
through virtual and in-person events: 
·	 23 days spent attending international conferenc­
es;
·	 11 days of roadshows around the world;
·	 Individual one-to-one meetings/group meetings/
conference calls and video calls;
·	 4 official conference calls to present quarterly fi­
nancial results to the market.
There were 534 interactions with institutional 
investors during the year. With regard to the inter­
action of ESG issues, there were 27 interactions 
during 2022, in addition to the ad hoc requests re­
ceived continuously during the year. In September 
2022, Fineco also took part in the Italian Sustainabil­
ity Week organised by Borsa Italiana.
MONEY SAVERS  
Money savers, who constitute a new category of rel­
evant Stakeholders for the Group, include the part 
of the community that puts aside part of its income 
and has the opportunity of enjoying the fruits of its 
savings. Their engagement by Fineco takes place 
through its financial education initiatives, which seek 
to help improve the community’s understanding of 
the financial products and the concepts underlying 
them, with a view to developing the abilities and 
knowledge needed to comprehend the risks and the 
opportunities of making informed financial choices. 
These initiatives and the related data on participa­
tion are described in Chapter 8 – “The Community”.

39
MATERIAL TOPICS
The materiality analysis is the core process of pre-
paring the Non-Financial Statement. Its aim is to se-
lect the economic, environmental and social matters 
to be reported.
The Analysis started with an extensive list of po-
tentially relevant topics, identified through desk re-
search on sustainability aspects considered relevant 
by regulators, sustainability reporting standards, Fi-
neco’s peers and leading ESG rating agencies. 
The most relevant stakeholders for the engage-
ment were identified (Employees, Personal Financial 
Advisors, Customers and Investors) in line with the 
updated map described in the section above, and 
were then engaged through a survey, conducted in 
July 2022, aimed at identifying the key sustainabili-
ty topics. The questionnaire, aimed at investigating 
the importance of the topics based on the concept 
of double materiality, asked these stakeholders to 
express their views on: 
·	 the importance of the topics with respect to the 
positive and negative impacts generated by Fine-
co’s business on society, the environment and the 
economy (inside-out perspective);
·	 the importance of the topics that pose the greatest 
risks to Fineco and its operating and financial per-
formance (outside-in perspective).
The results of the survey led to the preliminary 
identification of 19 priority topics, which were then 
aggregated to arrive at the definition of 10 material 
topics. The resulting material topics identified were 
then mapped against the main ESG and reputational 
risk categories identified and assessed in the Risk 
Inventory. 
 
The final results showed that most of the topics that 
had already been present in the previous Materiality 
Analysis, but were further expanded with new facets 
and definitions. The 10 material topics for Fineco 
can be depicted through the following matrix.
2.2.	 
Protection of the 
environment
Group’s solidity 
and resilience
Correctness 
and transparency 
of information 
Responsible
Finance
Customer
Satisfaction
Cybersecurity
and information
security
Innovation
TOPICS THROUGH WHICH FINECO GENERATES IMPACTS ON THE ENVIRONMENT, SOCIETY AND ECONOMY
TOPICS THAT POSE THE GREATEST RISKS FOR FINECO
LOWER RISKS
HIGHER RISKS
LOWER IMPACTS
HIGHER IMPACTS
Financial 
education and 
advice
Business ethics 
and compliance culture 
Fair and inclusive work
environment through talent
attraction and retention
strategies and meritocratic
remuneration policies

40
The new aspects compared to the previous year are set out in the table, in terms of both new material topics 
and new definitions for topics already present in previous analyses.
PRIORITISED LIST OF 
MATERIAL TOPICS
DESCRIPTION
CYBERSECURITY AND 
INFORMATION SECURITY
•	Identifying and managing information security risks 
•	Ensuring the protection and confidentiality of information and data 
through the continuous development and strengthening of appropriate 
tools and technologies
CUSTOMER 
SATISFACTION
•	Ensuring customer focus by providing continuous assistance in the 
operational management of Fineco’s services and guaranteeing 
efficient support
•	Listening to customer needs and expectations, supporting them in 
managing their savings through constant dialogue with the network of 
personal financial advisors and offering services and products focused 
on excellence
INNOVATION
•	Investing in digitalisation through technological and innovative 
tools to improve operations, processes, products and services
•	Simplifying the lives of our customers through the development 
and continuous implementation of user-friendly products and 
services that meet their needs by harnessing technology
RESPONSIBLE FINANCE
•	Developing and implementing financial services and products 
that consider environmental, social and governance matters while 
minimising risk, without sacrificing opportunities for return
•	Providing a product and service offering that promotes financial 
inclusion and access to financial services and products
GROUP’S SOLIDITY AND 
RESILIENCE
•	Adopting a corporate governance system that promotes clear and 
responsible banking, contributing to the creation of sustainable long-
term value
•	Adopting a resilient business model capable of maintaining healthy 
operating and financial performance, ensuring the Group’s capital 
strength
•	Protecting and strengthening the corporate identity and reputation 
CORRECTNESS AND 
TRANSPARENCY 
OF INFORMATION 
•	Promoting ongoing, transparent and comprehensive dialogue with 
the financial community, in line with the company strategy of creating 
value for shareholders over the long term
•	Preparing and adopting instruments governing behaviour and values 
that ensure integrity in business conduct
•	Clearly and transparently communicating the services and products 
offered, as well as their conditions, to help customers understand 
them and make informed choices

41
PRIORITISED LIST OF 
MATERIAL TOPICS
DESCRIPTION
BUSINESS ETHICS AND 
COMPLIANCE CULTURE
•	Adopting and disseminating ethical values and conduct, including 
conduct to safeguard and protect personal data of the Bank’s 
stakeholders, in order to ensure high standards of professional 
conduct and integrity in conducting the business in compliance with 
applicable regulations
FINANCIAL EDUCATION 
AND ADVICE
•	Promoting improved understanding of the financial products and 
the concepts underlying them among the community, with a view to 
developing the abilities and knowledge needed to comprehend the 
risks and the opportunities of making informed financial choices
•	Establishing a relationship of trust between customers and advisors, 
based on the advisor’s ability to identify customer needs and 
expectations, and to devise and agree on investment and overall 
wealth management solutions
FAIR AND INCLUSIVE WORK 
ENVIRONMENT THROUGH 
TALENT ATTRACTION AND 
RETENTION STRATEGIES 
AND MERITOCRATIC 
REMUNERATION POLICIES
• Creating and ensuring a fair and inclusive work environment where 
people can realise their full potential and where appropriate 
remuneration and incentive policies are designed within strategies 
aimed at attracting, retaining and motivating staff
PROTECTION OF THE 
ENVIRONMENT
• Minimising the direct environmental impacts produced by adopting 
policies and measures aimed at reducing emissions and improving 
consumption efficiency to ensure responsible use of resources
•	Assessing and understanding the indirect environmental impacts 
related to the business and implementing climate change 
mitigation plans and actions

42
03

43
OUR CUSTOMERS
3.1. 	
CYBERSECURITY AND INFORMATION SECURITY
3.2. 	
RESPONSIBLE PRODUCTS AND INVESTMENTS
3.3. 	
FINANCIAL INCLUSION
	
3.4. 	
FAIRNESS AND TRANSPARENCY IN CUSTOMER COMMUNICATIONS

44
For twenty years, Fineco is committed to making life 
simpler for its customers, courtesy of the unique na­
ture of its business model, which is designed to offer 
innovative, simple and efficient services. Increasing 
digitisation in Italy is changing consumer behaviour 
and expectations in everyday life. This structural 
trend increasingly encourages customers to choose 
their main bank on the basis of the quality of the ser­
vices and products offered and the overall customer 
experience, rather than merely in accordance with 
geographical proximity. For this reason, the contin­
uous improvement of the customer experience is 
crucial for Fineco, and this in turn is founded upon 
the concept of simplicity, which is one of the Group’s 
characteristic features. 
To simplify the lives of customers, the FinecoBank 
offering is based on the One Stop Solution concept: 
the customer can access banking, brokerage and in­
vestment services through a single current account. 
However, offering a “single solution” is not enough: 
Fineco’s goal is to deliver excellence at all times. 
Thanks to our deeply-rooted internal IT culture, Fine­
co is able to make full use of the value derived from 
knowing our customers, who make extensive use of 
the Group’s proprietary platforms, and we are con­
tinuously striving to develop user-friendly, top-quali­
ty products and services that meet all their financial 
needs. 
The success of the Group is founded upon the rela­
tionship of trust it has established with its customers, 
with regard to whom Fineco is committed to adher­
ing to strict standards of professional ethics, based 
on the principles of fairness, transparency and sim­
plicity in all services and communications. Observ­
ing proper conduct when engaging in business ac­
tivities is of fundamental importance to Fineco, and 
the company’s Integrity Charter and Code of Con­
duct Global Policy car serve to formalise the obliga­
tion of employees and personal financial advisors to 
act with due diligence and with the necessary pro­
fessionalism in every interaction with customers, al­
ways considering their needs, expectations and any 
potential benefits first and foremost. In this regard, 
the Code of Ethics also stipulates that relations with 
the Bank’s customers (regardless of whether public 
or private) must always be founded upon the criteria 
of honesty, courtesy, transparency, fairness, profes­
sionalism and collaboration.

45
CYBERSECURITY AND INFORMATION SECURITY  
Fineco’s distinctive business model is based on 
the innovative distribution of financial services that 
combines the efficiency of mobile and online digital 
channels, able to reach a variety of customer targets. 
The Bank’s transactional platforms and advisory ser­
vices are developed in-house using state-of-the-art 
proprietary technologies to make customer expe­
rience a more fluid and intuitive experience on all 
channels. Customer satisfaction, in terms of user 
experience, reliability, security and differentiation of 
services/products they can use, is a key element of 
Fineco’s success. 
At the same, in a world of growing digital complex­
ity, information security has become crucial for the 
banking industry. The most topical issues are cyber­
crime, online fraud, identity theft and hacktivism. 
Special attention is therefore paid to the issues of 
Cyber Security & Fraud Management right from 
the design of the systems. They are seen as key to 
properly defining the solutions and services offered, 
including taking advantage of opportunities offered 
by evolving regulations, in order to offer custom­
ers full security while maintaining simplicity of use. 
Specifically, the security and availability of data and 
services in a highly digitalised environment, as well 
as the effective and swift handling of fraud attempts 
that could cause damage to the Bank or its custom­
ers, are key components of Fineco’s operations.
The steps taken to improve IT security management 
help mitigate the Group’s exposure to operation­
al and reputational risks. The necessary measures 
are taken to minimise the risks inherent in the servic­
es offered, applying best practice in the field of se­
curity and ensuring that management vision and ICT 
risk are aligned, as well as the uniform application of 
the rules on information systems. 
Specifically, the processes and activities for the gov­
ernance and management of IT security and the 
related risk are organised based on a model involv­
ing the Bank’s corporate bodies and the various cor­
porate functions, in accordance with their respective 
responsibilities and in line with the checks connect­
ed to the three types of controls established in the 
Internal Control System. In this context, the “human 
factor” is one of the most important protection rings 
for Fineco, which is why it is essential to continue 
ensuring that customers, employees and manage­
ment are aware of possible threats, enabling them 
to recognise them and react appropriately. To this 
end, various initiatives were implemented in 2022, 
including training for employees and PFAs, special­
ised communication campaigns for customers, the 
overhaul of the security & fraud section of the web­
site, simulations of adverse cybersecurity scenarios, 
and exercises on ethical hacking challenges.
The increase in the complexity of the operating envi­
ronment, as well as the information systems support­
ing the company’s operations, has prompted Fineco 
to adopt a structured approach to governing both 
IT and Security. This has been achieved by leverag­
ing the strength of the management’s commitment 
in this area, which sees the information system and 
technology as key factors for success in increasing 
value for the Bank’s customers. 
In addition, the constant and continuous dialogue 
with investors in 2022 confirmed the stakeholders’ 
interest in the Bank’s approach to ICT and security 
issues, both current and future, highlighting the need 
to continue evaluating the opportunities for evolu­
tion and growth already identified, including the zero 
trust model, third party security and resiliency issues.
The main drivers considered in setting strategic 
ICT&Security objectives are detailed in the ICT & Se­
curity Strategic Guidance Document, updated and 
approved by the Board of Directors in 2021, which 
is the cornerstone of a broader set of documents 
governing FinecoBank’s ICT & Security Governance. 
This document sets out to the multi-year guidelines 
for the development of the information system, in line 
with the structure of the sectors of operations, orga­
nisation and corporate strategy identified in Fineco’s 
Multi-Year Plan and taking into account the evolution 
of the sector, as well as compliance with regulatory 
3.1.

46
developments. The diagram below shows the main 
drivers considered for the definition of the ICT & Se-
curity strategic objectives and the related enablers, 
i.e. the technological elements that are fundamental 
for the implementation of the strategy established. 
The ICT & Security Strategy is then set out annual-
ly in a specific Operational Plan, which describes 
the main project initiatives identified to achieve the 
strategic objectives and is submitted to the CEO and 
General Manager for approval. 
The main ICT & Security project initiatives, identified 
to achieve the objectives described in the Strategic 
Guidance Document, are agreed and approved an-
nually by the CEO and General Manager. The pro-
gress of these initiatives is continuously monitored to 
ensure their alignment with the strategic objectives, 
promptly communicate any problem issues arising 
during the course of the various projects and, con-
sequently, identify and implement appropriate cor-
rective solutions to avoid jeopardising the fulfilment 
of the plan. The Board of Directors annually reviews 
and approves the expenditure budget for maintain-
ing the efficiency of the ICT & Security Resources.
The effectiveness of the implementation of the ICT & 
Security Strategy is ensured by means of the Sum-
mary Report on Adequacy and Costs, which provides 
details on annual basis of the effectiveness of the 
services provided in relation to the costs incurred, 
together with an overview of the developments in 
the relevant topics in ICT, Security and Fraud, includ-
ing: organisational structure and resources, security 
awareness & training, availability management, inci-
dent and security incident management, disaster re-
covery, and anti-fraud management for payments. In 
addition, the Report provides a comparison at Italian 
level with other banks listed on the stock exchange 
or using industry sector analyses as a reference (e.g. 
CIPA – ABI, Gartner). This document is submitted to 
and approved by the Board of Directors.
During 2022, through the work of the Head of the 
CIO Department, further information was also pro-
vided to the Board of Statutory Auditors on the ICT 
& Security Strategy and its implementation, the evo-
lution of the landscape of cyber threats and attacks, 
and the performance in relation to Security & ICT 
incident management, Disaster Recovery and the 
management of ICT & Security risks. In addition, in 
May 2022, a specific information initiative on ICT 
Strategy, Security & Fraud was organised for the 
Board of Directors, which had a participation rate 
of 90% and illustrated the models implemented by 
the Bank, together with the opportunities related to 
those models, and current and future IT and security 
risks. 
FinecoBank dedicates and invests considerable re-
sources in pursuing these strategic objectives and 
around 16% of its staff work in the Department (of 
which 11% are women). The Department includes 
the dedicated Information Security & Fraud Man-
INTERNAL SKILL & COMPETENCIES
«IN HOUSE» APPROACH
1
2
3
4
Digitalization
Reliability
Efficiency
Resiliency
Flexibility
Data Driven
BIG DATA ANALYTICS
INNOVATIVE PLATFORM
CLOUD
CYBERSECURITY
KEY DRIVERS

47
agement Team, which is responsible for supporting 
and managing the adoption of policies and guide­
lines aimed at ensuring the security properties of the 
information and corporate assets in various areas, 
such as applications, network, asset management, 
device management, and patch/change/vulnerabili­
ty management, in order to avoid system breaches 
and data loss or damage.
The Team also manages information security inci­
dents using a structured and integrated incident re­
sponse framework, whose guidelines and roles are 
set out in the ICT Security Incident Management 
and Emergency and Crisis Management Group 
Policies. Specific detailed processes have also been 
developed to ensure swift and effective handling of 
the different types of events. 
The main objectives of the security incident man­
agement process are: 
·	 to quickly detect and identify damaging events; 
·	 to minimise the impact of those events; 
·	 to quickly identify and implement the appropriate 
counter/containment measures; 
·	 to identify and implement all the post-incident re­
covery operations;
·	 to collect and collate all the data and information 
needed to trace the events that have occurred, 
also in order to duly support the relevant com­
munications to the authorities and/or law enforce­
ment agencies, where necessary.
These objectives are pursued through an approach 
to the management of security incidents, which in­
cludes an effective combination of prevention activ­
ities, aimed at preventing incidents and proactively 
identifying/detecting events that could lead to po­
tential security incidents, and responsive activities, 
aimed at responding to incidents by adopting strate­
gies to manage and contain them. 
In terms of sourcing, over the years FinecoBank’s 
strategic choice has been to internally handle all 
technological and security activities that could make 
a significant contribution to the development of busi­
ness. This has allowed the Bank to offer customised 
and distinctive products, maintain a high level of 
know-how and internal control over the evolution of 
its technology and services, retain intellectual prop­
erty of the applications developed and their support­
ing algorithms and ensure cost competitiveness and 
rapid time to market, in addition to better and con­
sistent performance in service delivery.
Lastly, the Information Security & Fraud Manage­
ment Team, also handles the fraud management for 
customer transactions. The security strategy con­
sists of a multilayered approach, based on in-depth 
knowledge of the Bank’s customers, behavioural 
analysis and risk assessment, designed to enhance 
and improve the effectiveness of the existing an­
ti-fraud process, while maintaining a high level of 
user-friendliness. Over the years, the internal de­
velopment in this area has enabled FinecoBank to 
achieve some of the best results in the Italian and 
European banking industry, particularly in relation to 
banking, payments and card fraud. This has been 
made possible by a sourcing policy and an internal 
development approach, which have allowed the 
Bank to have a very high level of control on fraud, 
allowing it to adapt quickly to evolving threats and 
new trends in these areas.
The incident management strategy can be summarised as illustrated in the diagram below. 
DETECTION
Timely reporting by any 
user who becomes aware 
of/detects a suspicious 
security event
IDENTIFICATION
Recording and classifying 
the security incident also 
in terms of severity
CONTAINMENT & 
ERADICATION
Activation of the 
technological/ 
organisational response 
measures necessary to 
manage the incident
COMMUNICATION & 
ESCALATION
Communication/ 
escalation management 
consistent with incident
type/severity
REPORTING
Reviewing the occurrences 
and assessing the 
effectiveness and 
efficiency of the protection 
measures in place and the 
operational security 
procedures

48
In 2022, FinecoBank used external third parties to 
conduct security assessments, on both a continuous 
and on demand basis, to identify potential threats 
and vulnerabilities that could impact systems/servic­
es, with the aim of verifying the security measures in 
place and considering the implementation of addi­
tional protection measures, where necessary. 
In addition, in 2022, assessments were conducted 
on the Data Centers, with the support of specialist 
external companies, aimed at ensuring the update of 
the analyses of the associated environmental risks 
and the assessment of the adequacy of the physical 
security measures adopted. 
An independent verification was conducted by an 
external third party in 2022, which generated a 
positive outcome, aimed at assessing the method­
ology and model adopted and the fraud rates in ac­
cordance with Delegated Regulation (EU) 2018/389 
(PSD2).
Lastly, the Bank the positive outcome of the External 
Independent Assessment of the security measures 
relating to SWIFT operations was confirmed.

49
RESPONSIBLE PRODUCTS AND INVESTMENTS
Fineco’s aim is to continuously consolidate its strate­
gy for sustainable growth, in the belief that investing 
responsibly means helping to generate a positive 
social and environmental impact in the long term, 
minimising risks without sacrificing opportunities for 
yield and growth of the business. The Advisory, Third 
Party & Private Banking Solutions and Product and 
Services functions are responsible for promoting 
and implementing this strategy within the Group’s 
products. 
In line with the strategy, since 2021 the Group contin­
ued to enhance the integration of sustainability into 
its business activities. Indeed, in the update of the 
New Product Process – Global Policy, the process 
of assessment of the risks associated with new prod­
ucts and substantial changes to existing products 
was integrated into the assessment of sustainability 
risks, establishing the requirement for any environ­
mental sustainability, social and/or governance ob­
jectives to be included among the features of the 
products contained in the identification sheet.
In line with EU Regulation 2088/2019 (Sustainable Fi­
nance Disclosure Regulation - SFDR), in March 2021 
Fineco adopted the document “Policies on inte­
grating sustainability risks into advisory services”, 
which provides information on the policies currently 
established by FinecoBank, as an intermediary of­
fering investment advisory services, for the integra­
tion of sustainability risk into the provision of those 
services and considering the main adverse effects 
on sustainability factors generated by the advised 
investments. 
Fineco makes a positive contribution to the devel­
opment of the economy and the protection of the 
environment through the development of specif­
ic Banking and Credit products. In particular, the 
green mortgage offering promotes the renovation of 
Italy’s stock of real estate, and the continuous work 
on dematerialisation of product request/manage­
ment processes has cut paper consumption. 
Specifically, a “Virtual” card offering was introduced 
in 2022 for debit and prepaid card products request­
ed after opening an account. In this offering, there is 
no plastic version of the card and it can be used im­
mediately after being issued, using the information 
available in the Reserved Area of the website or on 
the Fineco APP.
In addition, the success continued of the green 
mortgage39, which enables the financing of the pur­
chase of class A or B energy properties through a 
mortgage loan, at favourable conditions compared 
to the standard price list. Over the course of the year, 
18% of all new purchase mortgage agreements fell 
into the green mortgage category, amounting to a 
total of €63 mln, or roughly 20% of the total amounts 
disbursed by the Bank for purchase mortgage 
agreements in the same year.
Lastly, the offering to customers relating to the trans­
fer of tax credits under the 110% Superbonus initia­
tive for the energy upgrade and reduction of seismic 
risk of buildings, with a completely paperless pro­
cess, continued until the end of June 2022. 
The Banking & Credit Products Unit regularly mon­
itors sales volumes and product developments on 
the market, also by analysing competitors, to identify 
any signs of an ineffective offering or find new ideas 
for the launch of products, also from a sustainability 
perspective. Where appropriate these are added to 
the roadmap of pipeline projects and their progress 
is monitored in collaboration with the Sustainability 
Unit. Product development is mainly guided by the 
needs gathered directly or indirectly from custom­
ers, with a focus on responsible finance, to support 
customers in achieving their investment objectives 
and meeting their transactional needs.
With regard to the Investing area in particular, advi­
sory services and insurance solutions are focused on 
offering solutions that take ESG criteria into account 
during the creation of model portfolios, through spe­
3.2.	 
39	Fineco’s mortgages qualify as “green mortgages” when they involve loans for the purchase of class A or B energy properties. Fineco intends to carry out a specific aimed at 
verifying the alignment of its mortgage portfolio to the technical screening criteria defined for the asset class “Acquisition and ownership of buildings” by the Delegated Act 
of the Taxonomy Regulation (EU Regulation 2020/852) on the climate change mitigation and adaptation objectives (EU Delegated Regulation 2021/2139 of 4 June 2021).

50
ESG ASSESSMENT OF 
FUNDS IN THE PLATFORM
202240
2021
2020
N° ISIN
%
AuM
[€ bn]41
N° ISIN
%
AuM
[€ bn]
N° ISIN
%
AuM
[€ bn]
ESG-rated funds
4,293
87%
29.4
5,278
83%
30.2
3,610
57%
13.7
of which with rating ≥ average42
3,671 
86%
27.1
3,880
74%
24.6
2,708
75%
10.9
Non-ESG-rated funds
649
13%
3.0
1,099
17%
6.3
2,748
43%
16.6
Total funds
4,942 100%
32.4
6,377
100%
36.5
6,358
100%
30.3
SFDR CLASSIFICATION OF 
FUNDS IN THE PLATFORM
2022
2021
N° ISIN
%
AuM
[€ bn]
N° ISIN
%
AuM
[€ bn]
SFDR Article 6 funds43
1,589
32%
14.6
3,246
51%
20.8
SFDR Article 8 funds44
2,756
56%
16.8
2,844
45%
14.2
SFDR Article 9 funds45
225
5%
0.9
264
4%
1.0
Unclassified funds
372
8%
0.1
23
0%
0.5
Total funds
4,942
100%
32.4
6,377
100%
36.5
cific quantitative and qualitative analyses and with 
the support of the “Fineco ESG Rating” which inte­
grates sustainability risk into the provision of the ser­
vices. This rating, developed by the Bank in 2022, 
recalculates the ESG scores assigned by an external 
provider to investment products – on a scale of 1 to 
100 (1 “low risk”, 100 “high risk” ESG) – using a con­
version table to reclassify these scores, on a scale of 
1 to 10 (1 “high risk”, 10 “low risk” ESG).
The rating provides investors with an immediate 
tool for better understanding the extent to which the 
economic value of the investment could be at risk 
due to issues related to the environment, the social 
sphere or the governance of the underlying assets, 
in addition to making them more aware of their in­
vestment choices. The Fineco ESG Rating is current­
ly available for Funds, Sicavs, ETFs, shares, bonds, 
and Unit-Linked and Multiclass insurance policies; 
assessments are being made to cover other types 
of instruments not yet available, such as Class I in­
surance policies, asset management services, ETCs 
and certificates. To comply with the new regulations 
and keep pace with consumer needs, from 1 Janu­
ary 2021 the Bank has committed to favouring the 
assessment, selection and inclusion of funds with an 
ESG rating in its range of offerings, increasing the 
ESG offering available to customers.
The Fineco ESG Rating is also used to assess the 
suitability of the customer’s portfolio with respect to 
the preferences expressed on the level of sustain­
ability of investments in the MiFID questionnaire. 
Each preference is associated with a minimum ESG 
Rating, which is compared with the average ESG Rat­
ing of the existing or proposed portfolio. The port­
folio or portfolio proposal is suitable if the average 
ESG rating of the portfolio is above the minimum 
thresholds set for each sustainability preference. 
Fineco regularly maps funds in its range to the SFDR 
classification per individual Article 6, 8 and 9. This 
allows Fineco to compare its positioning with the 
Italian and European averages. As at 31  Decem­
ber 2022, FinecoBank’s wealth management offer­
ing consisted of the following. 
40	In 2022, the Bank decided to withdraw a number of ISINs from placement that, due to their direct or indirect characteristics, are no longer aligned to its strategies. Specifically, 
all ISINs listed as residuals with AUM less than or equal to €500,000 were progressively removed from the placement. In addition, there was a decrease in AuM in that year 
due the performance of the market.
41	 Asset Under Management.
42	From 2022 the average corresponds to a minimum score of 6 out of 10 in the “Fineco ESG Rating” and is therefore not comparable with previous years, when this threshold 
was set by Morningstar. The average 2022 figures calculated according to the Morningstar threshold are: ISIN no. 3,234; Percentage: 75%; AuM: 24.6 € bn.
43	Funds that do not promote environmental or social characteristics and do not have sustainable investments as their objective.
44	Funds that, in addition to other characteristics, promote environmental or social characteristics, or a combination of those characteristics, provided the firms invested in 
comply with good governance practices.
45	Funds that have sustainable investments as their objective.

51
SFDR CLASSIFICATION OF ETFs IN THE
PLATFORM
2022
N° ISIN
%
AuC
 [€ bn]
ETFs ex Art. 6 SFDR
1,394
53%
3.9
ETFs ex Art. 8 SFDR
 581
22%
0,7
ETFs ex Art. 9 SFDR
47
2%
0.0
Unclassified ETFs
589
23%
0.0
Total ETFs
2,611
100%
4.6
ESG ASSESSMENT46 OF ETFs IN THE
PLATFORM
2022
N° ISIN
%
AuC47
[€ bn]
ESG-rated ETFs
1,996
76%
3.7
of which with ≥ average rating
1,656
83%
3.2
Non-ESG-rated ETFs
615
24%
0.9
Total ETFs
2,611
100%
4.6
With regard to supplementary pension schemes, in 
October 2020 the investment policy of the Core Pen­
sion open-ended pension fund managed by Amundi 
and distributed exclusively by Fineco, was changed 
on all the lines, with the integration of exclusion and 
selection criteria based on analysis and the assign­
ment of sustainability ratings into the existing invest­
ment process. As at 31 December 2022, the Assets 
Under Management of Core Pension amounted to 
€626 million, up 26% compared to 2021.
With regard to the Bank’s internal investment port­
folio, particular attention is paid to the green finance 
market, which, with the recent transactions in ESG 
bonds, represents an increasingly significant pro­
portion of the financial market, particularly in Europe. 
In this regard, during 2022, Fineco also continued 
to take this type of financial instrument into consid­
eration in its financing decisions, as an integral com­
ponent of its sustainability strategy. At 31 December 
2022, the Group held portfolio consisting of ESG 
bonds amounting to approximately €1,745 million, or 
approximately 6.8% of Fineco’s total portfolio.
Also in the area of responsible finance, the Bank has 
two collateral switch transactions (collateralised se­
curities lending) with ESG criteria in place with a total 
countervalue of around €71 mln. Compared to the 
traditional ones, these transactions involve the pay­
ment of an extra fee related to Fineco’s achievement 
of the following sustainability targets: (i) 100% of new 
ESG-rated funds placed on the Italian platform be­
tween 1 January 2021 and 31 December 2023 (ii) S&P 
Corporate Sustainability Assessment score greater 
than 67 out of 100. Upon maturity of the transactions, 
set at April 2024, the extra fee will be paid to Fine­
co by the counterparty and transferred by Fineco to 
Save the Children if the Bank reaches the agreed 
targets, whereas it will be transferred directly from 
the counterparty to Save the Children if Fineco does 
not reach the targets. 
The Irish company Fineco Asset Management DAC 
has developed policies, procedures and investment 
products to support its commitments to responsible 
investment by subscribing to the United Nations 
Principles for Responsible Investment (UN PRI), as 
well as the UN Global Compact. 
Since 2021, Fineco AM has adopted the Responsi­
ble Investment Policy, which lays down the commit­
ment to manage the funds in a responsible and sus­
46	The ESG information for the ETFs distributed has been available since 2022.
47	Asset Under Custody.

52
tainable manner, setting out guiding principles and a 
framework for integrating ESG risks and factors into 
its business activities.
Fineco AM’s commitment is also manifested through 
constructive dialogue between institutional investors 
and investee companies to address issues related 
to ESG risk management and take advantage of 
business opportunities associated with sustainability 
challenges. In particular, Fineco AM believes that the 
best way to promote improvements in market prac­
tices is by actively participating in collaborative plat­
forms. In this respect – in line with the commitments 
made through its subscription to the UN Global Com­
pact and the PRI – in 2022, the Company signed up 
to the “UN PRI Advance: a stewardship initiative 
for human rights and social issues”. Through this 
ongoing initiative, Fineco AM collaborates with other 
investors to develop opportunities for engagement 
with companies to promote human rights and posi­
tive outcomes for people. 
Again in the area of active ownership, Fineco AM 
uses the Institutional Shareholder Services (“ISS”) 
voting platform and proxy voting recommendations 
for all meetings where it votes. Fineco AM has incor­
porated sustainability considerations into its voting 
approach by subscribing to the ISS International Sus­
tainability proxy voting policy and guidelines.
Since 2020, Fineco AM 
has committed to not 
charging 
performance 
fees on the funds un­
der management. To 
this end, a specific “No 
Performance Fees” is 
used which tells cus­
tomers which funds do not have these type of fees. 
Not charging performance fees is a strategic choice 
aimed at ensuring fair prices and better results for 
customers.
Since 2021, Fineco AM has classified all its funds 
under management in accordance with definitions 
contained in Articles 6, 8 and 9 SFDR and includ­
ed the relevant pre-contractual information in its 
prospectuses and supplements to comply with the 
SFDR. The pre-contractual information of Fineco 
AM’s funds is also supplemented to comply with 
Regulation (EU) 2020/852 (EU Taxonomy), by in­
cluding qualitative and, where possible, quantitative 
information, as well as the statement regarding the 
principle of “doing no significant harm”. 
From January 2022, Fineco AM’s “SFDR and Tax­
onomy” internal working group started to meet on a 
weekly basis, both for the purpose of implementing 
the requirements of these regulations in force from 
2023, and analysing the level of preparedness and 
readiness of the company as a whole in relation to 
the integration of sustainability into the business. 
Since February 2022, Fineco AM has made consid­
erable progress in integrating ESG factors into all its 
activities, taking a number of important steps:
·	 the establishment of a formal ESG governance 
framework, including the Sustainable Finance 
Committee (SFC);
·	 the full integration of ESG into the front office trad­
ing platform to ensure that sustainability risks are 
considered at source;
·	 the integration of the MSCI ESG Fund Quality Score 
rating into the risk management model, which ena­
bles monthly monitoring of the score for each fund;
·	 the implementation of a company-wide exclusion 
policy, based on Fineco AM’s commitments as a 
signatory to the UN PRI and GC standards. 
The approach to integrating ESG factors into the in­
vestment process depends on the specific product 
type, strategy and asset class. With regard to Arti­
cle 8 funds, ESG factors are integrated, for example, 
through: 
·	 the integration of ESG data provided by third 
parties - To integrate ESG data into its front of­
fice trading platform, Fineco AM uses the provider 
MSCI ESG Manager, which can be supplemented 
by in-house or third-party research. This ensures 
that ESG criteria and sustainability risks are taken 
into account when the purchase is made. As part of 
ongoing ESG improvements, environmental, social 
and governance data have been integrated into 
the trading platform, at both the individual invest­
ment and aggregated fund level. 
·	 Positive sectoral and value-based screening

53
- The managers integrate ESG factors into their 
overall portfolio construction and security selec­
tion, including sector-specific environmental and 
social factors;
·	 ESG assessments at counterparty level - Fineco 
AM’s Article 8 funds promote ESG characteristics by 
applying minimum MSCI ESG ratings. This approach 
ensures that the portfolios are positively skewed to­
wards investments with higher ESG ratings. 
·	 ESG score at fund level - Fineco AM’s Risk Team 
carries out a monthly independent analysis and 
ESG score classification for each fund. At the fund 
level, a minimum ESG score threshold is applied 
to ensure that the fund score does not fall below 
a level considered appropriate by Fineco AM for 
a fund promoting ESG characteristics. The month­
ly risk reporting identifies the cases where this 
threshold has been breached. The ESG quality of 
the fund can then be formally investigated and the 
results reported to the SFC. This additional control 
serves to maintain a minimum ESG score at fund 
level and supports the engagement with fund man­
agers on ESG issues.
·	 Good Governance - Fineco AM is committed to in­
vesting in companies that manage their business­
es in a way that promotes sound ESG risk manage­
ment and fosters value creation for shareholders 
and stakeholders. The SFDR establishes that prod­
ucts classified as Article 8 or 9 must not invest in 
companies that do not follow good governance 
practices. The Good Governance Policy describes 
how Fineco AM determines whether an investee 
company does not follow good governance prac­
tices and should therefore be excluded from the 
initial investment universe for the Article 8 and 9 
SFDR products.
·	 Negative screening (“norm-based exclusions”) 
- Fineco AM believes that certain products and 
business practices are detrimental to the company 
and, in view of its fiduciary role, it wishes to avoid 
making investments that the company itself or the 
Group’s customers could consider incompatible 
with a responsible investment approach. Certain 
exclusion criteria are therefore applied to align 
the investments with this approach. Specifical­
ly, in 2022, Fineco AM published an Investment 
Exclusion Policy, which resulted in an Exclusion 
List identifying the various exclusions applied, the 
products the exclusions apply to and the extent to 
which they apply to them. Fineco AM applies this 
exclusion policy to all its funds and not just the Ar­
ticle 8 and 9 SFDR funds. The exclusion categories 
considered are: 
-	 UN Global Compact Principles;
-	 Controversial weapons;
-	 Tobacco;
-	 Climate change;
-	 Forced labour.  
·	 Principal Adverse Impacts - PAI - Fineco AM also 
considers the principal adverse impacts of its in­
vestment decisions on sustainability factors, as 
required by Article 4 of the SFDR, and in its due 
diligence processes. 
For investment funds where Fineco AM assigned 
the manage­ment of investments  under mandate 
to third parties, Fineco AM conducts thorough in­
itial ESG due diligence and ongoing monitoring to 
ensure that each fund under mandate is managed 
in accordance with the ESG criteria set out in the re­
spective offering documentation.
Fineco AM also offers products that have a sustaina­
ble investment objective and are therefore subject to 
the requirements of Article 9 of the SFDR. The sus­
tainability-focused strategies work from the same 
basis as the integrated ESG strategies, but add an 
ex-ante focus on securities that score better on ESG 
and environmental factors. The sustainability im­
pact strategies invest in companies that contribute 
to solving problems related to specific sustainability 
issues. These strategies are aimed at investors that 
want to have a positive impact on society or want to 
have a clear exposure to certain areas of sustaina­
ble development that they believe can generate ad­
equate investment returns, e.g. the following funds:
·	 Diversity and Inclusion Fam Fund - The fund’s 
investment objective is to maximise total returns 
through a combination of income and capital ap­
preciation by investing in companies that have 
proven gender and/or ethnic diversity, or that pro­
vide solutions that promote social equality. 
·	 Global Sustain Paris Aligned Fam Fund - The

54
fund’s investment objective is to provide a 
total return (capital growth plus income) that 
exceeds that of the global equity markets 
over a five-year period and to invest in com­
panies that contribute to the achievement of 
the Paris Agreement climate change goal. 
As at 31 December 2022, ESG funds classified 
as Articles 8 and 9 SFDR represented 51.5% 
of Fineco AM’s total assets under management.
ASSET UNDER MANAGEMENT 
OF FINECO AM ESG FUNDS48 [€/MN]
2022
2021
2020
SFDR Article 8 funds – internally managed 
5,203
3,128
1,502
SFDR Article 8 funds – under mandate
7,839
3,813
1,911
SFDR Article 9 funds – internally managed 
-
-
-   
SFDR Article 9 funds – under mandate
302
224
-   
Total AUM - Article 8 and 9 Funds
13,344
7,165
3,413
ASSETS SUBJECT TO POSITIVE AND NEGATIVE
ENVIRONMENTAL AND SOCIAL SCREENING
2022
2021
2020
% of assets subject to positive environmental 
and/or social screening
52%
13%
11%
% of assets subject to negative environmental 
and/or social screening
70%
27%
16%
% of assets subject to combined positive 
and negative environmental and/or social screening
70%
11%
6%
48 For an up-to-date list of ESG funds under management, see the Sustainability section of the Fineco AM website.  
49	For 2020 and 2021, the assets subject to screening are those covered by the analyses performed by Morningstar and MSCI. Specifically, positive screening identifies 
“Sustainable Investments” as funds that specifically refer in the prospectus or offering documents to sustainability-related activities, impacts or strategies (e.g. diversity, 
renewable energy, low carbon and local community development). Negative screening, on the other hand, excludes funds that invest in specific sectors considered 
controversial from an environmental and social sustainability perspective (e.g. alcohol, controversial weapons, gambling, tobacco, nuclear power, palm oil, pesticides, 
thermal coal). 
The assets that can be subject to positive and/or 
negative screening depend on the fund strate­
gy and asset class. Liquidity and indirect exposure 
through derivatives are excluded from the calcula­
tions. Positive and negative environmental and/or 
social screening is applied to Fineco AM’s Article 
8 and 9 SFDR funds, while negative environmental 
and/or social screening is applied to Fineco AM’s Ar­
ticle 6 SFDR direct investment funds. In addition, it is 
important to note that for 2022, the calculation of the 
percentage of assets subject to positive and nega­
tive environmental or social screening is based on 
a different methodology than in previous years. The 
calculation in 2022 was carried out internally, using a 
new ESG Integration Framework, whereas data from 
external providers49 were used in the previous years.
The following positive and negative screening crite­
ria can be applied: 
·	 Exclusion Policy;  
·	 Indicators of principal adverse impacts (PAI indica­
tors); 
·	 Minimum ESG score at Fund level; 
·	 Screening of ESG indices in order to circumscribe 
the investment universe.

55
FINANCIAL INCLUSION 
Fineco provides a product and service offering that 
promotes financial inclusion and access to finan­
cial services and products. In particular, it offers the 
possibility of subscribing to two different types of 
current accounts at favourable conditions: the Basic 
Account A and the Basic Account B, both aimed at 
facilitating access to basic financial services by eco­
nomically disadvantaged groups. 
The offering includes not only a predetermined num­
ber of free services and transactions, but also free 
provision of a debit card. Specifically, the “Basic Ac­
count A” can be opened by any ordinary consumer 
and is a current account with an annual fee and or­
dinary banking operations. For consumers with an 
ISEE (financial status indicator) of less than €11,600/
year who open a “Basic Account A”, there is no annu­
al fee or stamp duty. Consumers with retirement pay­
ments of up to €18,000/year can open the “Basic Ac­
count A” and there is no annual fee, but stamp duty is 
due to be paid. Alternatively, pensioners with a pen­
sion less than or equal to €18,000/year can open the 
“Basic Account B”, which only requires payment of 
stamp duty and limited operations compared to the 
“Basic Account A”.
In addition, in 2022 Fineco continued and adopted a 
number of initiatives aimed at promoting access to 
banking and financial services for young people:
·	 in line with the so-called Support Decree50, the 
Bank allowed the application of a zero substitute 
tax to loans for first home purchases by borrowers 
who are no older than 36 (in the year of the deed 
of exchange) and whose ISEE (financial status indi­
cator) is no more than €40,000;
·	 the Bank maintained the offering for young people 
under 30, which includes no account maintenance 
charge and a reduction in the fees on orders in 
Italian and international equities and ETFs, and 
eliminated the monthly fee for Capital Accumula­
tion Plans (CAPs) in ETFs and fixed fees for CAPs in 
SICAVs.
As part of its initiatives to improve the accessibility 
of services, Fineco has initiated a project of align­
ment to the new regulations51. In early 2022, an as­
sessment was carried out on the website and Apps 
(iOS and Android), also with the aid of a consultancy 
firm specialising in accessibility, in order to identify 
useful suggestions for optimising the level of acces­
sibility of the Bank’s portals. The reports resulted in 
improved accessibility of the channels, which had 
anyway already been designed and built to be fully 
compatible with screen reader software (voice assis­
tants). 
At user experience level, particular attention is given 
to the design of the information architecture in order 
to ensure easy navigation of the content, as well as 
to the correct contrast between the background and 
the text, using a legible typeface, and to the label­
ling of the images and links inserted, so that these 
can be recognised and correctly interpreted by the 
speech synthesis software. 
Finally, as required by recent regulations, the Acces­
sibility Statement was published on all the Bank’s 
portals in September 2022, according to the regu­
latory requirements laid by the Digital Italy Agency 
(AGID).
3.3.	 
50	Decree-Law no. 41 of 22 March 2021: Urgent measures in support of businesses and economic operators, labour, health and local services, related to the Covid-19 
emergency. These measures, extended to all of 2022 by the 2022 Budget Law, were also extended to 31 December 2023 as provided for in Article 1, paragraph 74, letter 
c) of Law No. 197 of 29 December 2022 (the “2023 Budget Law”)..
51	 In April 2022, the AGID (digital Italy agency) adopted specific Guidelines on the Accessibility of IT Tools for Providers in accordance with Article 3 paragraph 1-bis of Law 
4/2004 (so-called Stanca Law). The Guidelines, applicable from 28 June 2022, follow the extension of the scope of application of Law 4/2004 to private entities offering 
services to the public through websites or mobile applications above a specific turnover threshold, which took place with the so-called Simplification Decree (July 2020). 
In July 2022, a decree was also published to implement the Accessibility Directive (EU) 2019/882, which establishes rules on the accessibility of products and services for 
people with disabilities, i.e. physical, mental or sensory impairment.

56
FAIRNESS AND TRANSPARENCY IN CUSTOMER 
COMMUNICATIONS
Transparency is one of the cornerstones of the re­
lationship of trust that exists between Fineco and 
its customers, and is a fundamental element of the 
company culture. In addition to the issues addressed 
in the Group’s Integrity Charter and Code of Con­
duct, as well as in the Code of Ethics, the Group 
has also issued a specific internal Guidelines for the 
preparation of marketing and advertising initia­
tives (Circular no. 48/2021), designed to facilitate the 
establishment and dissemination of an internal cul­
ture founded on the principles of honesty, fairness 
and compliance with the relevant regulations. The 
guidelines clearly stipulate that a given behaviour 
with regard to the customer can be defined as in­
correct when it results in any form of alteration in the 
actions and perception of the consumer with regard 
to the product/service offered, regardless of the ac­
tual damage caused to the latter. According to the 
subject areas and content covered, the guidelines 
also stipulate that the marketing and advertising 
messages developed must always be validated by 
the relevant units of the Bank. 
In this context, Fineco is committed to ensuring all 
communications are distinguished by the simplici­
ty of the way in which they are written, courtesy of 
the direct and immediately comprehensible lan­
guage employed. When present, any sources relat­
ing to qualitative-quantitative numerical evidence or 
detailed conditions are always provided within the 
same information document, and are easily verifiable.
The procedure for creating, approving and publish­
ing the content of communications to customers, 
including marketing communications, follows a strict 
process of internal approvals that includes first-level 
checks, carried out directly by those who produce 
the content, and subsequent checks by the com­
pliance and legal departments and all of the offices 
concerned. All communications aimed at customers 
are generated and produced by Fineco’s internal 
staff, without the involvement of external third par­
ties; this provides an additional guarantee of privacy 
protection and control over the flow of publication. 
Within Fineco, transparency also means accessibil­
ity to information at all times, along with dedicated, 
immediate and “all-in-one” assistance. Courtesy of a 
complex system of data analytics, Fineco is able to 
profile communications destined to be sent to users 
with extreme granularity, ensuring that each cluster 
of contacts only receives information that is relevant 
or interesting to them. Marketing materials, such as 
email communications and website pages, follow 
predefined layout templates that make it easier for 
the user to access the information. The responsive 
structure enables most email communications to be 
optimised for reading on mobile devices, automati­
cally adapting to different screen resolutions.
In 2022 there were no cases of non-compliance with 
regard to commercial communications. 
3.4.

58
58
04

59
59
INNOVATION
4.1.	
TECHNOLOGICAL INNOVATION AND DIGITAL TRANSFORMATION
4.2.	
BUSINESS MODEL INNOVATION

60
4.1.	  TECHNOLOGICAL INNOVATION AND DIGITAL 
TRANSFORMATION
Technological innovation is a key component of process 
automation and digitalisation.
Process automation has a positive effect on the 
efficiency of the processes themselves, making the 
use of resources more efficient. This enables the 
management of increased business volumes, with­
out having to increase costs proportionally. Process 
automation also reduces operational errors and 
speeds up the execution of certain tasks. 
The monitoring of the effectiveness of efficiency im­
provement projects is carried out within the Demand 
Management process, during the Project Committee 
Meetings, using Scorecards, distributed to all em­
ployees through a specific circular. The aim of the 
Scorecards is to enable an objective assessment of 
the proposed efficiency measures, ensuring a uni­
form approach when comparing the different initia­
tives and identifying a priority of actions for the im­
plementation. Specifically, the process requires the 
Proposer of an intervention to fill in a scorecard that 
assesses the qualitative/quantitative benefit it will 
provide once this put into operation, which considers 
four different dimensions: i) Customer, i.e. the benefit 
obtained for customer satisfaction; ii) People, i.e. any 
reduction of FTEs; (iii) Financial, i.e. any reduction of 
operating costs and the transfer of costs to the budg­
ets of different controllers; (iv) Processes, i.e. the level 
of automation achieved, also considering the reduc­
tion in operational risk and sustainability impact (e.g. 
elimination of paper and/or physical postage). Based 
on the answers provided by the Proposer, the score­
card determines, and associates, a summary score 
to the Project. The Project Committee can also veri­
fy and monitor the actual benefit over time, after the 
efficiency improvement has been put into operation. 
Digitalisation has various positive effects, both in 
environmental and social terms, including a better 
customer experience, linked to the simplification and 
acceleration of the processes of requesting and using 
products and services – such as the signing of con­
tracts with digital signatures, the use of the video-self­
ies for customer recognition during onboarding and 
vocal passwords for recognition during customer as­
sistance – and the reduction of the use of raw mate­
rials and travel associated with traditional processes.
Historically, the Group has focused its efforts on 
minimising its environmental impact mainly through 
dematerialisation processes, thanks to innovations 
and the use of technology that significantly reduce 
paper flows and make processes more sustainable.  
Over the years, Fineco has implemented a number 
of initiatives aimed at reducing paper consumption 
and favouring the use of technology. In particular, 
since 2012, a function has been introduced that al­
lows the Bank to provide the customer with a digital 
copy of the account opening agreement, counter­
signed in acceptance, eliminating the need to print 
out the agreements to be able to sign them.
Subsequently, customers were also given the oppor­
tunity to provide digital and electronic handwritten 
signatures. Indeed, since 2013, remote digital signa­
tures have been available for existing customers, 
allowing them to sign agreements and documents 
directly from the reserved area of the Fineco website 
or app and avoid having to print the documentation 
to sign it. In the same year, electronic handwritten 
signatures were also activated, allowing custom­
ers to sign agreements digitally in the presence of 
a Fineco personal financial advisor. The signature 
represents an advanced electronic signature and is 
collected via a signature tablet connected to the Ad­
visor’s company computer or tablet. Today, this type 
of signature is used to sign current account opening 
agreements, agreements for Plus and Advice servic­
es, and the anti-money laundering questionnaire for 
natural persons.

61
In 2015, the Bank also introduced remote digital sig­
natures for new customers, a function that allows 
those wanting to open a current account with Fineco 
to sign all the necessary documents without having 
to print them out. 
Another initiative that became fully effective from 
2021 was the digitisation of Advice and Plus re­
quests for financial changes, as well as the digital 
sending of certificates, through which it has been 
agreed to send documentation regarding changes 
in service conditions by uploading them onto a ded­
icated platform. 
Within its internal back office activities, the Bank has 
digitised the saving of daily printouts, the transmis­
sion of anti-money laundering questionnaires for le­
gal entities via email attachments, and the manage­
ment of the closure of relationships and successions 
without the support of printouts.
4.2.	 BUSINESS MODEL INNOVATION
Continuous improvement of operational efficien­
cy is a key element in sustaining growth and qual­
ity. The cyborg-advisory model is constantly being 
strengthened: thanks to a highly advanced advisory 
platform in terms of both technology and investment 
solutions, the personal financial advisors are able to 
manage an increasing number of customers, also re­
motely, providing timely assistance and offering new 
proposals or portfolio rebalancing options based on 
different market scenarios and changes in needs. 
The main objective of the technological innova­
tion and business models is to reduce the time 
that the personal financial advisors have to spend 
on time-consuming activities with low added value, 
and maximising the time that can be devoted to the 
relationship with the customers and analysing their 
needs. To this end, the work on the development 
and streamlining of X-Net, the cyborg advisory plat­
form dedicated to personal financial advisors, con­
tinued in 2022. X-Net provides an integrated solu­
tion that, unlike pure robo-advisory systems, is able 
to exploit the advantages of digital technology and 
reconfigure the role of the advisors to amplify the 
most sophisticated aspect of their work.
In addition, through the adoption of digital signatures 
and the Web and Mobile Collaboration service, 
customers have been given the opportunity to eas­
ily and securely manage investment proposals from 
their personal financial advisors remotely, direct­
ly from their mobile phones or PCs, with a double 
benefit both for customers, who are offered a more 
convenient and flexible service, and in terms of re­
sources saved. In fact, when the personal financial 
advisors make a proposal to the customers, they are 
notified on the home page in the reserved area of 
the customer site or directly on their smartphone via 
the Fineco App. The customers are then able to view, 
accept and confirm the order in complete autonomy. 
The use of this channel made it possible, during the 
Covid-19 pandemic, to maintain operations with high 
standards to ensure the safety of both customers 
and personal financial advisors.
In addition to the Web Collaboration channel, personal 
financial advisors have access to the Digital Signature 
service, which allows documents to be signed elec­
tronically. This simple, fast and, above all, secure chan­
nel guarantees the authenticity of the account holder’s 
signature and the non-modifiability of the document. 
The customer can view the signed agreements and 
any time directly from the private area of the site.
If it’s not possible to use the Web Collaboration or 
Digital Signature channel, the PFAs always have the 
option of using paper contracts.
A selection of personal financial advisors are in­
volved in the development of projects with the great­
est impact on the X-Net platform. By allowing select­
ed PFAs to use new tools in advance, information 
can be gathered on the Network’s needs and spe­
cific tools can be designed to meet the PFAs needs 
and those of their customers.

62
62
05
62

63
63
SOLIDITY AND RESILIENCE
5.1. 	
GOVERNANCE SYSTEM
5.2. 	
MANAGEMENT OF ESG RISKS
5.3. 	
PERFORMANCE AND CAPITAL STRENGTH
5.4. 	
ECONOMIC VALUE GENERATED AND DISTRIBUTED
5.5. 	
ENVIRONMENTALLY SUSTAINABLE ASSETS
5.6. 	
PROTECTION OF THE COMPANY REPUTATION

64
SOLIDITY AND RESILIENCE
For the Fineco Group, being strong and resilient 
means adopting a corporate governance system 
that promotes clear and responsible banking, con­
tributing to the creation of sustainable long-term 
value. This commitment is manifested through the 
adoption of a resilient business model capable of 
maintaining healthy operating and financial perfor­
mance, ensuring the Group’s capital strength, and 
the implementation of actions and initiatives to pro­
tect and strengthen the corporate identity.
A key part of the Group’s resilient approach is busi­
ness continuity management. In this regard, the 
Parent Company has issued guidelines on emergen­
cy and crisis management and business continuity 
management, which envisage a decentralised mod­
el of emergency management, based on the plans 
of the individual companies which reflect their spe­
cific circumstances. 
In line with the applicable regulations, the Bank 
has adopted a model that comprises organisation­
al units dedicated to managing business continuity 
and crises, both in normal operating conditions and 
in emergency situations. The Business Continuity 
and Crisis Management framework of the Bank and 
Group companies includes:
·	 the emergency and crisis management plan; 
·	 the business continuity plan, which includes the 
disaster recovery plan, which sets out measures 
for the recovery of applications and information 
systems affected by a disaster, and the cyber at­
tack plan, which sets the strategies for dealing with 
large-scale cyber attacks;
·	 the pandemic management plan, which incor­
porates the experience gained during the health 
emergency caused by the Covid-19 pandemic. In 
particular, remote working, which was adopted on 
a large scale during the pandemic, is still the main 
emergency measure in the business continuity 
plan of the Parent Company and the subsidiary Fi­
neco AM.
The Bank’s business continuity plans are tested at 
least annually and the results are submitted to the 
CEO and General Manager (performing his manage­
ment function) within the Business Continuity & Crisis 
Management Committee; Lastly, the results are re­
ported to the Board of Directors.
To ensure business continuity in the event of a crisis, 
remote training on the subject by the essential staff 
for replacement staff was provided for a total of 636 
hours.
The events since the beginning of 2020 have pro­
vided the opportunity to test and confirm the effec­
tiveness of the Group’s approach to resilience. In 
this continued uncertain and hard to predict envi­
ronment, the Group’s business model has emerged 
as diversified and well balanced. Indeed, the Group 
is able to rely on a business model in which the di­
verse sources of revenue allow it to face complex 
stressors. The FinecoBank Group’s revenues are in 
fact based on three main components (banking, bro­
kerage, and investing) whose performance tends to 
be uncorrelated during periods of crisis.
Specifically, since February 2022, the military con­
flict between Russia and Ukraine (below the “Con­
flict”) has generated an international geopolitical and 
economic diplomatic crisis that has had significant 
repercussions on trade, causing commodity short­
ages and contributing to inflationary pressures. In 
this environment of uncertainty, as at 31 December 
2022, there was no direct impact of the conflict on 
the Fineco Group, as it has no direct exposure to 
Russian assets affected by EU sanctions, or whose 
value is directly affected by the conflict. The indi­
rect exposures to these assets consist of collateral 
received within customer loans secured by pledges 
(Lombard Loans and credit facilities with pledge), the 
amount of which is immaterial. The Group also has 
no significant exposure in roubles, or direct expo­
sure in commodities. Lastly, there were no significant 
impacts either in terms of management of liquidity, 
which remained solid and stable, or strategic direc­
tion, objectives and business model.
5.

65
With regard to ICT and cyber risks, in February 
2022, the CSIRT (response team of the national cy­
ber agency) issued a number of alerts calling for in­
creased attention and the implementation of all the 
protective measures for ICT assets, urging the adop­
tion of “a maximum cyber defence posture”. In Italy, 
the focus was generally on ministries, government 
agencies and companies strategic to the national 
interest, including financial institutions. The Group’s 
objective is to ensure the protection of customers by 
guaranteeing data security, in the form of availability, 
confidentiality and integrity. In view of the effects of 
the Russian-Ukrainian crisis on the EU financial mar­
kets, particular attention was paid to assessing the 
related risks. Specifically, in conjunction with the start 
of the conflict between Russia and Ukraine, there 
was a noticeable increase in reconnaissance activi­
ties. In compliance with the measures envisaged by 
the applicable legislation, Fineco implemented a se­
ries of initiatives aimed at verifying its security pos­
ture and operational readiness, also making use of 
the guidance and recommendations provided by the 
various national and international bodies. In addition 
to always having adopted best security practices, 
both in terms of technical and organisational/proce­
dural measures, further mechanisms have been in­
troduced to deal with any impacts arising from the 
current situation, while also ensuring constant and 
continuous monitoring of the evolving circumstances.
Some direct effects of the Conflict were noted on 
the management of investment products linked to 
those geographical areas. Specifically, the main im­
pact related to the suspension of the tradability of 
all securities listed on the Russian Stock Exchange, 
which made it impossible to update the Net Asset 
Values of the funds affected. As a result, the invest­
ment houses had to suspend some the funds invest­
ed in the geographic areas affected by the conflict, 
making it impossible for customers to divest. To miti­
gate this situation and allow investors to at least par­
tially recover the blocked assets, some investment 
houses decided to create side pockets in which to 
isolate the suspended securities, allowing trading to 
continue on the rest of the fund and give investors 
the possibility of divesting the unblocked portion of 
their investments, while other investment houses de­
cided to liquidate the sub-funds involved in order to 
pay the proceeds from the liquid assets in their port­
folios to the shareholders.
The Group’s asset management company, Fineco 
AM, conducted an initial analysis of the impact of 
the Conflict at the beginning of March 2022, which 
identified that managed funds had limited direct ex­
posure to Russia. It was therefore decided to reduce 
all the positions or exposures held in Russia to nil, 
in line with market practice, and to apply sanctions, 
where applicable, to protect the Company’s cus­
tomers, reputation and ESG principles. Specifically, 
Fineco AM took the following actions: (i) already prior 
to the application of the sanctions, the subsequent­
ly sanctioned positions held in any of the portfolios 
were reduced to nil; (ii) no increases were made 
to the non-sanctioned/exposed positions in Russia 
held by the funds; and (iii) the Company’s position 
and materiality exposure levels to non-sanctioned/
exposed positions in Russia were agreed in line with 
Fineco AM’s ESG principles.
In this environment of crisis and uncertainty, the 
Bank has supported its personal financial advisors 
by providing training on issues related to the emo­
tional management of customers, with the support 
of university lecturers and other experts in the field, 
including psychologists.
Lastly, the Conflict had a major impact on the supply 
chain for several commodities, causing increasing 
delays in the delivery of purchased goods and re­
sulting in a general increase in prices. The procure­
ment of materials related to real estate works and 
ICT activities in particular suffered the most from the 
impact of the Conflict. In addition, it was established 
that any new suppliers identified as having links to 
Russia following anti-money laundering and anti-cor­
ruption checks would be excluded from the list of 
approved suppliers.

66
GOVERNANCE SYSTEM
In addition to compliance with current laws and reg­
ulations, the corporate governance system adopted 
by FinecoBank S.p.A. incorporates the recommen­
dations contained in the Corporate Governance 
Code for Listed Companies which contain the fun­
damental standards for good governance, based 
on transparency and responsibility, with a long-term 
perspective, also taking into account the Company’s 
sustainable success. 
With this in mind, FinecoBank adopts a traditional ad­
ministration and control system, based on two bodies 
appointed by the Shareholders’ Meeting: the Board 
of Directors (“BoD” or “Board”), which exercises the 
powers of strategic supervision, and the Board of 
Statutory Auditors, which has auditing functions. 
The CEO and General Manager performs the role of 
management body in accordance with the Superviso­
ry Regulations. Accounts are audited by an external 
auditing company, in compliance with applicable laws.
In order to ensure that the board’s expertise is con­
tinuously updated also in relation to sustainability, Fi­
neco implemented a training plan for the members 
of the board in 2022 with three sessions dedicated 
to ESG topics: (i) sustainability: the current and pro­
spective regulatory framework, ESG products, distri­
bution policy, key stakeholder analysis and related 
ESG approach; (ii) ESG products and related ESG 
assessments: analysis of ESG products promoted by 
the Group, also in terms of product governance; (iii) 
state of the art and regulatory updates: the evolution 
of sustainability in the Bank’s operations, in relation 
to competitors and regulatory changes. 
The sessions are part of the broader induction pro­
gramme approved by the Board of Directors for the 
year 2022, which involved a total of 13 training ses­
sions, also conducted with the support of the Bank’s 
internal units. The Statutory Auditors also took part 
in the sessions.
In order to promote an efficient system of informa­
tion and consultation that allows the Board to better 
evaluate certain matters under its jurisdiction, in ac­
cordance with the Supervisory Provisions issued by 
the relevant Authorities and the recommendations of 
the Corporate Governance Code, four committees 
are established within the Board with investigative, 
proposal, advisory and coordination functions:
·	 Corporate Governance and Environmental and 
Social Sustainability Committee;
·	 Appointments Committee;
·	 Remuneration Committee;
·	 Risk and Related Parties Committee.
The members of the committees are chosen according 
to the best skills and availability to carry out the task.
During the year, these committees met respectively 
as follows: 12 meetings of the Corporate Governance 
and Environmental and Social Sustainability Commit­
tee, 11 meetings of the Appointments Committee, 13 
meetings of the Remuneration Committee and 24 
meetings of the Risk and Related Parties Committee.
5.1.	 
BOARD OF 
STATUTORY 
AUDITORS
BOARD OF DIRECTORS
REMUNERATION
COMMITTEE
APPOINTMENTS
COMMITTEE
RISK AND
RELATED
PARTIES
COMMITTEE
SUPERVISORY
BODY 231
INTERNAL
AUDIT*
CORPORATE
GOVERNANCE AND
ENVIRONMENTAL
AND SOCIAL
SUATAINABILITY
COMMITTEE
CEO 
AND GENERAL 
MANAGER
The governance structure of FinecoBank as at 31 December 2022
* In accordance with the Supervisory Regulations for Banks, the Internal Audit function operates inde­pendently from other company functions and reports its activities and their 
results quarterly to the Board of Directors (also via the Risk and Related Parties Committee) and the Board of Statutory Auditors.

67
In 2022, the Board of Directors approved the Sus­
tainability Global Policy, adopted with the aim of 
responding both to the requests from external stake­
holders to formalise the Group’s commitments and 
approach to sustainability, and to the internal need 
to adopt a specific global policy bringing together 
the commitments made. The policy also formalises 
the ESG governance structure and compliance con­
trols for regulating ESG risks and identifying the main 
areas of integration of sustainability factors into the 
Group’s operations.
SUSTAINABILITY GOVERNANCE
The Board of Directors is tasked with establishing the nature and level of risk compatible with the strategic 
objectives of the Bank and the Group, including all the risks that may be relevant for sustainable success in 
its assessments. It also sets the corporate strategies taking into account the sustainable finance objectives 
and the integration of environmental, social and governance (ESG) factors into business decision-making 
processes. Lastly, it approves the policy for the promotion of diversity and inclusiveness and promotes 
dialogue, in the most appropriate forms, with the shareholders and with the other relevant stakeholders of 
the Company. 
The Board Committee for Corporate Governance and Environmental and Social Sustainability, es­
tablished in 2020 with exclusive responsibility for sustainability matters, oversees FinecoBank’s business 
operations and the interactions with all its stakeholders in relation to sustainability, providing support to the 
Board of Directors. Specifically, it oversees the evolution of the Group’s sustainability strategy, assesses 
sustainability-related risks, and examines and, where necessary, draws up proposals concerning plans, 
objectives, rules and corporate procedures on social and environmental issues. It also provides support 
to the Board of Directors for the approval of policies aimed at promoting diversity and inclusiveness and 
contributes to the examination of the products with ESG objectives issued by the Bank, in addition to 
monitoring the positioning of the Company and the Group with the financial markets in relation to sustain­
ability and stakeholder relations, reviewing and issuing opinions on the policy for managing dialogue with 
shareholders in general, and reviewing the non-financial statement (NFS) and the environmental statement 
pursuant to the EMAS Regulation prior to their submission to the Board of Directors for approval. Lastly, the 
Committee also has been assigned specific duties in relation to corporate governance52.
In support of the Corporate Governance and Environmental and Social Sustainability Committee, a Sustai­
nability Management Committee comprised of FinecoBank managers has also been in place since 2019. 
The Committee’s main task is to draw up a proposal for the Bank’s sustainability strategy (company plans, 
rules and procedures in relation to social and environmental issues) and the related objectives to be achie­
ved, to be examined by the Corporate Governance and Environmental and Social Sustainability Committee 
and where necessary approved by the Board of Directors.
Lastly, since July 2019, Fineco has had a Sustainability Unit, a reporting to the Chief Financial Officer 
(CFO), tasked with supporting the CFO and the Sustainability Management Committee in managing su­
stainability within Fineco, including the development and monitoring of the ESG strategy (corporate plans, 
rules and procedures on social and environmental issues) and in the drafting and subsequent approval of 
the Consolidated Non-Financial Statement by the competent Corporate Bodies.
In 2021, the Parent Company set up a dedicated organisational model for ESG regulatory oversight, 
divided into thematic macro-areas. For each macro-area, the model identifies the scopes directly overseen 
by the compliance function (second level company control function), the compliance scopes assigned to 
specific specialised units (indirect compliance coverage) and the scope assigned to the risk management 
function (second level company control function):
52	The duties of the Corporate Governance and Environmental and Social Sustainability Committee are set out in the “Regulation on FinecoBank’s Corporate Bodies” available 
on the Bank’s website www.finecobank.it – section “Governance//Company Boards”.

68
MACRO-AREA
CORPORATE STRUCTURE IN CHARGE OF REGULATORY OVERSIGHT
NON-FINANCIAL DISCLOSURE
Sustainability Structure
REQUIREMENTS FOR 
CORPORATE OFFICERS, 
RELATED PARTIES AND 
CONNECTED PERSONS, 
FUNCTIONING OF THE 
SHAREHOLDERS’ MEETING 
Corporate Law & Board Secretary’s Office
HEALTH AND SAFETY
Real Estate Unit due to the appointment of the Head of the Unit the 
Officer responsible for issues relating to compliance of workplaces(Ti­
tles I, II, VIII, IX, X, XI of Legislative Decree 81/2008), plant, machinery 
and equipment, for keeping and updating compulsory documentation, 
identifying gaps in emergency personnel, verifying the technical and 
professional suitability of contractors, preparing the interference risk 
assessment document (DUVRI) and calculating the safety costs, and 
authorising sub-contracts
Chief People Officer Department, due to the appointment of the Chief 
People Officer as the Officer responsible for aspects relating to train­
ing, information, employee health surveillance, appointment of the 
Company Doctor, identification and designation of emergency staff, 
and communications to institutional bodies
Procurement Office due to the appointment of the Head of the of­
fice as the Officer responsible for issues relating to the identification 
of the scope of application of Article 26 and Title IV of Legislative 
Decree 81/2008, concerning maintenance or worksite activities, the 
identification of suppliers and the issuing of orders
LABOUR LAW
Chief People Officer Department 
TAX
Tax Affairs and Advisory Unit
ENVIRONMENTAL 
PROTECTION
Chief People Officer Department, for the regulations on mobility man­
agement
Real Estate Unit, for the regulations on responsible consumption, 
waste disposal and pollution reduction at buildings used by the Bank 
and the personal financial advisors
Chief Financial Officer, as Management Representative pursuant to 
the EMAS Regulation, and Sustainability Unit reporting to the CFO, for 
the Environmental Management System regulations
OTHER SUSTAINABILITY-
RELATED OBLIGATIONS
Chief Risk Officer Department, for ESG risk management regulations
Compliance Department, for the regulations on investment services, 
banking, insurance and credit products,anti-bribery, anti-money laun­
dering and anti-terrorist financing, conflicts of interest, gender equality, 
combating harassment, sexually inappropriate behaviour and bullying, 
the data privacy, remuneration policies, and whistleblowing

69
Each of the units identified is responsible for overseeing and monitoring external regulations applicable to 
them, analysing new requirements and identifying actions to be implemented with the engagement of the 
units concerned, defining and carrying out second level controls, in accordance with the methods estab­
lished for the specialist monitoring, and identifying any improvement actions where necessary, and lastly 
producing the appropriate information reports, at least quarterly, on the second level controls for the Com­
pliance Department, which reports in turn to the corporate bodies. The Sustainability Unit has also been 
assigned a role of coordination in this regard.
The oversight by the Chief Risk Officer Department is carried out, for the areas under its responsibility, as a 
second level control function, making clear that this is not an indirect coverage of the Compliance function.
Proportionate to their size and in consideration of the type of business, the subsidiaries adopt the necessary 
controls to ensure ESG compliance at local and, therefore, Group level.
COMPOSITION OF THE BOARD, COMMITTEES AND 
SUPERVISORY BODY
53	Pursuant to Article 147-ter, paragraph 1, of the Consolidated Finance Act.
The Shareholders’ Meeting appoints the Board Mem­
bers on the basis of lists submitted by the Board of 
Directors and the shareholders, according to the pro­
cedure described in the Articles of Association. The 
Board of Directors and the Shareholders can submit 
a list for the appointment of Directors, provided that 
when they submit the list they hold, alone or togeth­
er with the other submitting shareholders, at least the 
minimum shareholding established by Consob53 and 
in compliance with relevant provisions in the Issuers’ 
Regulations.
The appointment mechanism ensures broad rep­
resentation for the minority shareholders. In fact, the 
list that comes second in terms of number of votes will 
be assigned two Directors, while the list that comes 
third in terms of number of votes will be assigned one 
Director provided he/she has received at least 2% of 
the votes cast at the meeting. 
In order to ensure the functioning of the management 
body, the Board of Directors has also established the 
requirements that must be met by directors of Fineco­
Bank, in addition to those already envisaged by current 
laws and regulations, as well as the number of director­
ships that can be held by them in other companies. The 
directors accept the office when they believe they can 
devote the necessary time to the diligent performance 
of their duties, also taking into account the commitment 
connected with their own work and professional activi­
ties, as well as the number of offices they hold in other 
companies, including companies outside Italy.
The members of the Board must be suitable for the 
performance of the office. Specifically, they must meet 
the requirements of professional expertise, integri­
ty and independence and comply with the criteria of 
competence, correctness and dedication of time and 
the specific limits on the number of positions held laid 
down in the applicable regulations (Ministerial Decree 
no. 169 of 2020) and the Articles of Association and in 
any event those laid down in the CRD IV Directive, for 
the discharge of the duties of director of a bank issuing 
shares listed on regulated markets.
The Board of Directors shall elect a Chairman from 
among its members and – where appropriate – one 
or more Deputy Chairmen, one of which will act as a 
stand-in. The Chairman is responsible for chairing the 
Shareholders’ Meeting, directing and moderating dis­
cussions, establishing the voting procedures and con­
firming the results, in compliance with the applicable 
regulations and procedures for Shareholders’ meet­
ings. The Chairman of the Board of Directors of Fineco­
Bank has not been granted any management powers 
and therefore does not have any executive role. He/

70
Non-Executive Directors: 10/11	
Independent Directors: 10/11
Average time in office in the governance body (no. of years)54 : 5.73	
       Average age: 59.5 years
54 The number of years is calculated from the date of first appointment to the Board of Directors until the date of the Shareholders’ Meeting called to approve the annual 
financial statements as at 31 December 2022.
she does not have a specific role in the development 
of business strategies, is not the main person respon­
sible for the management of the Company, and does 
not have significant investments, either directly or indi­
rectly, in the Company’s share capital. The Chairman is 
not a member of any of the Bank’s board committees.
For further details, see Article 13 of the Articles of As­
sociation, as well as the “Report on corporate govern­
ance and ownership structures” and the “Qualitative 
and Quantitative Profile of the Board of Directors”, pub­
lished on the Bank’s website.
The Board of Directors in office as at 31 December 
2022, composed of 11 Directors in accordance with 
the articles of association provisions, was appointed at 
the Shareholders’ Meeting of 28 April 2020. Its term of 
office will end at the Shareholders’ Meeting for the ap­
proval of the Annual Financial Statements as at 31 De­
cember 2022. 
The composition of the Board of Directors in office 
quantitatively and qualitatively corresponds to the the­
oretical profile identified in the document “Qualitative 
and Quantitative Composition of the Board of Direc­
tors of FinecoBank S.p.A. (2020 and 2021 editions)”, 
also with regard to the limits on the number of offices 
held and the time availability required to fulfil role at 
FinecoBank. In addition, the Board of Directors meets 
the requirements of integrity, experience and inde­
pendence (including suitability) set forth in the Articles 
of Association and regulations applicable to the Board 
of Directors in office at the date of this document.  
BOARD OF DIRECTORS
11 members
CORPORATE GOVERNANCE 
AND ENVIRONMENTAL AND 
SOCIAL SUSTAINABILITY 
COMMITTEE
3 members
APPOINTMENTS 
COMMITTEE
3 members
RISK AND RELATED 
PARTIES COMMITTEE
5 members
REMUNERATION 
COMMITTEE
3 members
BOARD OF STATUTORY
AUDITORS
3 members
Breakdown 
by gender
Breakdown 
by gender
Breakdown 
by age group
Breakdown 
by age group
55%
33%
45%
67%
>50
30-50
73%
27%
Breakdown 
by gender
Breakdown 
by age group
67%
33%
>50
100%
Breakdown 
by gender
Breakdown 
by age group
67%
33%
>50
30-50
67%
33%
Breakdown 
by gender
Breakdown 
by age group
60%
40%
Breakdown 
by gender
Breakdown 
by age group
67%
33%
>50
30-50
67%
33%
>50
100%
>50
30-50
80%
20%

71
In accordance with the provisions of the Regula­
tion on the Corporate Bodies, the annual self-as­
sessment of the functioning of the Board and its 
Committees, as well as their size and composition, 
was conducted in 2022. This process involves: (i) 
an investigation, carried out with the help of anon­
ymous questionnaires and individual interviews; (ii) 
the elaboration of the results of the self-assessment 
and preparation of the summary document outlining, 
among other things, the strengths and weaknesses 
identified; (iii) the Appointments Committee’s review 
of the summary document and the formulation of 
proposals for possible corrective measures; (iv) the 
assessment and approval by the Board of Directors 
of the summary document, accompanied by propos­
als for further improvement. In line with the previous 
years’ Board Reviews, the questionnaire and inter­
views focused on several areas concerning the size, 
composition and functioning of the Board of Direc­
tors and Board Committees. The vast majority of Di­
rectors welcome the increased focus on ESG issues.
In carrying out the process, FinecoBank is support­
ed by an independent external professional, identi­
fied with the help of the Appointments Committee, 
charged with advising on the various stages of the 
process.
The outcome of the 2022 self-assessment revealed 
a positive picture with regard to the size and com­
position of the Board. Looking ahead to the next 
renewal to be decided by the 2023 Shareholders’ 
Meeting, the questionnaires reveal a desire to pre­
serve the inventory of expertise currently available, 
while expanding the expertise in the areas of ESG 
and IT, among others. In addition to fulfilling the ob­
jectives set out in the related Supervisory Provisions, 
the self-assessment for the year 2022 also had the 
objective, in view of the renewal of the Bank’s cor­
porate bodies, of providing possible indications in 
terms of the Qualitative and Quantitative Profile for 
the guidance opinion to be submitted to the Share­
holders at the Shareholders’ Meeting in 2023.
For information and details on the structure and 
functioning of the corporate bodies, the governance 
practices applied, and the activities of the board 
committees, please refer to the “Report the corpo­
rate governance and ownership structures”, as 
well as to the “Regulation on FinecoBank’s Corpo­
rate Bodies” both available on the company web­
site.
With particular regard to the skills, the Board has 
drawn up a “table of skills” which illustrates the 
collective experience, knowledge and expertise it 
considers appropriate in order to obtain the optimal 
composition.
Sustainability
Banking sector and techniques for assessing and managing related risks
Banking-financial sector regulation
Governance
Interpretation of economic and accounting data of financial importance
Business management and organisation
Compliance
Reference markets in which FinecoBank works
Economic-financial system
International experience and foreign markets
IT - Information Technology
   	
	
	
       100%
	
	
	
       100%
	
	
                        100%
	
	
                91%
	
	
                91%
	
	
                91%
	
	
         82%
	
                64%
	
          55%
                         54%           
27%
Skills of the Board of Directors

72
POLICIES ON THE DIVERSITY OF THE GOVERNANCE BODY
55	 It should be noted that following the amendments made, inter alia, by law no. 160/2019 (Budget Law) to Article 147-ter, paragraph 1-ter of the Consolidated Finance Act, at 
least two fifths of the elected directors of the supervisory body should belong to the least represented gender. This will come into force from the first renewal of the Board 
following the new regulatory provisions.  
56	 The Board of Statutory Auditors had already defined its optimal composition on a voluntary basis upon reappointment of the body approved by the Shareholders’ Meeting 
of 28 April 2020.
57	 Resolution no. 21359 of 13 May 2020 amended Article 144-undecies.1 of the Issuers’ Regulation, paragraph 3 of which, in its current wording, establishes that “Where the 
application of gender division criteria does not result in a whole number of members of the administrative or control body belonging to the least represented gender, this 
number is rounded up, except for the corporate bodies made up of three members, for which the rounding takes place by default to the lower unit”.
The composition of the Board must include a com­
bination of abilities and managerial skills, in compli­
ance with the requirements of integrity, independ­
ence, experience and gender as stated by current 
laws, regulations and the Articles of Association, as 
well as with the recommendations of the Corporate 
Governance Code. The number of board members 
must be such that the Board includes:
·	 all the different components of its social base;
·	 all the necessary skills for competent internal 
debate;
·	 a sufficient number of independent members in ac­
cordance with the Corporate Governance Code;
·	 adequate gender representation, in addition to re­
flecting an appropriate degree of diversification in 
terms of skills, experience, age and international 
scope, which will be defined upon reappointment 
of the body.
The composition of the Board is designed to ensure 
a balanced combination of profiles and experience 
and to promote diversity requirements in terms of 
specific skills additional to those in the banking in­
dustry and the distribution of seniority of the Direc­
tors, also in terms of age. Compliance with gender 
diversity policies as set forth in the applicable reg­
ulations is also reflected in the Articles of Associa­
tion. The composition of the Board of Directors of 
the Bank in office as at 31 December 2022 not only 
complies with the requirements of gender balance 
envisaged by the applicable regulations55, but in 
March 2021 the Bank also became the first company 
on the FTSE Mib with a predominantly female Board, 
with women representing 55% of its members.
It is also good practice, as far as is consistent with 
the skills required to hold the positions and the need 
to ensure the effective performance of the relevant 
tasks, that the positions of Chairman of the Board of 
Directors, Chairman of the Board of Statutory Audi­
tors, and CEO and General Manager are not held by 
members of the same gender.
The Board of Statutory Auditors, at the Shareholders’ 
Meeting of 28 April 2021, also defined the optimal 
theoretical profile of its members, preparing a specif­
ic document “Qualitative and Quantitative Composi­
tion of the Board of Statutory Auditors of FinecoBank 
S.p.A.”, approved by the body on 15 March 202156. 
With regard to gender diversity in particular, the pro­
visions of Article 144-undecies.1 (Gender Balance) of 
the Issuers’ Regulation57 also apply to the Board of 
Statutory Auditors.
Lastly, in view of the renewal of the Corporate Bod­
ies to be resolved upon at the 2023 Shareholders’ 
Meeting, the Board of Directors and the Board of 
Statutory Auditors approved the new versions of the 
documents “Qualitative and Quantitative Composi­
tion of the Board of Directors of FinecoBank S.p.A.” 
and “Qualitative and Quantitative Composition 
of the Board of Statutory Auditors of FinecoBank 
S.p.A.”, both published on the Bank’s website.

73
REMUNERATION POLICIES 
58	 Gross Annual Salary.
FinecoBank’s remuneration governance model 
aims to ensure clarity, reliability and transparency 
in decision-making processes, through proper con­
trol of the Group’s remuneration processes and by 
ensuring that decisions are taken in an independ­
ent, informed and timely manner, in order to avoid 
conflicts of interest and ensure proper disclosure 
in full compliance with the provisions set out by the 
Supervisory Authorities. In line with this approach, 
the Remuneration Policy is formulated by the Chief 
People Officer Department, with the involvement of 
other corporate functions for their respective areas 
of responsibility, and validated by the Compliance 
and Risk Management functions before being sub­
mitted to the Remuneration Committee. This Com­
mittee has the role of making proposals and pro­
viding opinions to the Board of Directors in relation 
to the Group’s remuneration strategy, including, for 
example, the criteria for determining the remunera­
tion, performance targets and share incentive plans, 
overseeing the overall coherence and actual appli­
cation of the Remuneration Policy approved. The Re­
muneration Policy is submitted annually, on proposal 
from the Remuneration Committee, to the Board of 
Directors and then to the Shareholders’ Meeting for 
approval, in line with regulatory requirements.
In application of the option envisaged in the applica­
ble regulations, the Remuneration Committee uses 
the aid of an external consultant specialised in advi­
sory services, whose independence has been veri­
fied in advance. This consultant supports the Com­
mittee’s decisions on remuneration by providing, for 
example, analyses on market practices and updates 
on the developments in the regulatory framework.
Fineco maintains a constructive dialogue with insti­
tutional investors and the main proxy advisors in 
relation to the Remuneration Policy and the Incen­
tive Plans, with a particular focus on ESG issues, in 
order to gather valuable input on the approach to 
remuneration and specific suggestions for ensuring 
effective disclosure to the public.
With regard to the voting at the Ordinary and Ex­
traordinary Shareholders’ Meetings of Fineco on 28 
April 2022 on the proposed resolutions concerning 
the remuneration systems, there was a positive re­
sult, reflecting broad consensus among sharehold­
ers. Specifically, there were 91.4% votes in favour for 
the Report on remuneration policy and 95.8% for the 
Report on compensation paid.
The remuneration strategy is based on the funda­
mental principles of clear and transparent govern­
ance, regulatory compliance, monitoring of market 
trends and practices, consistency between remuner­
ation and performance and between remuneration 
and value creation, motivation, and retention of all 
staff.
The Remuneration Policy establishes the guide­
lines for the Group remuneration practices, aimed at 
establishing incentive systems consistent with cor­
porate values and objectives, also in relation to sus­
tainability. In this regard, the Group is committed to 
ensuring fair remuneration irrespective of age, race, 
culture, gender, disability, sexual orientation, religion, 
political affiliation and marital status, and any other 
personal or professional circumstances. Particular 
attention is given to the gender neutrality of the poli­
cy, with the aim of contributing to the pursuit of equal 
opportunities in terms of professional development 
and remuneration.
Under the principle of “Pay for sustainable perfor­
mance” and in order to align management interests 
with those of the shareholders, minimum sharehold­
ing levels are set for the CEO and General Manager, 
equal to 100% of the GAS58, and for Key Manage­
ment Personnel, equal to 50% of the GAS, normally 
to be reached within 5 years from the first appoint­
ment and to be maintained for the entire duration 
of the office held. From 2023, the share ownership 
requirements will be raised to 200% of the GAS for

74
the CEO and General Manager and 100% of the GAS 
for the Key Management Personnel.
For the Group’s employees, the approach to the 
overall remuneration involves a balance between 
fixed and variable components, each set with the 
aim of having a significant impact on employee moti­
vation and retention. All fixed remuneration is set on 
the basis of pre-established, non-discretionary crite­
ria, considering the skills, levels of professional ex­
perience and responsibility of each employee. The 
variable remuneration, on the other hand, is aimed at 
recognising results achieved by establishing a direct 
link between remuneration and short-, medium- and 
long-term risk-adjusted performance, while avoiding 
incentives that could induce staff to behave in ways 
that are not consistent with the Bank’s sustainable 
performance and risk profile. The variable remunera­
tion is based on short-term Incentive Systems linked 
to annual performance, together with the Long-Term 
Incentive Plan.
The 2022 Individual Scorecard for the Identified 
Staff59 maintains an appropriate balance between 
quantitative/strategic factors, which account for 70% 
of the overall scorecard, and qualitative and sustain­
ability factors, which account for 30% of the overall 
scorecard. In particular, the specific Stakeholder Val­
ue objective includes a number of ESG goals, incor­
porated in the Group’s 2020-2023 Strategic Plan. In 
addition, a specific Tone from the top objective con­
cerning integrity in conduct and the dissemination of 
a compliance culture within the organisation contin­
ues to be maintained. With regard to the long-term 
59	 “Identified staff” means the staff whose activities have a significant impact on the Group’s risk profile according to the provisions of Circular no. 285 of 2013 and Delegated 
Regulation (EU) 2021/923.
variable remuneration, the 2021-2023 Long-Term 
Incentive (LTI) Share Plan for employees includes 
specific ESG performance targets, linked to custom­
er satisfaction, people engagement and the exten­
sion of the ESG rating to all new funds, in line with 
the 2020-2023 Strategic Plan. Bonuses are paid en­
tirely in shares and are subject to deferral periods.
As provided for in the Group Remuneration Policy, 
the variable remuneration awarded or paid is sub­
ject to ex-post correction mechanisms (malus and 
claw backs) designed to take individual conduct into 
account. Specifically, these measures allow for the 
reduction, cancellation or reclaiming of any form of 
variable remuneration. 
Other forms of remuneration (e.g. entry bonus­
es and retention bonuses) are subject to a specific 
decision-making process and are only envisaged in 
exceptional cases. These are considered variable 
remuneration and, as such, are subject to the rules 
applicable to it.
With regard to severance pay, the Termination Pay­
ments Policy has been adopted, which implements 
the regulatory provisions contained in Bank of Ita­
ly Circular no. 285 of 2013, with particular regard to 
the amounts agreed ahead of or at the time of early 
termination of the employment relationship. Discre­
tionary pension benefits are not normally awarded. If 
they are envisaged in local practices and/or, excep­
tionally, individual agreements, they are in any case 
paid in a manner consistent with the related specific 
legal and regulatory provisions.

75
RATIO OF TOTAL ANNUAL 
REMUNERATION 
2022
2021
2020
Total annual remuneration of the organisa­
tion’s highest-paid person/median annual 
total remuneration of all employees (ex­
cluding the highest-paid person)60
45
53
85
Percentage increase in total annual remu­
neration of the organisation’s highest paid 
employee/Median percentage increase in 
total annual remuneration of all employees 
(excluding the highest paid employee)
-4.9
-7.5
n.a.
60	The annual changes in the ratio of the total annual remuneration of the organisation’s highest-paid person to the median total annual remuneration of all employees 
(excluding the highest-paid person) are attributable to the different pay-out profiles (applicable in particular to the organisation’s highest-paid person) in the multi-year plans, 
in the form of cash and shares, in the reference year.
With regard to the remuneration strategy for the 
network, the provisions of the Remuneration Policy 
also apply to the FinecoBank personal financial ad­
visors classed as Identified Staff, in line with their 
specific remuneration characteristics. To adapt the 
rules on the structure of employee remuneration, 
which are based on the coexistence of a fixed and 
a variable component, to the specific features of the 
personal financial advisors, who are connected to 
the company through a self-employment contract, 
the regulations have established that remuneration 
must be separated between a “recurrent” and a 
“non-recurrent” component.
As a further compliance safeguard, a “Scoring” sys­
tem has been in place for the network since 2022, 
which introduces a corrective measure resulting 
from the assessment of indicators of compliance 
and quality of operations, relating to specific areas 
such as mandatory training and internal regulations, 
Transparency, Anti-Money Laundering and Anti-Ter­
rorism, MiFID and Disciplinary Measures. This system 
applies during the incentive period and may lead to 
a revision of the amount of the bonus accrued. 
For more details see “Section I – 2022 Report on Re­
muneration Policy” and the “Termination Payments 
Policy”, both of which are available in the Govern­
ance section of the FinecoBank website.

76
MANAGEMENT OF ESG RISKS
Fineco has always promoted a solid risk culture based 
on shared values and consistent behaviour, which are 
necessary to ensure long-term sustainable profitability. 
61	 For more details on the nature of the first, second and third level controls, see the section “Risk management objectives and policies” of the document FinecoBank Group 
Public Disclosure - Pillar III as at 31 December 2022, available in the Corporate/Investors section of the Fineco website.
Specifically, the Group has adopted an effective and 
efficient unitary Internal Control System (ICS), with 
the aim of ensuring that the company’s activities are 
based on sound and prudent management prac­
tices that guarantee capital solidity and company 
earnings, whilst also ensuring informed risk-taking 
and operating conduct based on fairness and com­
pliance with internal and external regulations. This 
system, which includes first, second and third lev­
el controls61, consists of the set of rules, functions, 
structures, resources, processes and procedures 
that aim to ensure the achievement of the following 
objectives:
·	 containment of risk within the limits indicated in the 
Group Risk Appetite Framework; 
·	 verifying the implementation of the Bank’s strate­
gies and policies;
·	 protecting the value of assets and preventing 
losses;
·	 ensuring the effectiveness and efficiency of corpo­
rate processes;
·	 ensuring the security and reliability of the Bank in­
formation and ICT procedures; 
·	 preventing the risk of the Group being involved, 
even involuntarily, in illegal activities (with particular 
reference to money laundering, usury and financ­
ing terrorism);
·	 ensuring transactions comply with the law, supervi­
sory regulations and internal policies, procedures 
and regulations.
The Internal Control System is pervasive in the 
Group’s organisational structure and involves the 
Corporate Bodies, the corporate control functions 
and the line structures. Fineco sees the Risk Appe­
tite Framework (RAF) as the instrument to monitor 
the risk profile that the Group wants to adopt in the 
implementation of its business strategies and in the 
pursuit of sustainable profitability in conjunction with 
solid business growth. The RAF uses a set of risk 
limits and metrics to establish risk objectives, toler­
ance thresholds and operating limits that the Group 
intends to comply with as part of the pursuit of its 
strategic guidelines. 
In line with the Risk Appetite Framework Global Pol­
icy, the RAF is defined through the Risk Appetite 
Statement, which qualitatively defines FinecoBank’s 
positioning in terms of strategic objectives and relat­
ed risk profiles, and the Risk Dashboard, composed 
of a set of quantitative indicators. Among the strate­
gic objectives set out in the Statement, the following 
intentions of the Bank are particularly relevant for 
non-financial reporting purposes:
·	 addressing ’its business and operational manage­
ment choices, accompanying its strategy, focused 
on stable and organic growth, with the progressive 
integration of environmental and social sustainabil­
ity (ESG) principles”;
·	 providing comprehensive information to custom­
ers on ESG issues within the investment and bro­
kerage product offerings, and in financial educa­
tion initiatives;
·	 achieving 95% investment in Net-Zero countries 
and institutions by 2030.
In line with the Statement, since 2020 the Group has 
been monitoring a series of ESG risk indicators in 
its Risk Dashboard: 
(i)	 one of the indicators is designed to ensure that 
a part of the investments is made in ESG bonds, 
5.2.

77
which are designed to support projects or activ­
ities that promote social and environmental sus­
tainability; 
(ii)	 an indicator for physical climate and environmen­
tal risk, which monitors the geographical concen­
tration of real estate collateral received to secure 
mortgage loans in areas with high seismic and 
hydrogeological risk; 
(iii)	for the year 2023, following feedback received 
from the ECB on the “2022 Thematic review of 
climate-related and environmental risk strate­
gies, governance and risk management frame­
work”, a new indicator was included to measure 
the percentage of ESG funds offered by Fineco 
Asset Management out of the total offering of 
funds;
(iv)	additional indicators relating to conduct risk and 
banking transparency, coupled with an enhanced 
escalation process, which is triggered when cer­
tain risk thresholds are reached.
The RAF metrics are regularly monitored and re­
ported, at least quarterly: the monitoring is carried 
out by the Chief Risk Officer Department and the 
Chief Financial Officer Department and reported to 
the Corporate Bodies. In this regard, the CRO De­
partment supports the Board of Directors in defin­
ing a proposed risk appetite for the Group. Aligning 
the incentive schemes for top management and the 
network of personal financial advisors with the RAF 
encourages a conservative approach to risk-taking 
and the maintenance of adequate risk levels.
The risk assessment is also carried out whenev­
er a new product is introduced. The New Product 
Process involves in-depth analysis by all the Bank’s 
functions for their respective areas of responsibili­
ty and requires unanimous approval by the Product 
Committee (of which the Chief Risk Officer and the 
Compliance Officer are permanent members).
The CRO Department, in its capacity as the risk 
management function, is responsible for identifying, 
quantifying and mitigating the Group’s risks, using a 
series of rules, methodologies, policies and strate­
gies in line with the regulatory requirements estab­
lished by the Supervisory Authorities, and support­
62	The Group does not finance companies operating in sectors with high climate and environmental risk, such as dams, mining, coal, nuclear, oil and unconventional gases 
(containing more carbon and sulphur and possibly higher impurities that make them harder to refine).
ing the strategic planning. In this context, in addition 
to the above-mentioned additions made to the risk 
appetite statement and dashboard, the CRO Depart­
ment, as part of the Risk Inventory for the year 2023, 
prepared a special focus on ESG risks and reputa­
tional risks. Given that these are cross-cutting risks, 
the analysis focused on the impact of environmental, 
social, reputational and governance risk factors on 
the traditional risk categories already managed and 
monitored by the Group (e.g. credit risk, market risk, 
etc.). 
The ESG risk assessment, in line with the priorities 
highlighted by the regulators, has been carried out 
considering different time horizons (short and me­
dium/long-term), and has focused on climate and 
environmental risks. For all the time horizons con­
sidered, the assessment did not show a high impact 
from those risks on the Group’s risk profile, given the 
limited exposure of FinecoBank’s business model 
to climatic and environmental risk factors. Specifi­
cally, with regard to credit risk, the Bank’s strategy 
does not contemplate the granting of credit to cor­
porate customers62, and the “Commercial Lending” 
Policy specifically states that the Bank shall refrain 
from financing companies operating in sectors with 
high climate and environmental risk (e.g. the energy 
or steel sectors). Furthermore, the Group’s strategic 
investments mainly involve sovereign counterparts 
(Sovereign States, Government Organisations, etc.) 
with little exposure to climate and environmental 
risks, or sufficiently organised to manage them. This 
approach safeguards the Group from being exposed 
to various climate risk factors, including, for example, 
loss of biodiversity. 
With regard to market risk, the Group as a whole 
does not engage in proprietary trading, and the trad­
ing book is only operated for the functional needs of 
proprietary trading with customers. The Group care­
fully monitors and hedges these positions, and in any 
event most of them are closed at the end of the day. 
The Group’s limited exposure to market risks pre­
vents it from being exposed to sudden price changes 
due to climatic and environmental risk factors.
Taking into account the characteristics of Fineco­

78
Bank’s business model outlined above, the risk cat­
egories that, albeit marginally, could be impacted 
by climate and environmental factors were credit 
risks stemming from retail customers’ reliance on 
the bank, and business risks stemming from offering 
financial products not aligned with customers’ sus­
tainability preferences. 
With regard to credit risks, the analysis carried out 
during the 2023 Risk Inventory recognises that mort­
gage loans granted to retail customers could be af­
fected, already in the short term, by a reduction in the 
value of the real estate pledged as collateral, main­
ly due to acute physical risk factors (e.g. floods or 
landslides). This trend could also worsen in the long 
run as global warming worsens, due to a greater fre­
quency and intensity of acute physical risk events, a 
more pronounced manifestation of chronic physical 
risks (e.g. sea level rise), and a greater likelihood of 
transitional risk factors, such as the imposition of a 
minimum energy class requirement for the sale of 
real estate. To mitigate the exposures to ESG risks, 
the second level controls on credit risks include a 
series of monitoring activities aimed at controlling 
the areas considered most at risk. In the calculation 
of the Expected Credit Losses (ECL), calculated by 
the Group in accordance with IFRS 9, FinecoBank 
has integrated physical risk factors into its model for 
estimating the Loss Given Default of mortgage loans. 
Specifically, loans secured by mortgages on prop­
erties more exposed to climate and environmental 
risks will have a higher LGD. As a result, the Bank cal­
culates higher expected losses on these positions.
Unlike credit risks, business risks are more concen­
trated in the short term. Specifically, the performance 
of investment products that do not promote social 
and/or environmental characteristics or that do not 
have sustainable investment objectives, offered by 
Fineco Asset Management, may be affected by cer­
tain transitional risks, such as a change in custom­
er preferences, which could shift towards products 
with greater sustainability characteristics offered by 
other asset managers. This risk factor is expected to 
decrease in the medium to long term as Fineco AM 
refines its sustainable product offering.
63	This indicator considers two fundamental parameters: the level of a country’s vulnerability to climate change and its positioning in terms of economic, social and governance 
readiness to cope with climate change. The two indicators are compared to determine a country’s exposure to climate and environmental risks.
The monitoring of country risk, includes a number 
of indicators (Worldwide Governance Indicators), de­
veloped by a group of researchers in collaboration 
with the World Bank, aimed at summarising the ef­
fectiveness of policies implemented by government 
authorities in different countries. To accompany these 
indicators, a specific environmental risk indicator, ND-
Gain63, is used, which was developed by a group of 
researchers at the US University of Notre Dame. 
Another area of monitoring is aimed at identifying 
business crisis situations in companies that pro­
vide salaries to a large number of Fineco account 
holders with outstanding personal loans or mort­
gages. Specifically, for the 10 companies that pay 
salaries to the largest number of Fineco current ac­
counts held by borrower customers, news monitor­
ing has been implemented to identify any business 
difficulties that could lead to delays or suspensions 
in the payment of salaries or in collective redun­
dancies, resulting in difficulties for Fineco’s bor­
rower customers to make repayments. In addition 
to checking the news about these companies, the 
Bank monitors the exposure and management of the 
ESG risks by analysing the ratings provided by the 
ESG Risk Rating agency Sustainalytics.
Within the ICAAP process (Internal Capital Adequacy 
Assessment Process), stress tests are carried out that 
consider both physical risk and transition risk. The 
stress test focuses on three uncorrelated risk factors 
considered relevant to Fineco’s business model:
·	 change of customer preferences from FAM funds 
classified as SFDR Article 6 to funds of third-par­
ty managers with ESG characteristics classified as 
SFDR Article 8 and 9. The objective of the scenar­
io, which can be classified as transition risk, is to 
estimate the impact of the change of preference 
on fees and commissions and the internal capital 
related to the Group’s business risk;
·	 reduction in the value of the real estate collater­
al for mortgage loans in areas of high climate and 
environmental risk. The reduction in value would 
lead to an increase in LGD, a consequent increase 
in loan adjustments and higher internal capital as a 
result of the credit risks;

79
·	 downgrades of countries most exposed to climate 
and environmental risks, resulting in a higher Prob­
ability of Default (PD) of institutional counterparties 
and higher credit and internal capital adjustments 
for credit risks.
To manage the operational risks related to human 
error, deficiencies in internal procedures and incor­
rect execution of processes, Parent Company CRO 
Department and the local risk control functions col­
lect and classify loss data from the various business 
areas and creates a system of operational risk in­
dicators. The loss data and any anomalous values 
recorded by the indicators are used for the purpos­
es of internal improvement of operations and are 
brought to the attention of the Board of Directors of 
the Parent Company through the Quarterly Report 
on Group risk exposures.
Specifically, the Group maintains a series of Key 
Risk Indicators divided into different control areas: 
Payment Cards, Compliance, HR, Legal, Operations 
Securities, Payment Systems, Complaints, Network 
Controls, IT Systems, Security, Administration, Audit, 
Sustainability/ESG, Outsourcing, Money Laundering, 
Anti-terrorism and Reputational Risk. Some of these 
indicators are defined as relevant for ESG purposes, 
because if their value is abnormal they may signal 
specific risks concerning relations with customers 
(e.g. complaints received from customers, availability 
or security issues in IT systems), with staff (e.g. turn­
over) or with the regulators, affecting the sustainabil­
ity of the business. These include indicators relating 
to gender equality and transition risk linked to the 
Bank’s offering of investment products (percentage 
of ESG-rated coverage of funds in the platform, com­
position of products offered considering the SFDR 
Article 8 and 9 classification). 
With regard to reputational risks, the Group has es­
tablished that any employee who identifies events 
that could have an impact on the image and repu­
tation of the Fineco Group must promptly inform 
the Parent Company’s CRO Department. The Group 
CRO will assess whether to continue the escalation 
to the Parent Company’s Top Management, includ­
ing the CEO and General Manager, based on the 
materiality of the event. In the most material cas­
es, the issue is brought to the attention of the Risk 
and Related Parties Committee at its next meeting.
In addition to ESG risks, the Group also assesses its 
exposure to other types of non-financial risks, includ­
ing a range of emerging risks, potentially impacting 
the Group’s business strategies, financial perfor­
mance or reputation.
Pandemic risk is the risk that, in order to contain the 
spread of a particular infectious disease, countries 
will impose a series of restrictive measures, includ­
ing, for example, social distancing and the closure of 
businesses, with serious repercussions on the local 
economy. As shown by the Covid 19 pandemic crisis, 
these types of events have little impact on Fineco­
Bank’s business model. Indeed, the business model 
does not involve the use of branches, and has al­
ways encouraged customers to use digital channels, 
also for financial advice. In addition, the Bank’s con­
tingency plan and IT infrastructure enable the use of 
remote working. Lastly, the Group’s credit exposures 
are mainly focused on the sovereign segment, which 
is only secondarily affected by a pandemic.
The risk of geopolitical and economic uncertainty 
is the risk of increased volatility in global markets or 
deterioration of the macroeconomic environment 
due to geopolitical and economic events. Fineco­
Bank’s business model has little exposure to curren­
cy or commodity price volatility, as the Group Market 
Risk Global Policy limits market risk exposure to the 
minimum compatible with the business needs and 
does not allow the opening of speculative positions. 
Credit exposures, on the other hand, despite being 
concentrated within the European Union, may be 
affected by the deterioration of the macroeconomic 
environment, particularly in the context of calculating 
expected credit losses in accordance with IFRS 9. In 
any case, all risks potentially impacted by geopoliti­
cal events (credit risk, country risk, market risk, etc.) 
are managed and monitored by the Group accord­
ing to the three lines of defence model, within the 
related frameworks.
Cyber risk is the risk of unauthorised access, by 
persons inside and outside the organisation, to in­
formation and communication systems. This is con­
sidered to be an emerging risk as a result of the 
increasing use of digital channels and the number 
and sophistication of cyber incidents targeting the

80
banking system. A cyber attack on the Group could 
result in customers being unable to access their fi-
nancial assets, or in the loss/deletion of sensitive 
data. In order to reduce exposure to this type of risk, 
the Group adopts the highest safety standards and 
best practices in the field, increasing risk awareness 
also through staff training by means of special vid-
eo courses. This risk is managed and monitored in 
conjunction with ICT risk according to the three lines 
of defence model, in accordance with the relevant 
Group framework.
Innovation and customer experience risk is the 
risk of not being able to maintain the standards of 
quality/innovation already provided to customers 
with repercussions for the level of customer service. 
The risk is considered to be emerging risk due to 
the entry of new, highly digitised competitors into the 
market and the increasing tendency to adopt cut-
ting-edge technologies in the provision of financial 
services that enable an increasingly personalised 
user experience. The Group is continuously devel-
oping and updating its digital platforms and servic-
es, using investment in technology infrastructure to 
guarantee business continuity and full maintenance 
of service levels even in emergency situations. The 
customer satisfaction orientation is also supported 
by a careful and proactive handling of complaints, 
and the monitoring of indicators that measure the 
degree of customer satisfaction/dissatisfaction.
The Group is committed to developing and stand-
ardising a common risk culture at all levels of the 
organisation, to ensure sustainable earnings over 
the long term. To this end, the Group encourages 
the development of transferable skills aimed at ac-
quiring an overall and integrated vision of control 
activities, including through programmes for rotating 
resources between the corporate control functions, 
as well as the possible participation of employees 
and managers of the aforementioned functions in 
the Risk and Related Parties Committee. 
For a full description of the risks and uncertainties 
that the Group faces in the current market situation, 
see “Part E – Information on risks and related hedg-
ing policies” in the “Accounts and Reports 2022”.

81
Material topics
Risk factor
and description
Management Approach
(control/mitigation)
Legislative Decree 254/2016: Social
Business ethics 
and compliance 
culture
Internal fraud: actions car­
ried out with the intent to 
defraud, 
misappropriate 
assets, violate laws or 
company policies involv­
ing at least one Company 
employee or similar.
Internal fraud takes on 
particular social and repu­
tational importance when 
perpetrated to the detri­
ment of customers
·	 Risk is overseen by the various functions of the Parent 
Company (Network Control Department, Risk Manage­
ment, Compliance, Information Security & Fraud Man­
agement, Internal Audit, etc.) by means of specific moni­
toring activities
·	 Fraud monitoring in accordance with EU and national 
legislation, to ensure the protection of information sys­
tems from incidents that may affect the rights of the per­
sons concerned
·	 The controls and mitigation measures are described in 
the “PFA network control system” Local Policy64, while the 
second level is governed by the “Monitoring and control 
of operational and reputational risks” Global Policy
·	 The results of the controls carried out by the various 
organisational units and centralised within the Network 
Controls Unit, which examines and analyses the individ­
ual cases, to enable the Bank to promptly take the most 
appropriate disciplinary action against the PFAs based 
on the severity of the misconduct
Risk of lack of protection 
of personal data and pri­
vacy
·	 Privacy Global Policy
·	 Establishment of a Data Protection Officer (DPO) to man­
age the theme and the launch of new projects, including 
assessing their feasibility and the way they are applied
·	 Enforcement of the relevant legislation, with the support 
of the DPO
·	 Technical and organisational security measures to pre­
vent data loss and unlawful use of data
Supply Chain: reputational 
risk from selecting suppli­
ers involved in unlawful 
actions or affected by so­
cial responsibility disputes
·	 Evaluation of the required documentation during the se­
lection process, such as: regulations concerning social 
security, health and safety at work, any ISO  9001 and 
ISO 14001 certifications, self-declaration on the exploita­
tion of labour (i.e. Gangmasters and Labour Abuse)
·	 Evaluation of the answers provided to the ESG self-as­
sessment questionnaire by the supplier at the start of the 
collaboration
Risk of error in tax com­
pliance: operational risk, 
which may arise when 
carrying out the activities 
contained in the business 
processes
·	 Subscription from 2016 to the optional Cooperative Com­
pliance regime pursuant to Legislative Decree 128/2015, 
which provides for the adoption of an effective tax risk 
management and control system as a condition for both 
eligibility and permanence (annual verification with feed­
back in the Closing Note envisaged)  
·	 Risk mapped in the Tax Control Framework (TCF)
·	 When an operational error emerges, Fineco promptly 
rectifies the problem, where possible, and notes the de­
ficiency in the internal control system reports
·	 The Tax Compliance Officer reports the emergence and 
correction of operational errors relating to the previous 
year to the Italian Revenue Agency, in accordance with 
the agreed time limits and procedures
64	The “PFA Network Control System” Policy contains the control criteria and methods and the information flows between the various units involved in ensuring efficient 
management and prevention of conduct by PFAs that does not comply with the applicable external and external regulations

82
Material topics
Risk factor
and description
Management Approach
(control/mitigation)
Business ethics 
and compliance 
culture
Tax fraud risk: risk of Fine­
co incurring tax violations 
as a result of criminal con­
duct, also by third parties
·	 Subscription from 2016 to the optional Cooperative Com­
pliance regime pursuant to Legislative Decree 128/2015, 
which provides for the adoption of an effective tax risk 
management and control system as a condition for both 
eligibility and permanence (annual verification with feed­
back in the Closing Note envisaged) 
·	 Tax fraud risk is controlled by monitoring, analysing and 
assessing compliance and interpretation risk, namely 
by interrelationships with the Bank’s internal processes 
(protocols of the model pursuant to Legislative Decree 
231/2001)
·	 Cases involving a risk of tax fraud arising from the actions 
of third parties are always reported to the tax authorities. 
Corporate functions that receive formal notices from the 
legal authorities must immediately inform the Tax func­
tion for it to examine the related tax implications
Tax interpretation risk: tax 
issues of a purely interpre­
tative/assessment nature 
that can be understood 
differently by the Bank 
and the tax authorities
·	 Specific escalation procedure for tax risk analysis and 
assessment and dialogue with the tax authorities. The 
procedure, validated by the Italian Revenue Agency 
under the Cooperative Compliance regime pursuant to 
Legislative Decree 128/2015, governs the roles, respon­
sibilities and procedures for the (i) detection of the exist­
ence of a possible interpretation risk, (ii) qualitative and 
quantitative assessment of the interpretation risk (iii) trig­
gering of the internal authorisation escalation procedure 
(iv) and potential dialogue with the tax authorities. In the 
case of an interpretation risk with “Delta Tax” above the 
threshold predefined with the Italian Revenue Agency, 
there is an obligation of prior disclosure with the Agency
Customer 
Satisfaction
Risk of implementing new 
products that do not re­
flect customer needs or 
expectations
·	 Monitoring of indicators measuring customer satisfac­
tion/dissatisfaction
·	 Survey of customer sustainability preferences under Mi­
FID
·	 Analysis of products offered by other operators
·	 Volume analysis of products traded on regulated mar­
kets
·	 Listening to customers during education sessions on var­
ious topics (chats and surveys in digital meetings) and 
during industry events 
Financial 
education 
and advice
Misselling practices - Risk 
of inappropriateness of 
financial education initia­
tives aimed at the public 
·	 Regular updating of initiatives to make the offering diver­
sified in order to enable users to broaden their knowl­
edge of financial products and the concepts underlying 
them
·	 Selection of target customers to be invited to the initia­
tives based on the level of knowledge of financial prod­
ucts and concepts

83
Material topics
Risk factor
and description
Management Approach
(control/mitigation)
Misselling practices - Risk 
of 
advising 
customers 
on products that do not 
match their investment 
preferences or risk/return 
profile
·	 Implementation of the MiFID profiling questionnaire with 
the possibility for customers to update it at any time and, 
in any case, the compulsory requirement for it to be up­
dated when its validity expires
·	 Adoption of IT procedures to perform suitability and tar­
get market checks on each investment recommendation 
made
·	 Addition of indicators in the PFA scoring to signal opera­
tions that are not in line with customer preferences and/
or risk profiles 
·	 Checks, by the Network Controls Unit, on advisors iden­
tified by related compliance indicators
Correctness 
and transparency 
of information
Compliance risk: non-com­
pliance with obligations to 
customers and risk of lack 
of transparency in market­
ing communications
·	 The controls and mitigation measures are described in 
the “PFA network control system” Local Policy;
·	 Remote and on-site audits of the sales network by Com­
pliance, Audit, Monitoring and Network Services;
·	 Group guidelines for the preparation of marketing and 
advertising initiatives
·	 Risk also controlled by the CRO Department as part of 
the monitoring of operational and reputational risks. This 
involves monitoring the KRIs on conduct risk and trans­
parency.
Innovation
Risk of not being able to 
maintain the standards of 
quality/innovation already 
provided 
to 
customers 
with repercussions for the 
level of customer service
·	 Business model that has always been underpinned by 
principles of innovation, transparency and simplicity, with 
a focus on customer satisfaction
·	 Ongoing development and updating of digital platforms 
and services
·	 Investments aimed at ensuring business continuity and 
full maintenance of service levels, also in emergency sit­
uations
·	 Thorough and proactive handling of complaints
·	 Monitoring of indicators measuring customer satisfac­
tion/dissatisfaction
Operational 
interruption 
and system failures: vul­
nerabilities and risks relat­
ed to the use of informa­
tion and communication 
technology can also have 
significant social conse­
quences. In the event of 
an interruption of opera­
tions, customers may, for 
example, be unable to ac­
cess their finances
·	 “Operational Risk Management Framework for Cyber 
Risk Assessment” Global Policy
·	 At the first level, the risk is managed by the ICT & Secu­
rity Office, which is responsible for adopting and manag­
ing policies and technical and organisational measures 
to guarantee the security of company information and 
assets, in order to avoid loss/damage of data
·	 At the second level, the risk is managed by the CRO De­
partment through the monitoring of RAF indicators, the 
second level controls (KRI), the collection of loss data 
and the annual ICT risk assessment, also performed 
through scenario analysis
·	 Preparation of the annual summary report on the IT risk 
situation

84
Material topics
Risk factor
and description
Management Approach
(control/mitigation)
Cybersecurity 
and information 
security
External 
fraud: 
actions 
committed by third parties 
with the intention of mis­
appropriating 
company 
or customer assets and 
infringing regulations or 
laws
·	 At the first level, this risk is controlled by the Information 
Security & Fraud Management team with regard to the 
security of customer transactions through intelligence 
gathering and prevention that ensure safeguards, in ac­
cordance with industry regulations, to meet strict security 
requirements and provide an appropriate level of protec­
tion for the risks involved
·	 At the second level, this risk is managed by the Risk Man­
agement function through the monitoring of RAF indica­
tors, the second level controls (KRI), the collection of loss 
data and the annual ICT risk assessment, also performed 
through scenario analysis
ICT and security risk
·	 At the first level, the risk is managed by the ICT & Secu­
rity Office, which is responsible for adopting and manag­
ing policies and technical and organisational measures 
to guarantee the security of company information and 
assets, in order to avoid loss/damage of data
·	 At the second level, the risk is managed by the Risk Man­
agement function through the monitoring RAF indicators, 
the second level controls (KRI), the collection of loss data 
and the annual ICT risk assessment, also performed 
through scenario analysis
Responsible 
Finance
Market risk related to lack 
of preparation or delay in 
understanding 
changes 
in customers’ preferences 
for products and invest­
ments that are socially and 
environmentally responsi­
ble
·	 Target included in the 2020-2023 Multi-Year Plan which 
includes training on ESG issues for personal financial ad­
visors
·	 Assessment of market risks and setting objectives for 
their management within the Environmental Manage­
ment System finalised in 2021
·	 Gathering customer preferences with respect to sustain­
ability issues in investment choices through the MiFID 
questionnaire
Legislative Decree 254/2016: Social/Human Rights
Responsible 
Finance
Financing of and invest­
ment in unethical activi­
ties, activities that do not 
comply 
with 
standards 
and practices relating to 
Human Rights, working 
conditions and the envi­
ronment
·	 In its lending activities, the Group adheres to a set of 
ethical values that incorporate environmental, social 
and governance (ESG) considerations. These principles, 
which were recently incorporated into the Commercial 
Lending Policy, can be summarised as follows:
o	the Bank does not finance any economic operators or 
projects that do not comply with the World Bank’s so­
cial and environmental standards and/or with national 
and international environmental regulations applicable 
in the country. Specifically, the Bank does not finance 
companies operating in sectors with a high environ­
mental impact
o	the Group is committed to offering its credit products in a 
responsible manner, assessing the specific circumstanc­
es of individual customers and ensuring that the criteria 
for granting credit do not lead to undue hardship and 
over-indebtedness of customers and their families

85
Material topics
Risk factor
and description
Management Approach
(control/mitigation)
Legislative Decree 254/2016: Personnel
Fair and inclusive 
work environment 
through talent
attraction 
and retention 
strategies 
and meritocratic 
remuneration 
policies 
Lack of applications, lack 
of attractiveness to the 
talent on the market, turn­
over with relative loss of 
key personnel and skills
·	 Organisational unit dedicated to Personnel Management 
and Development
·	 Processes and global policies issued by the HR function 
dedicated to personnel management
·	 Partnerships with the main Italian universities and partici­
pation in targeted events, presence and dedicated cam­
paigns on the main social networks
·	 Evaluation system consistent with a structured and trans­
parent compensation system
·	 Remuneration policy and management for the total re­
ward (including benefits and welfare offer) for all staff
·	 Strategies and employer branding campaigns
·	 Definition of pipeline leadership and succession plans
Fall in employee engage­
ment level with consequent 
impact on performance
·	 Listening initiatives on specific topics
·	 Engagement & Reputation Survey
·	 Using the company intranet as an information tool
Inadequate 
personnel 
training initiatives
·	 Presence of a specific unit for Personnel Management 
and Training
·	 Skills mapping to analyse gaps to be filled
·	 Traceability of training needs through the performance 
management tool 
·	 Mandatory Training Policy 
·	 Training and Professional Development Policy
Lack of effectiveness of 
programmes and initia­
tives related to diversity 
and equal opportunities
·	 Gender Equality Global Policy
·	 Joint committee on work-life balance, innovation and 
company welfare
·	 Continuous learning through participation in relevant as­
sociations
·	 Targets included in the 2020-2023 Multi-Year Plan in re­
lation to the issue
·	 Monitoring and analysis of the gender pay gap and gen­
der balance, also included in the targets of the Short 
Term Incentive Plan for the CEO and other Identified Staff 
based on the specific characteristics of their role.
·	 Monitoring through specific question on Diversity & In­
clusion within the Engagement & Reputation Survey
Failure to comply with the 
understandings in the sec­
ond-level agreements
·	 Management of discussions with trade union represent­
atives to verify the correct application of the understand­
ings contained in the second-level agreements
·	 Constitution of the Welfare Commission for corporate 
welfare issues, in which the parties hold discussions in 
order to analyse, monitor and gain a deep technical un­
derstanding of tools for work-life balance (e.g.: flexible 
work, additional leave, part-time). In addition, the Com­
mission is specifically concerned with analysing the 
performance of the company welfare plan, the related 
supplementary pension fund and the insurance plans for 
employees. The Commission also performs a superviso­
ry and monitoring function

86
Material topics
Risk factor
and description
Management Approach
(control/mitigation)
Fair and inclusive 
work environment 
through talent
attraction 
and retention 
strategies 
and meritocratic 
remuneration 
policies
Failure to comply with lev­
el 1 regulations on the ex­
ercise of trade union rights 
(e.g. provisions of the 
Workers’ Statute, NCBA)
·	 Internal controls carried out in accordance with Bank of 
Italy Circular no. 285 to ensure that the company guaran­
tees the exercise of trade union freedoms by trade union 
representatives and workers. For example: leave provid­
ed for trade union activities, leave for staff assemblies, 
other paid leave, etc.
Failure to apply or incor­
rect application of labour 
regulations (in relation to 
fixed-term, part-time, etc.)
·	 Internal controls carried out in accordance with Bank of 
Italy Circular no. 285 to identify any violations of labour 
regulations and provide for corrective measures
·	 Supporting and interpreting regulations relating to la­
bour law also in collaboration with the external labour 
consultant
Failure to apply or incor­
rect application of disabil­
ity legislation (Law 68/99 
“Rules for the right to work 
of people with disabilities”)
·	 Internal controls carried out in accordance with Bank of 
Italy Circular no. 285 to identify any violations of the pro­
visions of Law 68/99 and provide for corrective meas­
ures
·	 Interpretation and application of legislation also in coop­
eration with provincial Targeted Placement offices
Legislative Decree 254/2016: Personnel/Human Rights
Fair and inclusive 
work environment 
through talent
 attraction and 
retention 
strategies and 
meritocratic 
remuneration 
policies
Risk of human rights vio­
lations resulting from dis­
criminatory behaviour in 
the company
·	 “Commitment to Human Rights” Global Policy
·	 “Combating Harassment, Sexually Inappropriate Behav­
iour and Bullying” Global Policy
·	 Specific training on “Combating Harassment, Sexually In­
appropriate Behaviour and Bullying”
·	 Training with specific course on Unconscious Bias
Legislative Decree 254/2016: Environmental
Protection of 
the environment
Natural disasters and pub­
lic safety: events caused 
by natural disasters or sim­
ilar events. Such events, in 
addition to causing eco­
nomic losses, may lead to 
social impacts if business 
continuity cannot be guar­
anteed
·	 Business Continuity Plan, strategic plan aimed at ensur­
ing adequate levels of business continuity even in the 
event of major incidents

87
Material topics
Risk factor
and description
Management Approach
(control/mitigation)
Protection of 
the environment
Risk of inadequate mon­
itoring of the use of re­
sources and energy con­
sumption 
and 
energy 
emissions at Group level, 
with the consequent lack 
of achievement of objec­
tives in this area
·	 Objectives included in the 2020-2023 Multi-Year Plan 
concerning monitoring of energy consumption, moderni­
sation of the company car fleet, sustainable mobility initi­
atives, and reduction of plastic consumption 
·	 Net Zero Commitment, including reduction targets for 
operating emissions
·	 Drafting of the Environmental Programme 2021-2024 
with environmental targets
·	 Presence of the Energy Manager, tasked with analysing, 
monitoring and optimising the use of energy in all the 
buildings, in order to achieve economic, energy and en­
vironmental benefits
·	 Presence of the Company Mobility Manager, tasked with 
developing sustainable mobility tools to reduce the envi­
ronmental impact of vehicle traffic in the urban and met­
ropolitan areas where Fineco operates
·	 Risk of concentration 
of real estate securing 
mortgage loans in areas 
subject to high hydroge­
ological risk, with conse­
quent reduction in the 
value of guarantees for 
the Bank in the event of 
extreme weather events 
(physical risk).
·	 Risk of concentration of 
credit to customers em­
ployed by companies 
exposed to climate and 
environmental risks.
·	 Risk of exposure to 
countries 
vulnerable 
to climate change and 
lacking the economic, 
social and governance 
capacity to cope with it.
·	 “Framework for the management and monitoring of 
credit risks” Global Policy
·	 Second level controls on the concentration of buildings 
in areas classified as having high seismic, landslide and 
hydrogeological risk
·	 Addition of the risk of reduction in the value of collateral 
properties due to climate and environmental risk factors 
in the estimation of LGDs for mortgage loans, used to 
calculate expected credit losses in accordance with IFRS 
9
·	 Monitoring ND-Gain indicator in the context of country 
risk controls
Legislative Decree 254/2016: Corruption
Business ethics 
and compliance 
culture
Risk of losses and harm 
to reputation due to the 
Group’s involvement in 
bribery and corruption. 
The risk relates to com­
pleted actions as well as 
attempts, instigations and 
being an accessory to 
those actions
·	 Zero-tolerance policy towards corruption formalised in 
the “Anti-Corruption” Global Policy
·	 Anti-Corruption Plan 
·	 Organisation and Management Model pursuant to Legis­
lative Decree 231/01

88
Material topics
Risk factor
and description
Management Approach
(control/mitigation)
Business ethics 
and compliance 
culture
Risk of money laundering 
or funding terrorism: pro­
viding direct or indirect 
support for money laun­
dering or funding terror­
ism. The risk has reputa­
tional consequences and 
also 
carries 
significant 
sanctions
·	 Risk controlled by the “Anti Money-Laundering” function
·	 “AML/CFT Global Policy”
·	 Organisation and Management Model pursuant to Legis­
lative Decree 231/01
·	 Training on AML issues through face-to-face sessions 
conducted by the compliance officers, including case 
studies
Risk of loss and harm 
to 
reputation 
due 
to 
non-compliance with an­
titrust regulations and to 
anti-competitive practices
·	 Antitrust Compliance and Antitrust Training Programme
·	 Single Antitrust Rulebook – Antitrust and Unfair Commer­
cial Practices Group Policy, containing practical rules of 
conduct for managing meetings with competitors
·	 Antitrust handbook on fair competition
·	 Organisation and Management Model pursuant to Legis­
lative Decree 231/2001
Other areas: economic
Group’s 
solidity 
and resilience
Prudential regulation - Risk 
of non-compliance with 
regulatory 
requirements 
or exceeding regulatory 
indicators
·	 Risk Appetite Framework
·	 Capital & Liquidity Plan
·	 Other Contingency Plans
External Communications 
- Deceptive or misleading 
disclosures of financial 
results or regulatory indi­
cators
·	 Global policy and operational processes on the manage­
ment of regulated information for the preparation and 
disclosure of data and information provided to the mar­
ket
·	 Constant monitoring of press coverage (traditional media 
and online) in particular following the publication of regu­
lated information and relevant data
·	 Internal policies and operational processes governing 
the preparation of key documents containing financial 
results or regulatory indicators
·	 Assurance of the Consolidated and Individual Financial 
Statements and the NFS by the independent auditors

89
PERFORMANCE AND CAPITAL STRENGTH 
64	
Performance and capital strength are ensured 
through careful planning and the preparation of the 
Group Budget and Multi-Year Plan.
The Budget and the Multi-Year Plan are constructed 
on the basis of the assumptions and business objec­
tives provided by the Bank’s various departments in 
relation to their areas of responsibility. Specifically, 
a preliminary step in drawing up the Budget is an 
analysis of the needs and characteristics of custom­
ers, carried out by the Bank’s internal commercial 
and business departments. The achievement of for­
ward-looking objectives, which are the main drivers 
for the formulation of economic and financial fore­
casts, is therefore the responsibility of the Bank’s 
organisational units involved in the budget and mul­
ti-year plan preparation process.
On a monthly basis, in conjunction with the Bank’s 
Management Committee meeting, the Planning 
Unit carries out a careful analysis of the devi­
ations between the forecasts contained in the 
budget and forecast models and the actual results 
achieved, both with regard to the overall operat­
ing and financial results and to the main drivers, 
including, for example, the figures for deposits 
and loan disbursements, bringing any deviations 
from the budgeted figures to attention of the Top 
Management. The differences found are justified 
through targeted meetings with the various the 
Bank’s various functions, the purpose of which 
is to determine the actions necessary to reduce 
and/or eliminate potential negative impacts and 
to provide new estimate forecasts to the Plan­
ning Unit that take these corrective actions into 
account.
This activity provides a “360 degree” view of the 
resilience and effectiveness of the Bank’s business 
model, highlighting any critical areas and/or areas 
for improvement.
The planning and control process, in particular the 
strategic planning and budgeting processes and 
the monitoring processes, play a priority role in the 
management and allocation of capital based on the 
risks assumed, in order to develop its operations 
with the aim of creating value. Accordingly, in the 
active management of its capital, the Parent Com­
pany prepares a capital plan, in compliance with the 
regulatory constraints and in line with the risk profile 
adopted by the Group, and monitors the regulatory 
capital requirements, identifying the actions needed 
to achieve the objectives.
Capital and its allocation therefore play a very im­
portant role in setting long-term strategies, because 
it represents the shareholders’ investment in the 
Group, which must be adequately remunerated, but 
it is also a resource subject to external limits, set by 
the supervisory regulations.
Fineco’s attention to capital management is reflect­
ed in its position as one of the most solid banks in 
Italy and Europe in 2022, with a CET1 ratio of 20.8% 
and a Total Capital ratio of 31.4%.
For more details, see the document “FinecoBank 
Group Public Disclosure – Pillar III as at 31 Decem­
ber 2022”, published on the Bank’s website.64
5.3.

90
ECONOMIC VALUE GENERATED AND DISTRIBUTED
65	To determine the economic value generated and distributed, the Group adopted the “Statement of determination and distribution of value added” defined by ABI 
(October 2019), prepared from the balances of the items in the consolidated income statement of FinecoBank Group at 31 December 2022, also taking into account the 
Parent Company’s proposed allocation of profit for the year. The income statement has been reclassified in order to highlight the process of value creation and its distribution 
to the various categories of stakeholders.
The FinecoBank Group also operates with the aim 
of generating long-term economic value for all 
its stakeholders. In this regard, the economic value 
generated by the Group during 2022, which repre­
sents the overall wealth generated by FinecoBank 
thanks to the production and commercial capacity 
linked to its business activities, amounted to approxi­
mately €1.4 billion, of which approximately 89% was 
redistributed to its stakeholders: human resources, 
suppliers, shareholders, public administration and 
the community65.
(amounts in € thousands)
Items
31/12/2022
31/12/2021
31/12/2020
10.
Interest income and similar revenues
357,272
250,598
278,318
20.
Interest expenses and similar charges
(19,723)
(7,449)
(10,647)
40.
Fee and commission income
903,823
871,244
720,503
50.
Fee and commission expense
(77,835)
(73,834)
(65,201)
70.
Dividend income and similar revenue
206
199
108
80.
Net trading income
77,966
71,643
87,678
90.
Net gain (loss) on hedging activities
12,207
2,505
(259)
5.4.	 
21%
Shareholders
11%
Economic value
retained
BREAKDOWN OF THE ECONOMIC VALUE GENERATED
33%
9%
0%
26%
Employees and staff
Suppliers
Central and public 
administration
Community

91
(amounts in € thousands)
Items
31/12/2022
31/12/2021
31/12/2020
100.
Profit (loss) from the sale or repurchase of:
49,404
32,141
9,005
 
a) financial assets at amortised cost
49,095
29,243
7,235
 
b) financial assets at fair value through other comprehen-
sive income
309
2,898
1,770
 
c) financial liabilities
-
-
-
110.
Profits (Losses) on other financial assets and liabilities 
measured at fair value through profit or loss
(480)
(39)
(758)
 
a) financial assets and liabilities designated at fair value
-
-
-
 
b) other financial assets designated at fair value
(480)
(39)
(758)
130.
Net write-downs/write-backs for credit risk relating to:
(5,186)
(586)
(9,584)
 
a) financial assets at amortised cost
(5,184)
(594)
(9,569)
 
b) financial assets at fair value through other comprehen-
sive income
(2)
8
(15)
140.
Profit/loss from contract changes without cancellation
(1)
-
23
160.
Net premiums
-
-
-
170.
Net other income (expense) from insurance operations
-
-
-
230.
Other net operating income/expenses
139,717
140,813
111,869
250.
Gains (losses) on equity investments
-
-
-
280.
Profit (loss) on disposal of investments
543
1
(6)
320.
Profit (loss) after tax from operating activities
-
-
-
A. TOTAL ECONOMIC VALUE GENERATED
1,437,913
1,287,236
1,121,049
190.
b) other administrative expenses
(126,007)
(112,996)
(116,349)
ECONOMIC VALUE DISTRIBUTED TO SUPPLIERS
(126,007)
(112,996)
(116,349)
190.
a) Payroll costs
(479,009)
(458,323)
(367,007)
ECONOMIC VALUE DISTRIBUTED TO EMPLOYEES 
AND STAFF
(479,009)
(458,323)
(367,007)
340.
Profit (Loss) for the year attributable to minorities
-
-
-
ECONOMIC VALUE DISTRIBUTED TO MINORITIES
-
-
-
Net profit attributable to shareholders
(299,210)66
(237,947)
-67
66	The portion allocated to shareholders corresponds to the allocation to dividends of net profit for 2022 that the Board of Directors of the Parent Company will propose to the 
Shareholders’ Meeting.
67	In line with the recommendations of the European Central Bank and the Bank of Italy concerning the dividend distribution and share buy-back policies that credit institutions 
and significant supervised groups should adopt in the economic environment impacted by the Covid-19 emergency, the Shareholders’ Meeting approved the allocation of 
the 2020 profit entirely to reserves. At the subsequent Shareholders’ Meeting on 21 October 2021, it was resolved to pay a total dividend of €323.2 million with value date 
24 November 2021.

92
(amounts in € thousands)
Items
31/12/2022
31/12/2021
31/12/2020
ECONOMIC VALUE DISTRIBUTED TO SHAREHOLDERS
(299,210)
(237,947)
-
190.
b) other administrative expenses: indirect duties and 
taxes (-)
(142,916)
(145,162)
(116,731)
190.
b) other administrative expenses: charges for resolution 
and deposit guarantee funds (-)
(47,734)
(40,039)
(26,805)
300.
Tax expense (income) related to profit or loss from con-
tinuing operations: current tax, adjustment to current tax 
of prior years, reduction of current tax for the year
(178,666)
(150,741)
(117,805)
ECONOMIC VALUE DISTRIBUTED TO CENTRAL AND PUBLIC 
ADMINISTRATIONS
(369,316)
(335,942)
(261,341)
190.
b) other administrative expenses: donations (-)
(693)
(179)
(313)
ECONOMIC VALUE DISTRIBUTED TO THE COMMUNITY AND 
ENVIRONMENT
(693)
(179)
(313)
B. TOTAL ECONOMIC VALUE DISTRIBUTED
(1,274,235)
(1,145,387)
(745,010)
200.
Net provisions for risks and charges
(10,051)
(9,890)
(7,310)
 
a) commitments and guarantees given
(23)
9
(39)
 
b) other net provisions
(10,028)
(9,899)
(7,271)
210.
Impairment/write-backs on property, plant and equipment
(20,258)
(19,529)
(19,683)
220.
Net adjustments/reversals of intangible assets
(6,607)
(6,689)
(5,757)
250.
Profit (loss) from investments (for the measurable portion: 
“write-downs/write-downs”, “write-downs/write-backs”, 
“other charges and income”)
(276)
(26)
-
260.
Gains (losses) on fair value of tangible and intangible as-
sets
-
-
-
270.
Impairment of goodwill
-
-
-
300.
Tax expense (income) related to profit or loss from con-
tinuing operations: adjustment to current tax of prior 
years, adjustment of deferred taxes
2,809
37,04968
(19,718)
Profit allocated to reserves
129,295
142,764
323,571
C. TOTAL ECONOMIC VALUE RETAINED
(163,678)
(141,849)
(376,039)
68	 The positive change recognised in 2021 was mainly due to the effects of exercising the option for the tax realignment of goodwill recognised in the financial statements at 
31 December 2019 provided for by Article 110 of Legislative Decree No. 194 of 2020. The profit and loss effects of the realignment for the portion relating to the change in 
deferred tax assets and the change in deferred tax liabilities amounted to €34.7 million.

93
ENVIRONMENTALLY SUSTAINABLE ASSETS
69	Commission Delegated Regulation (EU) 2021/2139 of 4 June 2021 supplementing Regulation (EU) 2020/852 of the European Parliament and of the Council establishing the 
technical screening criteria for determining the conditions under which an economic activity qualifies as contributing substantially to climate change mitigation or climate 
change adaptation and for determining whether that economic activity causes no significant harm to any of the other environmental objectives.
70	Due to an improvement in the collection and calculation process, the figures for the year 2021 have been restated with respect to those published in the 2021 Sustainability 
Report. See the 2021 Sustainability Report, for the previously published historical figure.
71	 The total assets covered correspond to the total assets net of exposures to central governments, central banks and supranational issuers and the assets held for trading.
In July 2020, Regulation (EU) 2020/852 (the Taxon­
omy Regulation) came into force, with the main ob­
jective of defining environmentally sustainable eco­
nomic activities by introducing environmental criteria 
and objectives, also with the aim of promoting more 
responsible allocation of capital to companies that 
invest in economic activities that are positively cor­
related with potential impacts on the environment, 
health and social activities. Specifically, Article  8(1) 
of the Taxonomy Regulation requires certain large 
companies subject to the disclosure requirements 
of the Non-Financial Reporting Directive “NFRD” (EU 
Directive 2014/95), which include Fineco, to provide 
public disclosures on how and to what extent their 
activities are related to environmentally sustainable 
objectives and activities, as defined in the Regula­
tion.
In this respect, with regard to the year 2022, Fineco 
carried out the analysis of the part of its consolidat­
ed balance sheet assets eligible for the Taxonomy 
pursuant to Article 10(3) of Delegated Regulation (EU) 
2021/2178, i.e. related to exposures to the econom­
ic activities included in Delegated Regulation (EU) 
2021/213969. 
2022
202170 
Total covered assets71
40.0%
42.1%
Eligible activities/total covered assets 
23.6%
17.4%
Non-eligible activities/total covered assets
76.4%
82.6%
Total assets
100%
100%
Exposures to central governments, central banks and supranation­
al issuers/total assets
60.0%
57.9%
Trading book exposures/total assets
0.0%
0.0%
Exposures to derivatives/total assets
4.7%
0.4%
Exposures to companies not required to publish non-financial in­
formation/total assets
1.4%
0.8%
Exposures to on demand interbank loans/total assets
0.7%
0.6%
The share of the eligible activities of the Taxono­
my of the FinecoBank Group, amounting to 23.6% 
of the consolidated covered assets and of equal 
value for both the climate change mitigation and ad­
aptation objectives, is associated with the value of 
the stock of loans to households collateralised by 
residential property, and, from 2022, to the portions 
of eligible activities related to exposures to credit in­
stitutions, asset management companies and insur­
ance companies. In fact, from this reporting year, it 
has been possible to calculate this share of eligible 
activities following the publication by the counter­
parties of their respective KPIs of eligible activities 
in the EU Taxonomy. Lastly, there are no exposures 
to companies operating in the sectors of economic 
activity indicated in Annexes I and II of Delegated 
5.5.

94
Regulation (EU) 2021/2139 and subject to the obliga­
tion to publish non-financial information pursuant to 
Article 19a or 29a of Directive 2013/34/EU. 
FinecoBank’s lending policy is focused on grant­
ing credit to Retail customers and investing in Cen­
tral Government financial instruments (Government 
bonds), as reflected in the amount of the exposures 
to central governments, central banks and supra­
national issuers, which represent 60% of total con­
solidated assets.
In line with this approach, the total exposure to com­
panies not required to publish non-financial infor­
mation is minimal, at 1.4% of total assets.
The figures reported include the line items loans and 
advances, debt securities and equity investments 
taken from the figures in the 2022 Consolidated Fi­
nancial Statements, and therefore include the expo­
sures of the Parent Company FinecoBank S.p.A. and 
the subsidiary Fineco Asset Management DAC.
In order to increasingly integrate sustainability as­
pects into the corporate strategy and product design 
processes, sustainability risk assessment has been 
integrated into the risk assessment process for new 
products and substantial changes to existing prod­
ucts since 2021 (“New Product Process” Global 
Policy). 
Lastly, in light of the recent changes in the European 
regulations on the energy efficiency of buildings and 
disclosure of environmental, social and governance 
risks in the Pillar III disclosure, the Bank has begun 
structuring a process for the systematic collection of 
the information needed to assess the sustainability 
aspects associated with residential properties pur­
chased by retail customers, for whom a Fineco mort­
gage has been requested. This information includes, 
for example, the energy class of the buildings, which 
is useful for the reporting on the Taxonomy-aligned 
activities as defined by the technical screening crite­
ria of Delegated Regulation (EU) 2021/2139.

95
PROTECTION OF THE COMPANY REPUTATION
To protect the company reputation, the Group has 
adopted the Global Policy on Media Relations and 
Public Speaking, which is aimed at employees and 
personal financial advisors and provides guidance 
on the principles and rules relating to the manage­
ment of media relations, the use of social media and 
personal websites, spreading a culture aligned with 
the company’s principles and promoting the respon­
sible use of these communication tools. 
The aim of the policy is to clarify to each company 
structure when and to whom in the media it is al­
lowed to communicate with in the name and on 
behalf of the Fineco Group, or when it may use the 
Group’s name for events and company matters that 
could influence the Group’s public image, includ­
ing external events, public meetings, conferences 
or seminars with a media impact. In addition to the 
company officials authorised to speak to the media – 
i.e. the Chairman of the Board of Directors, the CEO 
and General Manager, the Deputy General Manag­
ers and the CFO – the Policy also identifies other 
spokespersons who can give interviews or attend 
public events (Marketing Director, Product Manager, 
HR Manager, etc.). The management of media rela­
tions is centralised within the Identity & Communica­
tions Team, which is the point of reference and coor­
dination for these activities. The policy also regulates 
the use of social media, prohibiting employees from 
disclosing confidential or sensitive information con­
cerning Fineco, also for the purpose of protecting 
the Group’s reputation and that of its stakeholders. 
In addition to the adoption of this Global Policy, Fine­
coBank develops a reputational programme, which 
identifies and monitors the main areas of concern 
and therefore of interest for Italians in relation to the 
role of companies, such as, in particular in 2022, the 
management of environmental issues, the protec­
tion of employees and the management of the infla­
tionary/recessionary environment.
The actions taken by FinecoBank to protect its rep­
utation are focused on two main stakeholders: the 
Italian population and the company’s employees. 
With regard to the population, on a monthly and quar­
terly basis, a reputational indicator is measured and 
analysed, and the impact this has on the propensity 
to buy, to recommend and to trust Fineco, in order to 
identify any situations which, as a result of specific 
activities carried out, may have weakened consum­
er trust in Fineco, in addition to the socio-economic 
context.
The areas for action are identified on the basis of ra­
tional parameters inherent in some areas of the com­
pany, including products and services, management 
leadership, financial performance, the workplace 
and the ability to innovate, in order to identify the 
aspects to be mitigated because they are perceived 
to be weaker and the aspects that should continue 
to be enhanced, also with respect to the areas of 
highest expectation.
For employees, the monitoring covers the same are­
as, but with a different timing and with the addition of 
a specific indicator relating to the level of employee 
engagement, aimed at measuring the sense of be­
longing to the organisation.
To regularly report and share reputational results, 
a working group has been set up that cuts across 
Fineco’s functions, with the aim of making more in­
formed decisions on actions to be taken. The func­
tions involved include: Marketing, Advertising and 
Events, HR, Sustainability, Investor Relations, CRM, 
PFA Network.
Specifically, in 2022, a number of specific are­
as relating to Fineco’s customer experience were 
measured, and the results that emerged helped the 
above-mentioned functions to better target their 
communication in this area.
5.6.

96
96
96
96
06

97
ETHICS AND COMPLIANCE 
CULTURE
6.1. 	
COMPLIANCE CULTURE
6.2. 	
ETHICS AND INTEGRITY IN BUSINESS CONDUCT

98
Compliance with internal and external regulations 
and codes of conduct is of great strategic impor­
tance. Compliance with rules and fairness in activ­
ities are fundamental to the conduct of banking 
business, which by nature is based on trust and 
transparency. A culture of compliance supports the 
protection of customer rights, as well as the creation 
and maintenance of a competitive business environ­
ment, thereby contributing to local and community 
development.
Fineco pursues its business objectives with hones­
ty, fairness and responsibility, in full and substantive 
compliance with the rules, professional ethics and 
the spirit of the agreements it has signed, setting 
high standards of compliance for the whole Group. In 
complying with the applicable regulations and inter­
nal rules, the Group prevents misconduct and con­
tributes, among other things, to combating financial 
crime. Fineco’s business relationships are based on 
the principles of transparency, integrity, professional­
ism and must be conducted in strict compliance with 
applicable laws and related internal regulations.
The Group’s regulatory model has two levels: 
·	 a global level, through regulations issued by Fi­
necoBank and addressed to at least one other 
Group Company, the Global Rules (GRs). The GRs 
constitute the Group rules that the Parent Compa­
ny issues in performing its policy, coordination and 
control functions, to regulate activities that are con­
sidered relevant in accordance with the legal and 
regulatory provisions in force and/or with regard 
to responsible business conduct and risk manage­
ment.
·	 a local level, through the regulations issued by a 
Group Company applicable to itself, including its 
foreign legal entities, and where appropriate to its 
other subsidiaries.
At Parent Company level, each function issues GRs 
for its area of responsibility, adhering to the corpo­
rate principles and rules laid down for the drafting of 
regulations and the related approval and distribution 
processes. The issuing functions (“Owners”) are also 
responsible for:
·	 implement the GRs under their responsibility in 
FinecoBank, identifying and completing the regu­
latory, organisational, operational and/or IT meas­
ures required to implement the regulatory provi­
sions contained in the GRs; and
·	 monitoring the status of their approval and imple­
mentation at the target functions and legal entities.
In relation to the management of Group rules, the 
Bank’s Organisation and Operations Department 
acts as the overall hub and coordinator of the man­
agement of the various rules by the Parent Com­
pany’s internal owners, by establishing principles, 
standards and rules applicable at Group level and 
supporting the rule owners in ensuring their correct 
application. The controls are carried out through 
periodic reporting to FinecoBank’s Owner units and 
Corporate Bodies on the status of approval, imple­
mentation and planning of the Global Rules, includ­
ing the status of those transmitted to the legal enti­
ties.
In the area of business relations, the implementation 
of commitments for responsible business conduct is 
regulated in the Expenditure Regulation, which gov­
erns the entire procurement process at Group level. 
Lastly, training on the implementation of the commit­
ments is provided within the processes of identifying 
the training needs of employees and implementing 
training activities, in compliance with the applicable 
internal and external regulations, managed by the 
Chief People Officer Department.

99
COMPLIANCE CULTURE 
72	 The SpeakUp channel is operated by an independent third party.
Compliance culture is a core value for Fineco. If busi­
ness is at the core of the Bank’s operations, com­
pliance and integrity are how its business activities 
must be carried out. In doing so, the Compliance De­
partment regularly defines, develops and monitors 
the implementation of and conformity to the Bank’s 
rules, procedures, methodologies and other compli­
ance standards. The function also manages these 
processes, thus promoting an integrated compli­
ance culture.
In this regard, FinecoBank has adopted a Code of 
Ethics to mitigate operational and reputational risk 
and promote a widespread culture of internal con­
trol. The Code of Ethics is an integral part of the 
Organisation and Management Model pursuant to 
Legislative Decree 231/2001. It contains a series of 
principles of ethics and rules intended to ensure that 
the conduct of all addressees is always guided by 
criteria of fairness, collaboration, loyalty, transparen­
cy and mutual respect, as well as to prevent the per­
petration of offences or administrative offences set 
forth in Legislative Decree 231/2001. 
The Fineco Group has also adopted the Integrity 
Charter and Code of Conduct Global Policy, which 
sets out the Group’s ethical principles and standards. 
In particular, with a view to promoting the compliance 
culture and the Group’s commitment to sustainabili­
ty issues, the Code of Conduct sets out the general 
principles that must be observed by all members of 
the executive, strategic and control bodies, employ­
ees and third parties, in order to ensure high stand­
ards of professional conduct and integrity in carrying 
out activities performed in-house or on behalf of the 
Group. Employees who violate or engage in conduct 
that is not in line with the obligations arising from that 
document may be subject to disciplinary action by 
the human resources function. Serious violations of 
the provisions of this Code of Conduct and of the lo­
cal laws and regulations referred to in the Code may 
instead result in termination of employment.
Lastly, the Compliance Culture Global Policy de­
fines the key principles of the compliance culture at 
Group level, as well as the roles and responsibilities 
of the internal functions responsible for implement­
ing this policy (e.g. Compliance, Human Resources 
and Communications).
With the aim of strengthening the compliance cul­
ture within the Bank, the Compliance Culture - Tone 
from the Top initiatives have been implemented 
since 2018, which meet the top management’s need 
to interpret and disseminate a culture of respect, 
prudence and integrity to all those who work for and 
on behalf of the organisation, enhancing internal 
risk mitigation procedures. In this context, the Top 
Management of Fineco and Group Companies helps 
to ensure the adoption and supervision of correct 
and compliant behaviour to achieve sustainable 
business objectives. The programme continued in 
2022, with senior managers focusing on specific 
compliance issues and communicating directly with 
employees via email or the company intranet portal, 
such as: conduct and behaviour at Fineco, Anti-cor­
ruption, the Organisation and Management Model 
pursuant to Legislative Decree 231/2001, Antitrust 
and Unfair Commercial Practices, ESG issues and 
Whistleblowing.
With regard to whistleblowing, Fineco believes that 
reporting any irregularities helps to protect the com­
pany and its reputation, as well as all of its employ­
ees. Through the Whistleblowing Global Policy, 
FinecoBank has adopted a system through which 
employees, personal financial advisors and third 
parties can report any conduct that violates the law 
or the Bank’s internal rules. In this regard, the Bank 
provides employees, personal financial advisors 
and third parties with specific channels, available 24 
hours a day, 7 days a week, for reporting irregular­
ities, also anonymously. Specifically, the reporting 
can be made through the following channels:
·	 by phone, via the FinecoBank SpeakUp line72, 
6.1.

100
leaving a voice message, also anonymously;
·	 on the website, via the FinecoBank SpeakUp web 
service, leaving a written message, also anony­
mously;
·	 using the dedicated email address;
·	 by writing to the dedicated postal address.  
Information on whistleblowing is also made availa­
ble to employees and personal financial advisors in 
a specific section of the company Intranet dedicat­
ed to the importance of this issue, which provides 
details on how and when to make the report, and 
through dedicated online training sessions.
If there is any reason to suspect that unacceptable 
conduct has occurred or may occur, it can be report­
ed to the company’s Compliance Officer (the local 
anti-corruption manager) who, as the person respon­
sible for the internal reporting systems, ensures that 
the procedure is properly conducted. If a report falls 
within the scope of the Whistleblowing Policy, the 
Compliance Officer carries out a preliminary assess­
ment of the report received and, if he or she con­
siders that there is sufficient evidence of unlawful 
conduct to justify the initiation of an investigation, a 
person or function is assigned to carry out the inves­
tigation, based on the matter reported. If the Compli­
ance Officer is hierarchically and functionally subor­
dinate to the person to whom the complaint relates 
or if he or she is held responsible for the violation 
or has a potential interest in the report that is liable 
to compromise his or her impartiality and independ­
ence of judgement, the company’s Internal Audit De­
partment may be contacted directly. 
Serious disclosures, even if anonymous, must be 
managed and promptly and confidentially reported, 
complying with the specific Group process, which 
guarantees the involvement of the Senior Manage­
ment of the Group Company in analyses, defining 
the activity plan, the investigation’s results, recom­
mendations and monitoring.
FinecoBank ensures confidentiality, privacy and 
data protection and guarantees the protection of 
the whistleblower from any direct or indirect retalia­
tion related to the report made. Where possible, the 
whistleblower is informed of the initiation, progress 
and outcome of the process. At the end of the in­
vestigation, the person or function in charge of the 
investigation prepares a report, summarising the 
course of the investigation and the evidence gath­
ered, setting out the conclusions, providing recom­
mendations and suggesting actions to be taken to 
remedy the breaches identified and ensure that they 
do not occur in the future. 
In addition, an annual Report is prepared on the 
proper functioning of the internal system for report­
ing breaches, containing aggregate information on 
the results of the activities carried out, which is made 
available to the company personnel after has been 
approved by the Board of Directors.

101
ETHICS AND INTEGRITY IN BUSINESS CONDUCT
FinecoBank S.p.A. has adopted an Organisation 
and Management Model, in accordance with Leg­
islative Decree 231/2001 (“Model”), concerning the 
administrative liability of entities, companies and 
associations. The aim of adopting the Model is to 
ensure that the Bank provide its own customers 
with banking and financial services with respect for 
the values and principles of integrity, professional­
ism, diligence, honesty, fairness and responsibility. 
Although organisations are not legally obliged to 
implement the Model, it nonetheless performs the 
important function of preventing offences, including 
corruption, that could give rise to the Bank’s admin­
istrative liability.
The Model, approved by the Board of Directors and 
updated in 2022 to incorporate the latest regula­
tory changes introduced, is aimed at all corporate 
bodies’ members, all FinecoBank personnel and ex­
ternal parties, such as, for instance: advisors, inde­
pendent professionals, personal financial advisors, 
suppliers and business partners. 
The adoption of Model pursues the following funda­
mental objectives:
·	 to remind and raise awareness among its intend­
ed readers of correct behaviour and compliance 
with internal and external regulations, rejecting any 
conduct contrary to the principles of sound and 
transparent business operations to which the Bank 
aspires;
·	 to prevent offences, including criminal offences, 
within the Bank, through continuous monitoring of 
all areas of activity at risk and staff training on how 
to correctly perform assigned tasks;
·	 to implement the values set out in the Group Integ­
rity Charter and Code of Conduct.
In particular, FinecoBank has identified the follow­
ing tools for formulating, planning and implementing 
company decisions and for carrying out the related 
checks: the Corporate Governance rules, the internal 
controls system, the delegation of powers system, 
the Integrity Charter and the Code of Conduct. More­
over, with regard to Legislative Decree 231/2001, the 
Bank has formalised specific decision-making proto­
cols that identify the activities at risk and the related 
potential offences, as well as the principles of con­
duct and the rules on checks, designed to prevent 
those offences, and has established additional rules 
of conduct in the Code of Ethics. In drafting the Mod­
el, the Bank took into account the ABI (Italian Bank­
ing Association) guidelines.
ANTI-CORRUPTION
Fineco has a “zero tolerance” approach to corrup­
tion and prohibits facilitation payments. Political do­
nations in any tangible or intangible form are also 
prohibited, as specified in the Anti-Corruption Glob­
al Policy. Accordingly, there were no contributions 
of this kind made in 2022 and no cases of corruption 
were recorded. 
Fineco’s approach to preventing corruption and brib­
ery is defined in the Anti-Corruption Global Policy, 
which, together with the related Operating Instruc­
tions, establishes the minimum standards for an­
ti-corruption compliance and apply to all members of 
Fineco’s strategic, control and executive bodies, em­
ployees, personal financial advisors and casual staff. 
More specifically, the Anti-Corruption Policy aims to 
define principles and rules aimed at identifying and 
preventing potential acts of corruption in order to 
protect the integrity and reputation of the Group and 
to provide recipients with general information on the 
measures taken to identify, mitigate and manage the 
risks of corruption. The Bank has also adopted an 
6.2.

102
Anti-Corruption Programme, based on the follow­
ing five main elements, whose implementation is 
periodically monitored and submitted to the Bank’s 
bodies through periodic compliance reporting:
•	assessment of corruption risk in terms of the re­
sults of the risk assessments;
•	 verification of the updating of policies and procedures;
•	monitoring of compulsory training attendance;
•	continuity of the tone from the top initiatives;
•	controls in terms of the summary evaluation of the 
Second Level Controls (2LCs) carried out.
The Group has adopted specific mechanisms to 
monitor the effectiveness of the adopted anti-corrup­
tion and bribery approach, including: escalation pro­
cedures for significant and strategic issues, quarterly 
information requests from management, analysis and 
testing of the results of activities relating to managing 
second level controls, compliance risk assessment 
processes carried out for each regulatory area of the 
Compliance Department, and internal audit inspec­
tions. The last two mechanisms result in risk mitiga­
tion actions that need to be completed on time to 
ensure the management of the risks identified.
Lastly, the Bank’s activities and organisational struc­
tures are subject the implementation of the Organi­
sation and Management Model in accordance with 
Legislative Decree 231/2001 in relation to anti-cor­
ruption.
MANAGING CONFLICTS OF INTEREST  
For the management of conflicts of interest, the Group 
has adopted the Global Policy for the management 
of transactions with persons in potential conflict of 
interest of the FinecoBank Group. The document 
sets out the principles and rules to be observed in or­
der to guard against the risk arising from situations of 
possible conflict of interest caused by the proximity of 
certain parties to the decision-making centres of the 
Bank and the Company controlled by the Group. Spe­
cifically, the Global Policy regulates transactions with: 
(i) 	 related parties in accordance with the Consob 
Related-Party Regulations; 
(ii) associated persons within the meaning of the 
Bank of Italy Supervisory Regulations (Part Three, 
Chapter 11, Circular No. 285 of 2013);
(iii) 	bank corporate officers in accordance with Arti­
cle 136 TUB; 
(iv) 	relevant persons pursuant to Article 88 CRD V; 
(v) 	other entities identified by the Bank on a discre­
tionary basis.
In addition, FinecoBank has implemented the Con­
flicts of Interest Global Policy, which sets out the 
single model for identifying and managing Conflicts 
of Interest (below the “Model”). 
The current Model adopted by the FinecoBank 
Group involves: i) the identification of events/activi­
ties related to the Group that may generate conflicts 
of interest; ii) the identification of the types of con­
flicts of interest on the basis of the group classifica­
tion; iii) the identification of the organisational meas­
ures capable of mitigating or eliminating the specific 
types of conflict of interest as well as the conduct to 
be adopted; iv) the recording of conflicts of interest; 
and, lastly, v) the controls. 
Based on the Model, certain types of organisational 
measures and general principles have been identi­
fied to eliminate or mitigate the risk of harming cus­
tomer interests, including:
·	 measures based on the organisational structure, 
such as i) the separation, between product com­
panies and distribution companies, of the develop­
ment and distribution of the products and services 
offered to customers and the separation, where 
possible, into different business units of activities 
that generate conflicting interests and transac­
tions; ii) the adoption of the principle of hierarchical 
independence between structures that oversee 
potentially conflicting activities; and iii) the preven­
tion or control of the simultaneous performance of 
conflicting activities;

103
·	 measures based on specific policies/internal mem­
os, such as the adoption of: i) a remuneration policy, 
with incentive mechanisms designed to eliminate 
any direct connection between the remuneration 
of individuals who predominantly engage in trans­
actional activities and the results of activities re­
lated to interests that might conflict with them; ii) 
policy on personal interests, for the establishment 
of limits, exclusions, behavioural measures, notifi­
cation procedures and monitoring of cases of per­
sonal interests of employees potentially in conflict 
with the interests of the Group or the Group’s cus­
tomers; iii) policy on the execution/transmission of 
orders; and the identification of specific functions 
dedicated to the management of conflicts of inter­
est (i.e. the Compliance Department); 
·	 measures based on codes of conduct and employ­
ee training modules, such as: i) training of staff at all 
levels on conflict of interest regulations; ii) preven­
tion of the exercise of undue influence by individu­
als in top management positions on the employees 
responsible for carrying out transactions, outside 
the structures under their hierarchical authority. 
The Compliance Department submits a Report on 
Conflicts of Interest to the Top Management at least 
once a year.
ANTITRUST AND UNFAIR COMMERCIAL PRACTICES
Following the introduction of the Group’s antitrust 
regulations in 2016, the Bank has adopted an anti­
trust Compliance Programme, subject to periodic 
monitoring and review, aimed at strengthening an­
titrust governance, promoting a competition culture 
and reinforcing the broader compliance culture, en­
hancing the Bank’s reputation in the markets and 
mitigating antitrust risks and sanctions.
In this regard, Fineco has adopted the Group an­
titrust and Unfair Commercial Practices Policy, 
which includes practical rules of conduct for the 
proper management of meetings with competitors, 
the promotion and marketing of products and ser­
vices offered by the Bank in order to protect con­
sumers, and inspections carried out by the Antitrust 
Authorities.
Lastly, the Code of Ethics obliges all those con­
cerned to conduct all activities in compliance with 
current laws and regulations related to non-compe­
tition agreements and forbids any act of intimidation 
against the Bank’s competitors. 
In 2022, there were no prosecutions and penalties 
or proceedings for anti-competitive behaviour, anti­
trust and monopolistic practices.
PROTECTION OF HUMAN RIGHTS
The Group recognises the importance of respect 
for human rights as an essential element for prop­
er business conduct. The Commitment to Human 
Rights Global Policy reinforces the Group’s desire 
to base its activities on guaranteeing and promot­
ing respect for all human rights, in order to ensure 
compliance with national and international regula­
tions and standards, and to establish an inclusive 
approach that manages impacts and minimises po­
tential risks of violation, while maintaining an open 
dialogue with stakeholders and taking into account 
their legitimate expectations. This commitment is un­
derpinned by the principles set out in the main ref­
erences and international standards, including the 
Universal Declaration of Human Rights and the UN 
Guiding Principles on Business and Human Rights. 
This commitment defines the roles and responsi­
bilities, as well as the principles, rules, procedures 
and reporting systems adopted in order to create 
a corporate culture that is capable of guarantee­

104
ing human dignity and a working environment that 
is free of any form of discrimination, and promoting 
the diversity and inclusion of its own staff and per­
sonal financial advisors. It emphasises the protection 
and the importance placed on and the commitment 
to recognising all forms of diversity, be it in terms of 
gender, physical characteristics, skills, sexual ori­
entation, gender identity/expression, or beliefs and 
opinions, valuing the richness and innovation there­
of to benefit the company. 
The Bank also pays close attention to the indirect 
impacts on human rights that may be generated 
through its financial advisory activities and promotes 
dialogue with customers based on clarity and trans­
parency, in addition to considering potential risks 
related to the respect of human rights in investment 
decisions. In this regard, Fineco AM has also adopt­
ed the Declaration on Modern Slavery and Human 
Trafficking, which was approved by the Company’s 
Board of Directors in June 2022 and is aimed at fully 
integrating the fight against slavery and human traf­
ficking into its fund management approach.
The commitment to human rights also applies to 
the supply chain, with the aim of minimising the risk 
of violation of those rights; To this end, Fineco im­
proved the efficiency of the assessment of suppli­
ers in relation to social and environmental impacts, 
by evaluating the characteristics of the supply chain 
also taking into account respect for and protection 
of human rights. 
Any impact on human rights must be managed and 
reduced in such a way as to protect privacy and 
identify and mitigate any risk of corruption. With this 
in mind, as already described, the “whistleblowing” 
infringement reporting system has been put in place 
with the aim not only of reporting potential unlawful 
behaviour, which can result in possible violations of 
human rights, but also of protecting confidentiality 
with regard to the identities of both the whistleblow­
er and the accused in order to prevent discriminato­
ry behaviour as a result of such reporting.
PRIVACY AND DATA PROTECTION
The subject of privacy, namely the individual right 
to the confidentiality of personal information and a 
private life, has been the subject of specific regu­
lations in recent years with the aim of safeguarding 
and protecting the private sphere of the individual. 
The protection of personal data is recognised as an 
individual’s right to have control over information 
and personal data concerning their private life, and 
is fully recognised as a fundamental human right. 
In this context, for Fineco, safeguarding the personal 
data of its data subjects is fundamental to protect 
them from undue intrusions into their personal lives 
by third parties. To this end, the Bank has put in 
place a comprehensive system for protecting the 
information provided by data subjects to Fineco. In 
addition, for the purposes of transparency towards 
its data subjects, the Bank has adopted special infor­
mation tools, such as information on the processing 
of personal data, to make data subjects aware of the 
purposes, methods and rights concerning the pro­
cessing of personal data carried out by Fineco.
The Data Protection Office (DPO) has assumed 
an increasingly central role, both with regard to the 
general management of privacy issues and to the 
launch of new projects that have an impact on the 
protection of personal data, in order to assess the 
feasibility of these and the most appropriate means 
of implementation. The DPO ensures that the privacy 
legislation is adhered to and overseeing the imple­
mentation of any updates and alignments with the 
regulations, and monitors compliance with the points 
stipulated in the measures provided by the Antitrust 
Authority. 
To this end, Fineco has adopted a Global Policy on 
Privacy, applicable to all Group companies, and has 
issued further specific internal regulations on data 
protection, such as the detection and management

105
of data breaches, the appointment of external data 
processors, the duties and responsibilities of the 
data protection officer, and the management of the 
register of processing operations. 
The measures adopted internally by FinecoBank 
cover all business processes, from the design of 
products and services to training, incentives and in­
teraction with the data subjects and they include:
·	 the establishment of a regulation on the use of 
electronic tools (e.g. email, internet, laptops and 
smartphones) during work, to set out the principles 
of conduct on their correct use, including rules on 
security, personal data protection, confidentiality 
and protection of the Bank’s workers;
·	 the dissemination of specific guidelines on the 
Data Retention Period and the Rights of Data 
Subjects;
·	 a Data Privacy Impact Assessment (DPIA);
·	 the updating of the “Data Protection Agreement” 
document used for the appointment of Data Pro­
cessors;
·	 the adoption of a Legitimate Interests Assess­
ment (LIA) model for assessing the legal basis 
of the legitimate interest, where used by the data 
controller.
These instruments are published and made availa­
ble to all addressees on the corporate portal, and 
communicated at the time of recruitment to each 
employee, or at the start of the collaboration to each 
consultant worker, who uses the Bank’s information 
systems, with acknowledgement that they have 
viewed their contents. 
In order to support this, it should be noted that dur­
ing the course of 2022, Fineco continued to devel­
op and improve the measures required in order to 
implement the new regulations set out under the 
GDPR, including adhering to the principles of data 
protection by design and by default, a data protec­
tion impact assessment, the fine-tuning of the data 
processing activity register and the strengthening 
of security measures.
The Bank has implemented a data breach manage­
ment procedure that sends notification to the DPO 
of any violations detected internally or by external 
entities (including customers); this retrieves informa­
tion from the relevant departments and assesses the 
impact on privacy. For each breach, the necessary 
measures to reduce the risk of similar occurrences 
in the future are assessed, with the help of the com­
petent Bank structures. 
Data protection is also carried out through fraud 
monitoring in accordance with European and nation­
al legislation, security regulations and best-practice 
industry standards, in order to ensure that informa­
tion systems are protected from attacks or incidents 
that could compromise the rights of data subjects. In 
the event of a data breach, the Bank, in its capacity 
as Data Controller, will proceed with assessing this 
and sending out any communications and notifica­
tions necessary pursuant to Articles 33 and 34 of the 
GDPR, in the manner and within the time limits indi­
cated therein.
With regard to the handling of reports and com­
plaints regarding privacy-related issues, Fineco 
has formalised and adopted a number of specific in­
ternal procedures designed to ensure that these are 
given due consideration, and dealt with within the 
timeframe established by the GDPR. 
The data protection management model can be au­
dited by the Internal Control Functions. In particu­
lar, it is worth mentioning the ex-post controls carried 
out by the Compliance Department in order to ver­
ify the effective application of internal rules and the 
effectiveness of the measures put in place to elimi­
nate or mitigate any non-compliance. For each area 
monitored, including privacy, there is provision for 
the identification of the main legal requirements and 
the respective association with a level of risk defined 
based on the comparison between the result of an 
indicator and the default single control limit thresh­
old. In 2022, there were no specific internal audits 
in this regard, but the risk assessment was carried 
out to verify any non-compliances in this area. The 
second level controls continued in accordance with 
the framework in place.
The data protection initiatives are brought to the 
attention of stakeholders through communication 
initiatives and awareness-raising campaigns on the 
subject. For example, internal stakeholders receive

106
specific information notices on the processing of 
their personal data, enabling them to understand 
how their personal data are processed, the purpos­
es for which they are processed and their rights, 
as well as awareness-raising initiatives on the sub­
ject, through special training campaigns, and inter­
nal data privacy policies. In fact, over the course of 
2022, the Bank ensured that it continued to provide 
all staff with a mandatory privacy training plan, which 
serves as a general introduction to the topic of per­
sonal data protection. External stakeholders, on the 
other hand, are provided with data privacy notices 
and specific privacy awareness videos and FAQs.
73	 With regard to Fineco AM, there were no substantiated complaints regarding privacy breaches or events of data theft or loss.
In 2022, the Bank received 4 substantiated com­
plaints concerning violations of the personal data 
of customers which were proven to be (even if only 
partially) well-founded, although these did not rep­
resent a risk or source of potential harm to custom­
ers and their rights and freedoms. With regard to 
possible data leaks, thefts or losses, following the 
strengthening of the detection capacity of the com­
petent structures and in line with the results of the 
surveys carried out in 2022, 24 events were detect­
ed for which the Bank determined that there was no 
damage to the customers and put in place appropri­
ate corrective measures73.
TAX COMPLIANCE
The contribution that the Fineco Group makes from 
a tax perspective is a key part of the wider economic 
and social role that it plays in the countries in which 
it operates. The tax approach adopted by the Group 
is contained in FinecoBank’s Tax Strategy, which 
has been approved by the Parent Company’s Board 
of Directors, published on the institutional website 
and implemented by the Group companies through 
resolution by their respective Boards. The Strategy 
is reviewed at least annually by the tax function and 
any changes are submitted to the Board of Directors 
for approval. The document sets out the objectives 
of the top management in relation to taxation, as well 
as the risk appetite at Group level, the degree of top 
management involvement in tax planning decisions 
and the objectives in relation to risk management 
processes. 
The Fineco Group’s primary objective, in relation to 
its Tax Strategy, is to meet all its tax obligations, to 
promptly fulfil all the requirements imposed by tax 
regulations, both national and international, while 
ensuring the efficiency of the Group’s taxation at 
global level, avoiding double taxation and reducing 
its tax burden only where legitimately permitted, in 
compliance with the provisions aimed at guaran­
teeing appropriate transfer prices for intercompany 
transactions. 
The Fineco Group is committed to guaranteeing 
constant and transparent cooperation with the tax 
authorities, in compliance with the reporting obli­
gations established by international regulations on 
the exchange of information between countries (e.g. 
the FATCA and CRS regulations). In this context, the 
Bank also ensures compliance with the provisions 
on reporting to the tax authorities of cross-border 
arrangements that identify a potential undue tax ad­
vantage, in accordance with DAC 6 regulation. More 
specifically, a number of safeguards have been put 
in place both for the competent internal structures of 
the bank and for the personal financial advisors, giv­
en that the latter may find themselves in the condi­
tions envisaged in the above-mentioned regulation. 
Since 2016, Fineco has been admitted to the Coop­
erative compliance regime, which aims to increase 
the level of certainty on relevant tax issues and thus 
avoid possible disputes with the tax authorities. This 
objective is pursued through constant and pre-emp­
tive dialogue with the tax authorities, including the 
pre-emption of controls, aimed at a common assess­

107
ment of situations likely to generate tax risks, and the 
agreement on the internal control system for tax risk. 
An important step in the correct fulfilment of the tax 
obligations is the check carried out by the External 
Auditors for the signing of the tax declarations.
Compliance in tax matters is guaranteed by an ef­
fective Tax Control Framework (TCF), consisting of 
controls and procedures that ensure the correctness 
of the data entered in the relevant tax returns, tax 
payments, and communications to the financial au­
thorities, which is checked periodically in order to 
be able to promptly adopt the necessary mitigation 
actions and changes. 
Each Group Company guarantees the presence of 
a specific internal Tax function or Internal Manager. 
The Tax Affairs and Advisory Unit is responsible for 
defining domestic, international and supranational 
tax scenarios and implementing appropriate and ef­
fective procedures for the correct fulfilment of tax ob­
ligations and the correct and efficient taxation of the 
Group. This Unit, together with the CFO, periodically 
reports to the Board of Directors on major tax issues. 
In addition, the Head of the Tax Function participates 
in several internal committees as a permanent mem­
ber, in order to monitor the potentially related risks. 
The Tax Affairs and Advisory Unit includes the Tax 
Compliance Technical Unit, as a specialised arm of 
the Compliance Department, whose purpose is to 
monitor and control the risk of non-compliance with 
tax regulations by the activities carried out by the 
Bank. 
Raising awareness among the Bank’s staff and top 
management in relation to tax risk is actively sup­
ported by training courses, aimed at generating 
greater awareness of the regulations and conse­
quently fostering the development of a corporate 
culture focused on tax compliance. The Fineco 
Group does not have any remuneration schemes for 
its directors and employees that are related to tax 
saving and they are expressly prohibited from pur­
chasing or offering investments, products and other 
transactions that are purely based on a tax benefit 
for the Group, customers or other counterparties.
Fineco advocates the interests of its stakeholders by 
actively participating in the opportunities for discus­
sion offered by the professional and industry associ­
ations of which it is a member. Within these forums, 
Fineco promotes actions to improve the body of 
rules and interpretations based on the observations 
of its customers, the network of personal financial 
advisors and investors. Stakeholders are also in­
volved through the processes of gathering and tak­
ing on board their opinions, including through the 
various meetings with investors, for example, as well 
as by means of direct contact between the customer 
and the Bank, through customer care, the first and 
fundamental point of contact between the Bank and 
its customers.

108
Country-by-country 
reporting 
2022
2021
2020
Italy
Ireland
Italy
Ireland
Italy
Ireland
Name of resident entity
Fineco 
Bank 
S.p.A.	
Fineco Asset 
Management 
DAC
Fineco 
Bank 
S.p.A.
Fineco Asset 
Management 
DAC
Fineco 
Bank 
S.p.A.
Fineco Asset 
Management 
DAC
Main activity of the 
organisation
Regulated financial services
Head Count at 31/12
1,279
57
1,261
44
1,226
36
Revenues from sales to 
third parties [€/000]
1,186,045
311,555
1,045,147
244,719
967,239
179,412
Revenues from 
intragroup transactions 
with other tax 
jurisdictions [€/000]
145,103
-
119,670
-
85,951
-
Profit/loss before tax 
[€/000]
582,892
118,659
471,709
84,268
453,094
60,077
Property, plant and 
equipment other 
than cash and cash 
equivalents [€/000]
144,102
2,106
149,506
841
150,883
989
Corporate income taxes 
paid on a cash basis 
[€/000]
153,721
15,495
99,624
10,005
108,475
7,037
Corporate income taxes 
accumulated on profits/
losses [€/000]
163,626
15,040
137,478
10,592
110,235
7,570
The difference between the corporate income tax accrued on profits/losses and the tax due is attributable to 
the tax prepayments made by FinecoBank S.p.A. during the year. The reconciliation of the theoretical tax rate 
and the effective tax rate, which can be found in the financial statements, is mainly due to the combined tax 
effect of income and expenses that are not relevant in determining the tax base, as envisaged by law.

110
110
07

111
OUR PEOPLE
7.1. 	
MANAGEMENT OF OUR PEOPLE
7.2. 	
DIVERSITY AND INCLUSION
7.3. 	
PROMOTING AND DEVELOPING HUMAN RESOURCES
7.4. 	
WELFARE AND INDUSTRIAL RELATIONS
7.5. 	
HEALTH AND SAFETY

112
MANAGEMENT OF OUR PEOPLE
OUR EMPLOYEES
7.1.	  
Aware that the ability to innovate and continuous 
evolution cannot exclude the enhancement of hu­
man capital and the development of the correspond­
ing professionalism and talent, as well as the rich­
ness deriving from the diversity of its composition, 
Fineco aims to be “The Place To Be” where its staff 
are concerned; that is, a workplace in which every­
one can fully express their potential and aspirations, 
contributing to the success and sustainability of the 
business. People constitute one of the Key Success 
Factors and Fineco is committed to investing in their 
development and growth, creating an inclusive and 
sustainable work environment that allows for work-
life balance.
To consolidate and spread this culture, Fineco has 
set up a regulatory framework of policies, proce­
dures and documents governing the fundamental 
aspects of its human resource management. These 
documents include the Bank’s Code of Ethics, the 
Group Integrity Charter and Code of Conduct, and 
the “HR Policy Framework” Global Policy. This last 
policy regulates the main processes of the Human 
Resources service model, including: human resource 
management, people engagement, skill modelling, 
training and development, talent acquisition, com­
pensation and benefits. The Code of Ethics deals 
with several factors required to ensure good per­
sonnel management, including the recruitment and 
selection process, which must be carried out objec­
tively based on competence and professionalism 
and not involve any prejudice or discrimination, in 
accordance with the principle of equal opportunities.
2022
2021
2020
NO. OF EMPLOYEES
Men
Women
Total
Men
Women
Total
Men
Women
Total
TOTALS
Italy - Milan74 
615
394
1,009
608
383
991
585
375
960
Italy - Reggio Emilia
125
145
270
124
146
270
121
145
266
Outside Italy - Ireland
32
25
57
29
15
44
24
12
36
Total
772
564
1,336
761
544
1,305
730
532
1,262
Men
Women
Total
Men
Women
Total
Men
Women
Total
PERMANENT 
Italy - Milan
615
390
1,005
604
380
984
583
373
956
Italy - Reggio Emilia
121
144
265
121
141
262
120
139
259
Outside Italy - Ireland
32
25
57
29
15
44
24
12
36
Total
768
559
1,327
754
536
1,290
727
524
1,251
74	In this table, the figure for the geographical area “Italy - Milan” also includes the Data Processing Centre in Pero.

113
2022
2021
2020
N. EMPLOYEES
Men
Women
Total
Men
Women
Total
Men
Women
Total
FIXED-TERM 
Italy - Milan
0
4
4
4
3
7
2
2
4
Italy - Reggio Emilia
4
1
5
3
5
8
1
6
7
Outside Italy - Ireland
0
0
0
0
0
0
0
0
0
Total
4
5
9
7
8
15
3
8
11
Men
Women
Total
Men
Women
Total
Men
Women
Total
FULL-TIME 
Italy - Milan
613
345
958
606
331
937
583
322
905
Italy - Reggio Emilia
122
101
223
121
104
225
118
109
227
Outside Italy - Ireland
32
25
57
29
15
44
24
12
36
Total
767
471
1,238
756
450
1,206
725
443
1,168
Men
Women
Total
Men
Women
Total
Men
Women
Total
PART-TIME 
Italy - Milan
2
49
51
2
52
54
2
53
55
Italy - Reggio Emilia
3
44
47
3
42
45
3
36
39
Outside Italy - Ireland
0
0
0
0
0
0
0
0
0
Total
5
93
98
5
94
99
5
89
94
Men
Women
Total
Men
Women
Total
Men
Women
Total
BY EMPLOYEE CATEGORY AND GENDER
Executives
34
9
43
30
6
36
29
6
35
Managers
325
140
465
317
129
446
302
116
418
Professionals
413
415
828
414
409
823
399
410
809
Total
772
564
1,336
761
544
1,305
730
532
1,262
≤ 30
31-50
> 50
≤ 30
31-50
> 50
≤ 30
31-50
> 50
BY EMPLOYEE CATEGORY AND AGE
Executives
1
18
24
-
18
18
1
17
17
Managers
6
322
137
3
333
110
5
328
85
Professionals
177
550
101
183
558
82
193
543
73
Total
184
890
262
186
909
210
199
888
175

114
The average age of a FinecoBank Group employee 
at the end of 2022 was 42 (in line with 2021). Fine­
co’s staff is comprised of two main groups:
·	 highly qualified staff with specific skills, mainly in 
the product, commercial and ICT areas;
·	 young people (so-called Millennials and Gen­
eration Z), hired mainly in Customer Care, which 
serves as a “talent incubator” in which they have 
the opportunity to acquire a thorough knowledge 
of the Bank’s products, services and processes. At 
the end of the year, 15% of the total workforce was 
employed in customer care, in line with last year’s 
figure.
The sharp acceleration of digitisation in all the HR 
processes initiated in previous years continued in 
2022. Fineco, as a digital native bank, was able to 
quickly adapt to this change, shifting the entire re­
cruitment process completely to digital. Indeed, for 
several years now, the Bank has been using the 
video interview, which speeds up the screening pro­
cess, while also reducing travel times and the use of 
means of transport. Fineco establishes contact with 
“digital natives” through the channels of communica­
tion that they use most frequently, namely social me­
dia and job fairs, which, especially in recent years, 
have become digital events. FinecoBank’s partner­
ship with the top universities in Italy also continued 
in 2022 through its participation in Digital Job Fairs 
promoted by some of the main universities in Milan 
(Bicocca and Cattolica) and Pavia, as well as other 
national and international digital fairs.
In the area of customer care, the main entry point for 
new employees joining FinecoBank, at the end of a 
period of around 2 years of on-the-job training, new 
employees have the opportunity to further special­
ise in Customer Care or to embark upon a horizontal 
growth process at the Bank through intensive job ro­
tation. In 2022, this allowed 15 individuals to take the 
opportunity to get to know and work in other areas 
of the Bank. 
Fineco has always aimed for organic growth de­
signed to improve the professionalism of the com­
pany, Many of the vacancies are, in fact, filled by in­
ternal staff.
HIRING RATES AND NUMBERS75 
2022
2021
2020
Number
Rate
Number
Rate
Number
Rate
BY GENDER
Men 
58
7%
54
7%
43
6%
Women
43
8%
31
6%
30
6%
Total
101
8%
85
7%
73
6%
BY AGE GROUP
≤ 30
72
39%
63
34%
44
22%
31-50
28
3%
21
2%
27
3%
>50
1
-
1
-
2
1%
Total
101
8%
85
7%
73
6%
BY GEOGRAPHICAL AREA
Italy - Milan
69
7%
62
6%
48
5%
Italy - Reggio Emilia
5
2%
9
3%
9
3%
Ireland
27
47%
14
32%
16
44%
Total
101
8%
85
7%
73
6%
Hires and terminations by gender, age group and geographic location
75 The recruitment rate is the ratio between the number of new recruitments over the course of the year and the number of employees at year end (by gender, age group and 
geographic location).

115
OUR PERSONAL FINANCIAL ADVISORS
A fundamental element for the PFA Network Sales 
Department and Private Banking and the Network 
itself, is the relationship with the customer, based on 
transparency and the overriding protection of the 
customer’s economic and financial interests, as well 
as on technological and process innovation, effi­
ciency and growth, primarily through the acquisition 
of new customers.
The cornerstone of the Network strategy is the qual­
ity of the relationship with the customer, based 
creating a solid relationship of mutual trust. The work 
of the advisors helps to identify customer needs and 
agree on investment solutions, and the overall man­
agement of their assets, in order to develop effective 
financial and wealth planning throughout the various 
stages of their lives, primarily for the purpose of 
controlling asset risks rather than just financial per­
formance. Another equally important objective is fi­
nancial education, aimed at mitigating the emotional 
impacts on customers, as these can lead them to in­
stinctively engage in transactions that are not appro­
priate to their financial situation and personal goals.
With regard to the objective of mitigating asset al­
location risks, Fineco Asset Management’s contri­
bution is key. Indeed, the company is increasingly 
distinguished by its capacity for innovation and a 
time-to-market strictly aligned to the changing cus­
tomer needs and market situations. Furthermore, the 
open architecture platform, one of the most compre­
hensive on the market, means that the investment 
solutions that the Group is able to create (“Guided 
Products & Services”) allow the advisor to work min­
imising conflicts of interest and ensuring the best 
possible solutions to customer needs, maximising 
the overall utility.
The quality of the Network is in line with last year: 
considering the much more complex scenario, the 
assets per capita remained substantially stable, 
moving from €33.9 million to €32.1 million. Personal 
76	 The termination rate is the ratio between the number of employees that have left over the course of the year and the number of employees at year end (by gender, age 
group and geographic location).
TERMINATION RATES 
AND NUMBERS76 
2022
2021
2020
Number
Rate
Number
Rate
Number
Rate
BY GENDER
Men 
47
6%
24
3%
19
3%
Women
23
4%
18
3%
17
3%
Total
70
5%
42
3%
36
3%
BY AGE GROUP
≤ 30
44
24%
27
15%
14
7%
31-50
22
2%
13
1%
22
2%
>50
4
2%
2
1%
-
-
Total
70
5%
42
3%
36
3%
BY GEOGRAPHICAL AREA
Italy - Milan
51
5%
30
3%
26
3%
Italy - Reggio Emilia
5
2%
6
2%
6
2%
Ireland
14
25%
6
14%
4
11%
Total
70
5%
42
3%
36
3%

116
financial advisors with assets under management ex­
ceeding €20 mln accounted for 58% of the Network 
as at 31 December 2022, with 86.5% of the assets 
under management, representing a low level of con­
centration.747576
The FinecoBank Personal Financial Advisor Net­
work, the third largest77 in Italy in terms of assets 
under management, is organised on three levels 
in ascending hierarchical order: Personal Financial 
Advisor (PFA), Group Manager and Area Manager. 
PFAs represent the base of the pyramid and are the 
people almost exclusively responsible for the cus­
tomer management; Group Managers are the in­
termediate role in the Network, who, in addition to 
managing customers, also have the managerial task 
of coordinating the advisors within a particular local 
area. Lastly, Area Managers are the most senior role 
in the Network and are mainly dedicated to promot­
ing business development and coordinating staff in 
	
	
the geographical areas assigned to them. In addition 
to this three-tier organisation of the Network, in 2022 
the Bank set up an Ambassador Club, made up key 
people selected from the leading advisors in private 
banking, with testimonials of their professional ca­
pabilities and a solid reputation. The initiative was 
prompted by the need for dialogue with the Bank’s 
top management on key issues, such as involvement 
in strategic, operational and business decisions and 
in the design of new products and services; the dis­
cussion on the evolution of the organisation of the 
work of the private bankers and how they serve their 
customers; the design and testing of communica­
tions, marketing and initiatives for developing private 
customer base. There were 26 Ambassadors as at 
31 December 2022.
In 2022, there was significant net growth in the Net­
work with 128 net arrivals, reflecting the appreciation 
of the model and the very healthy environment.  
Number of 
personal financial 
advisors by role
2022
2021
2020
Men
Women
Total
Men
Women
Total
Men
Women
Total
BY GENDER
Area Manager 
26
-
26
26
-
26
26
-
26
Group Manager
173
9
182
168
9
177
170
8
178
Other PFAs
2,201
509
2,710
2,111
476
2,587
1,964
438
2,402
Total
2,400
518
2,918
2,305
485
2,790
2,160
446
2,606
BY AGE GROUP
≤30
31-50
>50
≤30
31-50
>50
≤30
31-50
>50
Area Manager 
-
3
23
-
5
21
-
7
19
Group Manager
-
53
129
-
65
112
-
75
102
Other PFAs
210
1,133
1,367
189
1,125
1,273
109
1,116
1,178
Total
210
1,189
1,519
189
1,195
1,406
109
1,198
1,299
Organic growth, through the acquisition of new cus­
tomers, new assets and the enhancement of exist­
ing relationships by the Network, continues to be 
the main driver for the development of the Bank’s 
business. In 2022, total net sales through the per­
sonal financial advisor network reached €7.3 billion. 
Although some slowdown in investment operations 
can be seen, the significant inflow of funds is a sign 
of customer confidence and a foundation for future 
enhancement. 
77	  Source: Assoreti, September 2022.

117
Three are main drivers underpinning the results 
achieved: (i) the high level of customer satisfaction, 
which continues to be the main generator for the 
acquisition of new customers, (ii) the quality of the 
products and services offered, and (iii) the progres­
sive increase in the Network’s productivity, support­
ed by the continuous updating and use of digital 
platforms. Consistent with the natural and intrinsic 
drive for growth, over 50% of total net sales came 
from newly acquired customers, connected to the 
opening of over 55,000 current accounts during the 
year. 
With regard to the recruitment of new personal fi­
nancial advisors, the priority objective for 2022 was 
once again to improve the quality of the network, fo­
cusing the selection on qualified professionals with 
solid experience. The Group seeks to attract pro­
fessionals who share the Group’s vision and values: 
transparency in customer relationship management, 
ability to use technology intelligently, desire for pro­
fessional growth and drive to meet market challeng­
es. The new employees are provided: i) specific and 
thorough onboarding, for a period sufficient to ob­
tain full knowledge of the Fineco world; and ii) full, 
independent operational activation. Particular atten­
tion is paid to the financial package, which consists 
of the two components of initial premium and on­
going remuneration, with a high degree of flexibility 
and personalisation. 
Another fundamental pillar for growth is the Bank’s 
investment in junior talent, necessary to promote 
generational change in the network and update 
the working methods and professional culture. 
Candidates are selected through partnerships with 
universities, smart monitoring of social and digital 
communication channels and targeted use of more 
traditional channels. The Bank also provides training 
support, ranging from preparation for the qualifica­
tion exam through to the end of the fourth year of 
work within the Network, financial support through 
a “package”, able to maintain the new recruit for the 
first 36 months of work, which represents the most 
critical period for building economic sustainability in 
this profession, and operational support provided by 
a dedicated trainer.
Taking into account senior advisors and young be­
ginners, 214 new advisors joined the Network. Also 
worth noting is the low turnover of the Network in 
this period (3.1%), largely consisting of retirements.
New arrival (2022)
Women
Men
Total
Beginner
30
98
128
Senior
20
66
86
Total
50
164
214

118
DIVERSITY AND INCLUSION
OUR EMPLOYEES
Fineco aims to support the wellbeing and protect 
the people it comes into contact with through its 
business activities and on whom it can generate a 
positive or negative impact. Accordingly, the Group 
is constantly striving to make the most of the talents, 
skills, experience and diverse cultural backgrounds 
of a diverse organisation, in which people feel re­
spected and appreciated and can express their 
potential, by adopting an approach to diversity that 
takes into account the different needs expressed by 
customers, employees and communities. 
In recognition of this, a Diversity Manager has been 
appointed within the Bank to act as a focal point for 
diversity-related activities and initiatives. 
As also stated in the Code of Ethics, diversity of gen­
der, thought, experience and skills represents a form 
of value that enhances Fineco’s professionalism, not 
to mention a source of strength to be harnessed as 
a source of new ideas. The addressees of the Integ­
rity Charter and Code of Conduct are called upon 
to promote an environment based on equal oppor­
tunities, to treat others with dignity and respect, and 
under no circumstances discriminate or tolerate any 
sort of discrimination or harassment. The Global 
Policy on Gender Equality sets out principles and 
guidelines for ensuring a level playing field in which 
all employees, regardless of gender, can realise 
their full potential and for creating a gender-bal­
anced leadership pipeline in which the contributions 
of both genders are equally valued in decision-mak­
ing processes, at all levels of the organisation. The 
Group has also issued the Combating Harassment, 
Sexually Inappropriate Behaviour and Bullying 
Global Policy, reflecting the commitment to support­
ing a happy working environment free of all forms 
of harassment, sexually inappropriate behaviour and 
bullying. Lastly, the Human Rights Commitment es­
tablishes that there will be no tolerance of any dis­
crimination based on age, race, nationality, ethnicity, 
citizenship, political opinions, religion, marital status, 
gender, sexual orientation, sexual identity, disabili­
ty, personal characteristics and experiences or any 
other aspect that might distinguish an individual 
over the course of his or her life, such as personal or 
corporate culture, the type of employment contract 
they have, their professional role or their hierarchi­
cal position within the organisation. No incidents of 
discrimination in the workplace were brought to the 
attention of the Group in 2022.
The Fineco Group is also committed to gender 
neutrality in terms of remuneration. In particular, the 
Board of Directors, with the support of the Remuner­
ation Committee, oversees the gender neutrality of 
policies, monitoring the gender pay gap defined, as 
the ratio of the average remuneration of the most 
represented gender to the average remuneration of 
the least represented gender, and its evolution over 
time. In addition, the equity pay gap is also calculat­
ed, which enables assessment based on equal pay 
for equal work, taking into account the organisation­
al complexity of the roles and the uniformity of the 
professional skills. Analyses performed showed that 
there was no significant gender pay gap within Fi­
neco. Management is made responsible for gender 
neutrality in remuneration systems. Indeed, in 2022, 
the ESG objective of “Stakeholder Value”, which in­
cludes, among others, the KPI “Y/Y delta on Gender 
Pay Gap and Gender Balance”, was again included 
in the performance evaluation forms for the Group 
CEO and the other Identified Staff.
7.2.

119
According to the GRI 405-2 standard methodolo­
gy, the ratio of women’s to men’s basic salaries78 in 
2022 totalled 80% for executives, 99% for managers 
and 102% for professional employees, while in 2021 
the figures were 87%, 96% and 101% respectively. 
The ratio of women’s to men’s total remuneration79 in 
2022 totalled 62% for executives, 98% for managers 
and 102% for professional employees, while in 2021 
the figures were 71%, 95% and 101% respectively. 
Since 2019, FinecoBank has annually signed the 
association agreement with Valore D, promoting 
access to new training courses and the sharing of 
best practices with other member companies. Fur­
thermore, also since 2019, Fineco has decided to 
use Valore D’s Inclusion Impact Index methodolo­
gy to map its diversity and inclusion policies in an 
integrated manner and gauge their actual organisa­
tional impact with the aim of identifying not only its 
strengths but above all those areas in which it should 
continue to invest in the future. In 2022 Fineco took 
part as a supporter in the “D&I in Finance” event 
promoted by the Italian Banking Association. This 
is a key annual event for banks and professionals in 
the financial world to reflect on the importance of the 
socio-cultural transformations taking place, national­
ly and internationally, in relation to diversity, inclusion 
and accessibility.
Fineco is also committed to the management and 
continuous monitoring of employees returning from 
maternity and paternity leave. In this regard, in 
keeping with the previous years, an analysis was 
78	The basic salary is understood as the Gross Annual Salary (GAS). Due to the specific nature of the role assigned to the CEO, the calculation does not include the CEO’s basic 
salary. The information reported states that there were 42 executives in 2022, so changes in the individual pay structure may lead to significant variations in the gender ratio.
79 Total remuneration is understood as the GAS combined with any additional amounts paid, such as bonuses, benefits, overtime and daily rates. Due to the specific nature 
of the role assigned to the CEO, the calculation does not include the CEO’s total remuneration. The information reported states that there were 42 executives in 2022, so 
changes in the individual pay structure may lead to significant variations in the gender ratio.
80 The data on the award of bonuses and promos refer solely to the staff eligible for an evaluation (232).
carried in relation to three themes, which revealed 
that out of the total of 23 people returning from leave 
in 2022:
·	 Position and role: 100% went back to the same 
role as before the period of absence, including in 
the case of positions of responsibility;
·	 Flexibility: 87% returned full-time without request­
ing any kind of flexibility, whilst 13% requested a 
change to more flexible working hours; all requests 
were granted;
·	 Promotions80: around 80% received a promotion 
or salary increase or a bonus during the period of 
maternity leave.
Lastly, the Group is constantly committed to sup­
porting people from protected groups, which, as at 
31 December 2022, came to a total of 55, of which 7 
were middle managers and 48 were office workers. 
In this context, in 2022 Fineco participated in three 
events aimed at promoting diversity management 
and the employment of people with disabilities and 
from protected groups: (i) Diversity Day in-person 
event organised at the University of Milano-Bicocca 
in partnership with private companies, universities, 
public institutions, the media and communities; (ii) 
Digital Inclusion Job Day; and (iii) Digital Diversity 
Day E-campus. In addition, the collaboration contin­
ued with Jobmetoo, an online recruiting company 
that matches companies with candidates from pro­
tected groups, offering the opportunity to participate 
in workshops on the management and empower­
ment of staff with disabilities.

120
OUR PERSONAL FINANCIAL ADVISORS  
81	  Source: Supervisory Board and Register of Personal Financial Advisors - 2021 Annual Report.
Fineco adopts policies that also ensure gender 
equality within the personal financial advisor net­
work. This means that the parameters for defining 
objectives, assessments, remuneration and rewards 
for advisors are based on the principles of meritoc­
racy and objectivity, and are independent of gender, 
as they refer exclusively to qualitative and quantita­
tive factors linked to the performance achieved.
As confirmation of this, the Integrity Charter and 
Code of Conduct Policy, also aimed at the per­
sonal financial advisors, promotes an environment 
based on equal opportunities, dignity and respect, 
and the addressees of the Policy are not permitted 
under any circumstances to engage in or tolerate 
discrimination or harassment. Specifically, the per­
sonal financial advisors are also required to respect 
the principles of civil liberties and reject all forms of 
discrimination, to be replaced by the fundamental 
importance of assessing each individual’s skills and 
abilities, and backed up by a specific commitment 
to nurturing and integrating the people who join the 
Group.
In absolute terms, 17.8% of the Network is made 
up of women, compared to an average in the na­
tional Networks of 22.1%81. In this regard, it is worth 
noting that the profession of personal financial ad­
visor has a strong technical and relational content, 
and the legacies of the past – even though mistaken 
and disproved by more recent evidence – have al­
ways led to the belief that men are more suited to 
the profession. On the contrary, Fineco believes that 
the daily organisational needs of women, including 
mothers, are highly compatible with the organisa­
tional flexibility afforded by the work of a personal 
financial advisor. From this perspective, this flexibility 
could be considered an implicit benefit, facilitating 
a more efficient work-life balance. This is why, for 
some years now Fineco has been seeing a change 
in trend and the percentage of women in this pro­
fession, although still low, is increasing significantly.
For years, the Bank has focused on and believed in 
its Youth Project aimed at supporting those entering 
the profession. Here, female participation is higher, 
showing that there is a greater willingness to embark 
on this career path in the younger generation.
Lastly, Fineco provides support measures for PFAs 
on maternity leave, including, for example, the pos­
sibility of temporarily transferring management of 
their customer portfolios to colleagues operating in 
the vicinity, while retaining a part of the fees.

121
PROMOTING AND DEVELOPING HUMAN RESOURCES
OUR EMPLOYEES
Developing human resources is a strategic factor 
for Fineco and, for this reason, appropriate training 
plans and programmes designed to develop the in­
dividual’s skills and capabilities are encouraged.
In 2022, training focused both on acquiring and con­
solidating the skills required by the various corpo­
rate needs, and on updating individual knowledge, 
with a focus on compulsory, technical, linguistic and 
behavioural-managerial training. In line with the pre­
vious years, the courses were mainly conducted in 
synchronous and asynchronous e-learning mode, 
with the support of external training companies or 
internal staff. 
In 2022, Fineco delivered over 45,400 hours of 
training involving all employees, equating to an av­
erage of over 34 hours of training per person.
Fineco is constantly committed to disseminating 
and improving its risk and compliance culture. Ac­
cordingly, in 2022 the Group again gave special 
attention to compulsory training for all employees, 
which includes learning tests and periodic monitor­
ing. The completion of compulsory training is also 
a requirement for access to the annual incentive 
scheme. Some of the topics covered were: Bank 
Compounding, Conflict of Interest, Market Abuse, 
Financial Sanctions, Anti-Money Laundering and 
Anti-Terrorism. Within the units responsible for pro­
viding information to customers, compulsory IVASS 
insurance training, professional refresher courses 
for the purposes of CONSOB regulations and annual 
skills assessment on the subjects identified by ESMA 
were also provided.
In order to ensure compliance with occupation­
al health and safety regulations, Fineco provides 
appropriate training, information and instruction on 
a regular and continuous basis to all the staff con­
cerned on the basis of current regulations.
The following new compulsory courses were also 
released during the year:
·	 “Training course for Smart Workers”, aimed at sup­
porting employees in managing remote work, with 
a specific focus on regulations and safety.
·	 “Sustainability: commitments and initiatives at Fine­
co”, to illustrate how the key themes of Sustainabil­
ity and Sustainable Finance underpin the Group’s 
strategy and operations, encouraging virtuous en­
vironmental and social behaviour.
·	 “Cybersecurity”, to increase knowledge and 
awareness of possible cyber threats and the ability 
to react appropriately.
To emphasise the importance of this last aspect, Fi­
neco has chosen to support the CertFin consortium 
in the information campaign “I Navigati - Informati e 
sicuri” designed to promote the safe and informed 
use of digital channels for financial services, by pro­
viding training modules on the different types of cy­
ber attacks.
To improve business development and enhance 
employee specialisation, training sessions were 
organised on technical and behavioural skills, in col­
laboration with specialist internal trainers, external 
suppliers, strategic partners and universities.
A great deal of importance is also given to on-the-
job training, which are extremely useful when it 
comes to ensuring that employees receive concrete, 
practical and effective training. This method of train­
ing is used in particular in customer care and a total 
of 13,487 hours of training was provided to new em­
ployees.
The catalogue of online courses freely accessible 
by all employees, for the development of profes­
sional, managerial but also personal skills, has been 
continuously expanded. The topics covered include 
communication, leadership, motivation, and exe­
cution & organisation. The catalogue also includes 
7.3.

122
courses on ethics, diversity & inclusion and stress 
management.
During the year, following the migration of the IT 
systems used by the entire Bank, a course was made 
available to employees offering a general overview 
of the new features of Microsoft 365. Training cours­
es on Project Management were also launched, 
aimed at teaching the basic principles and develop­
ing a project management-oriented mindset through 
practical training and a structured approach. In ad­
dition, training modules were provided to managers 
to support them in their role, focused on managing 
their teams in hybrid working mode.
For the non-compulsory training, a dedicated survey 
is usually conducted and completed to monitor both 
satisfaction and effectiveness.
Through the collaboration with Valore D, in 2022 
Fineco took part in a number of training initiatives 
specifically designed to promote diversity and inclu­
sion in the company, covering topics such as uncon­
scious stereotyping, inclusive language, working in 
diverse teams, empowering staff, and gender and 
sexual harassment in the workplace.
Lastly, with regard to language training, in 2022 all 
employees had the opportunity to use a dedicated 
platform, based on artificial intelligence, aimed at 
enhancing their English language skills through a 
personalised learning path based on their initial lev­
el of knowledge and interests. In addition, the usual 
group and individual training courses were carried 
out for over 300 employees by telephone or in virtu­
al classrooms. Courses in legal English and German 
were provided for specific staff. The progress for this 
type of training is monitored by analysing levels of 
knowledge.
2022
2021
2020
AVERAGE HOURS 
OF TRAINING PER CAPITA
BY GENDER
34.1
31.4
33.3
Men
37.0
34.2
35.4
Women
30.1
27.5
30.4
BY EMPLOYEE CATEGORY
34.1
31.4
33.3
Executives
43.0
41.2
30.1
Managers
26.7
26.5
28.3
Professionals
37.7
33.5
36.0
TOTAL TRAINING HOURS
BY TRAINING AREA
Technical
17,881
13,207
13,651
Linguistic
4,121
4,917
11,319
Mandatory
22,075
21,410
16,569
Behavioural
1,411
1,418
444
Total
45,488
40,952
41,983

123
All Group employees undergo an annual perfor­
mance evaluation by their respective managers that 
not only takes into account performance and results 
linked to specific and common objectives but also 
identifies future opportunities for learning and de­
velopment. The Performance Management tool re­
sponds to the need to make the assessment objec­
tive and identify the behaviour expected to achieve 
results. This assessment process consists of several 
stages.
 
  
  
 
  
  
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Performance 
Management
Based on five possible 
levels of performance 
and three level of potential.
The combination of these two 
variables indentifies
the individual’s position within 
the evolution matrix.
During which 
an individual development 
plan will be individual 
a pathway of growth 
to follow
  
 
  
  
 
  
  
 
  
  
  
  
  
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The process therefore comprises two official discus­
sion sessions between the assessor and the person 
being assessed, one during the assignment of ob­
jectives and the second during the feedback phase, 
with the aim of developing talent and increasing 
employee engagement. To this end, Executives 
and Talents are assessed not only based on perfor­
mance levels, but also on 3 levels of potential (from 
potential reached to high potential). The pathways 
for Senior Managers are designed to support them 
in successfully dealing with the changes and chal­
lenges of the current environment, to develop new 
methods of strategic thinking needed to manage 
complex situations based on a mindset of sustain­
able growth for the organisation and its team. The 
pathways for female Middle Managers are de­
signed to help develop more advanced profession­
al skills, in addition to acquiring the necessary tools 
82	The most recent data available is for the 2021 assessment year, as the performance review takes place at the beginning of the year following the year of assessment. 
Therefore, the percentage of employees who have undergone an evaluation of their annual performance for 2022 will be available after this document has been published.
for the development of a sustainable career. More­
over, with regard to young talents in the company 
in particular, in order to support them in the early 
stages of their professional growth, pathways were 
identified designed to increase self-awareness and 
self-knowledge and to enhance relations with others 
and within the organisation. 
The annual review provides an opportunity to plan, 
identify and manage career and succession plans 
in line with the performance and expectations of 
those concerned and identify activities to support 
the development of sustainable leadership. In 2021, 
around 97% of employees received an annual per­
formance evaluation using the Performance Man­
agement tool82.
The compensation and salary review process, for its 
part, is closely linked to the performance evaluation

124
system. The head of each unit proposes a promotion 
and/or pay rise for their staff, which is analysed by 
the Chief People Officer Department in accordance 
with the principles of fairness, transparency and con­
sistency and through a careful and accurate Pay for 
Performance analysis, which looks at the consistency 
between the distribution of individual performance 
evaluations for the year and the relative average bo­
nus paid. This analysis is presented annually to the 
Remuneration Committee.
OUR PERSONAL FINANCIAL ADVISORS
Training has always been one of the main building 
blocks to support the company’s growth and guide it 
towards its business goals. Such growth can only be 
achieved if the advisors are able to grow, cultivate 
and express their full potential as professionals and 
be recognised as such. Fineco is therefore constant­
ly committed to implementing training plans aimed 
at developing the advisors as professionals and as 
businesses, with a strong focus on managerial train­
ing and on the private banking segment.
For years, Fineco has provided a training course 
dedicated to new arrivals with a senior profile called 
“welcome senior”, which consists of 5 training ses­
sions on the products and services offered by the 
Bank to its Network. In 2022, a new session on pen­
sion funds was added to this course, as Fineco’s 
pension offering continuously being updated with 
new implementations and features. Solely for the 
advisors originating from the bank, the course also 
includes a session on their new role, enabling them 
to develop the all-important role awareness that 
characterises a Fineco advisor.
The series of sessions entitled “Current Scenario 
and Managing Emotions”, includes a series of web 
conferences with academics and industry profes­
sionals to support the advisors with new insights into 
the emotional management of customers in this diffi­
cult time of international tensions. 
In continuation from the previous year, in 2022 an­
other step forward was made in the programme of 
supporting the managers in the Network with the 
structuring of decision-making teamwork, a method 
for effectively conducting meetings and gatherings, 
focusing attention on the phases that make up the 
meeting and creating the right climate of proactive 
collaboration between the participants and engage­
ment for the decisions taken. 
At the end of the training sessions, the participants 
are given a survey to collect feedback on the con­
tent and methods of delivery in order to continue to 
improve the process.
A total of over 235,000 hours of training were pro­
vided in 2022 (approximately 80 hours per personal 
financial advisor) against over 215,000 hours in 2021 
(approximately 77 hours per personal financial advi­
sor), including: 
·	 132,136 hours of training on mandatory topics;
·	 80,531 hours of training on Fineco product-related 
issues;
·	 5,059 hours of highly specialised training for the 
Private Banking PFAs through a dedicated course;
·	 videos, media, web conferences, webinars and 
dedicated sessions; 
·	 an e-learning platform dedicated to detailed study 
and the provision of classroom materials; 
·	 highly qualified trainers and leading figures from 
the financial and academic spheres.
Training on mandatory topics, continues to be a key 
element for strengthening the risk and compliance 
culture. Indeed, again in 2022, the training offering 
for all the personal financial advisors was updated 
and personalised with targeted content, and the re­
sults were monitored to ensure that the subjects had 
been mastered. The focus was on providing cours­
es aimed at compliance with and knowledge of the 
applicable regulations and the products in the port­
folio, particularly insurance products. In the regulato­
ry sphere, training sessions were organised on the 
subject of anti-money laundering, delivered in virtual 
classrooms directly by the Compliance Department,

125
mainly aimed at the new PFAs that arrived during the 
year, with a specific focus on operational aspects 
and practical cases. 
Special attention has also been maintained on the 
subjects of possessing and maintaining the knowl­
edge and skills required of the personal financial 
advisor network. Indeed, to comply with the require­
ments of the regulations on the review of develop­
ment and training needs, in 2022 a specific Knowl­
edge and Skills Assessment was again made 
available to the entire Network. Any skills gaps iden­
tified by the assessment were filled through specific 
online training courses. 
The 30-hour training course validated for CONSOB, 
IVASS and EFPA purposes on specific topics also 
continued, together with the 60-hour training course 
for personal financial advisors who were not yet reg­
istered with the Register of Insurance Intermediaries 
(IVASS), as envisaged by the related IVASS Regula­
tion.
Lastly, the following new mandatory courses of stra­
tegic importance for Fineco were launched in 2022:
·	 “Sustainability: commitments and initiatives at Fine­
co”, to illustrate how the key themes of Sustainabil­
ity and Sustainable Finance underpin the Group’s 
strategy and operations, encouraging virtuous en­
vironmental and social behaviour; 
·	 “Sustainability: from the latest regulatory provisions 
to the integration of ESG drivers into the adequacy 
assessment”, aimed at exploring the issue from a 
legal perspective and promoting appropriate be­
haviour towards customers interested in sustaina­
bility-related investments; 
·	 “Cybersecurity”, to increase knowledge and 
awareness of possible cyber threats and the ability 
to react to them appropriately.
To assess the effectiveness of the training provided, 
each mandatory course includes a final knowledge 
assessment test, which must be passed at the end 
of the course. Participation in the mandatory cours­
es is also periodically and continuously monitored 
and, under certain conditions, the personal financial 
advisors who have done so are reported to Fineco’s 
internal control bodies.
In relation ESG, which is now a shared and priority 
objective for many of the personal financial advisors 
in line with the greater market awareness of this is­
sue, since July 2021 Fineco has supported the EFPA 
ESG Advisor certification for its personal financial 
advisors. This is the European certification of a con­
tinuous and permanent professional training pro­
cess and includes a compulsory preparatory course 
for registration for the exam organised by EFPA. Ob­
taining the certification is optional for the individual 
personal financial advisors, however, with the aim 
of offering an incentive to the Network, the Bank 
provides a one-off contribution to the advisors who 
obtain the certification. As at 31 December 2022, a 
total of 225 Fineco personal financial advisors had 
obtained EFPA ESG Advisor certification.
In 2022, Fineco continued its investment and focus 
on young personal financial advisors who want 
to enter the profession. In fact, during the year 128 
young advisors were included in the Youth Project, 
which provides training support, in addition to finan­
cial support and the assistance of a tutor, through a 
four-year course, constantly monitored and updated 
in terms of content, for the acquisition of the techni­
cal and behavioural/commercial skills necessary to 
exercise the profession. Specifically, in 2022 a total 
of 70 dedicated courses were delivered, for a total 
of over 10,434 hours of training.

126
2022
2021
2020
AVERAGE HOURS OF TRAINING 
PER CAPITA
BY GENDER
80.8
77.2
65.8
Men
80.0
77.2
65.5
Women
85.0
77.5
67.6
BY ROLE
80.8
77.2
65.8
Area Manager
85.4
136.1
79.8
Group Manager
85.4
108.7
75.8
Other PFAs
80.5
74.0
65.0
TOTAL TRAINING HOURS
BY TRAINING AREA
MANDATORY
132,136
136,929
109,066
ESG
20,395
15,552
-
Compliance 
27,427
45,278
17,361
Product insurance issues 
9,329
4,381
12,031
IVASS/CONSOB maintenance 
65,865
61,578
74,994
New IVASS registrations 
9,120
10,140
4,680
BUSINESS AND YOUTH PROJECT
103,780
78,577
62,515
ESG
-
4,252
-
Products
80,531
50,680
46,173
Technical
10,854
7,546
2,338
Behavioural 
12,395
16,099
14,004
Total
235,916
215,506
171,581
With regard to performance evaluation for the PFA 
Network, a set of tools to support the management 
of the network has been developed by the Network 
and Private Banking Sales Department. Specifically:
·	 internal reporting and analysis which periodically 
summarises data on sales and measure deviations 
from assigned budgets and desired targets;
·	 benchmarking with main competitors based on re-
ports provided by trade associations (ASSORETI, 
ASSOGESTIONI and AIPB) and/or studies by bro-
kerage houses on listed peers;
·	 regular meetings with management departments 
to compare results and identify specific initiatives 
and actions designed to enhance performance;
·	 monitoring of operational anomalies, in collabo-
ration with the designated Departments, with in-
tervention by the units supporting the work of the 
network’s management units.

127
7.4.	 WELFARE AND INDUSTRIAL RELATIONS
OUR EMPLOYEES
83	 All the leave indicated is paid except for introducing children to daycare and/or nursery school and children’s illness.
Also in 2022, the process of close collaboration with 
social partners continued, to address issues of rel­
evance to the entire company population. In March 
2022, the new Agreement regulating agile work 
in the post-emergency period was signed with the 
trade unions, which is considered an important tool 
in achieving work-life balance. The new Agreement, 
valid until 31 December 2023, introduces significant 
changes and more favourable conditions with re­
spect to the provisions of the national collective bar­
gaining agreement for the sector, including: 
·	 the possibility of working remotely for 12 days a month; 
·	 the provision of meal vouchers also for days 
worked remotely; 
·	 additional flexibility for certain categories of work­
ers such as pregnant women and shift workers. 
In addition, in light of the recent national plan to curb 
energy consumption and the current economic en­
vironment, a temporary trade union agreement was 
signed on 20 October 2022 that envisages – in the 
period from 31 October 2022 to 31 March 2023 – re­
mote working on Mondays and Fridays and, with the 
aim of ensuring greater flexibility, raising the monthly 
limit of agile working days to 14 days (for shift work­
ers the number of days has been raised to 16). These 
solutions will reduce consumption by changing the 
scheduling of energy services (heating and electric­
ity) in the company offices and achieve environmen­
tal benefits related to the reduction of greenhouse 
gas emissions.
The work of the Joint Commission on work-life bal­
ance, innovation and welfare also continues. The 
Company and the Trade Union, as part of the work 
of the Commission, intend to continue promoting the 
company’s welfare system to increase the wellbeing 
of its staff and their families, introducing measures 
and solutions to improve the company atmosphere, 
which is the reason why the Welfare System is con­
tinuously being evolved and enhanced. In particular, 
the Commission met four times over the course of the 
year with the aim of developing and improving servic­
es and initiatives relating to four themed macro areas: 
(i) Savings: pension funds, mortgages, loans, financial 
support at preferential rates, and welfare accounts; 
(ii) Family: contributions for families with children and 
support for elderly and disabled family members; (iii) 
work-life balance: home working, flexible working 
hours, part-time hours, leave of absence and sab­
batical years; (iv) Health: supplementary healthcare, 
insurance cover and prevention campaigns.
The initiatives relating to parenting, organisational 
flexibility and staff welfare promoted within the In­
novation Plan, the second-level agreement aimed 
at introducing and promoting tools to facilitate work-
life balance, have been confirmed until 31 December 
2023. In particular, the possibility of taking leave for 
key life events (children’s wedding, bereavement for 
relatives up to the second degree, children’s grad­
uation, moving house, buying of a first home), for 
childcare, for carrying out voluntary work, for intro­
ducing children to daycare and/or nursery school, 
for children’s illness, for disabled family care and 
for quarantine and suspension of in-person educa­
tion has been maintained83. The flexibility granted to 
working parents in the use of daily leave to care for 
children in their first year of life has also been main­
tained, with the granting of additional leave allowing 
them to accumulate so-called breastfeeding leave in 
the afternoon and to work up to the morning break. 
The company benefits in the form of financial contri­
butions for employees with children aged between 
4 and 12, the Christmas gift for employees with chil­
dren aged between 0 and 12 and the disabled family 
contribution also continue to be provided. 
Finally, as further confirmation of Fineco’s constant fo­
cus on the wellbeing and satisfaction of its staff, and

128
in the light of the current economic climate, Fineco 
has decided to provide additional support in the form 
of extraordinary welfare payments for the purchase 
of goods and services through the Welfare Platform. 
The communication campaign dedicated to the Wel­
fare Plan continues. Digital information corners 
have been created where employees were able to 
request more information on the services available. 
The renovation of the workspaces at the Milan of­
fice continued, helping to achieve the Group’s aim of 
creating a better workplace for its people.
Confirming its commitment to promoting the health 
of its employees, Fineco extended and increased 
the range of services at the time of the three-year 
(2022-2024) renewal of its Health Insurance Plans, 
also through discussions with the trade union rep­
resentatives. The revised health insurance policy 
provided for the raising of the out-of-pocket maxi­
mums for many benefits and the introduction of new 
protection cases. The Employee Benefits were also 
confirmed with the following policies: life, permanent 
disability, car work-related and personal use, and ac­
cident insurance. 
The remote medical assistance service (telemedi­
84	The figure stated refers to the Group’s Italian division (which accounts for 96% of employees), the employment relationships of which, where Professional Areas for Middle 
Managers and Executives are concerned, are regulated by the respective NCBAs for the credit sector. Among other things, this NCBA establishes the minimum number 
of weeks’ notice to be given to employees and their representatives regarding significant changes that could have a considerable effect on them, amounting to 50 days 
(around 7 weeks). As far as FAM is concerned, there are no agreements resulting from collective bargaining.
cine) and home swabs for Covid-related symptoms 
also continued in 2022, alongside the telephone coun­
selling service, aimed at providing specialist support. 
In keeping with FinecoBank’s Remuneration Policy, 
benefits are generally aligned by applying a series 
of common criteria for each employee category, 
whilst the nature of the benefits is established based 
on the Bank’s practices. Benefits that complement 
national social security, healthcare and work-life bal­
ance support systems with the aim of ensuring the 
wellbeing of employees and their families through­
out their working lives and even after retirement, for 
example, are included. Special access conditions 
for various banking products and other FinecoBank 
services are also granted with the aim of providing 
employees with support throughout the stages of 
their lives.
Welfare systems in line with local best practice are 
adopted for Fineco AM employees, which include: 
agile working, a supplementary healthcare plan, 
marriage leave, paid parental leave, and 5 days of 
leave in addition to those provided for by law.
All FinecoBank S.p.A. employees are covered by 
collective bargaining agreements84.
OUR PERSONAL FINANCIAL ADVISORS
The focus on the wellbeing of workers and their fam­
ilies is also equally strong for the personal financial 
advisor network. In line with the roles assigned and 
the portfolios managed, benefits are awarded on the 
basis of uniform criteria and range from the supple­
mentation of national pension and welfare systems, 
to access to the Bank’s products and services at 
special conditions.
A number of benefits of increasing value are award­
ed, based on the role held and the assets managed 
by each personal financial advisor. These benefits 
relate to:
·	 insurance cover for death and permanent disability;
·	 health insurance to cover medical examinations 
and tests, hospitalisation, surgery and specialist 
care;
·	 investment-linked insurance policy (with different 
investment lines to be chosen by the policyholder) 
which provides for a liquidation upon termination 
of the work activity;
·	 car contribution.
The entire network is also offered favourable con­
ditions for current accounts, mortgages, credit facili­
ties and personal loans, in line with that available for 
employees.

129
HEALTH AND SAFETY
85	 For more information, see the section “The Governance System - Sustainability Governance”.
OUR EMPLOYEES
In its efforts to protect the health and safety of its 
people, the Fineco Group is committed to comply­
ing with the regulations, properly assessing risks and 
consequently designing and planning prevention 
and protection measures to minimise those risks, 
as set out in the Human Rights Commitment. The 
Code of Ethics lists the obligations that all those 
bound by it are required to comply with in order to 
ensure safe, healthy and dignified working condi­
tions and healthy working environments, in accord­
ance with the applicable regulations and available 
technology. 
To ensure the health and safety of all employees, 
Fineco AM is committed to complying with local 
regulations, conducting risk assessments and in­
troducing appropriate measures to prevent illness 
and injury and to minimise risks to employees. Fine­
coBank has implemented an effective Health and 
Safety Management System, in line with the reg­
ulatory requirements, coordinated and managed by 
the Prevention and Protection Office, comprising an 
external Prevention and Protection Officer (PPO), an 
external Company Doctor (responsible for coordinat­
ing two other doctors, one in Milan and one in Reg­
gio Emilia), an internal Safety Officer, up to the end 
of November 2022, and two Worker Safety Repre­
sentatives (below WSRs), one for the Milan office and 
one for the Reggio Emilia office. In December 2022, 
new Safety Responsibilities of were assigned and, 
as a result, a new system was developed with three 
“theme-based” Safety Officers85, each with specif­
ic employer responsibilities allocated according to 
their area operation, based on their actual spending, 
organisational, management and control powers. 
The system for the monitoring, management and 
prevention of risks related to the performance of the 
professional activities in place at FinecoBank relates, 
for example, to the presence of electrical systems 
and appliances, the use of video display equipment 
and work-related stress. This management system 
also standardises the methods of engagement of 
the FinecoBank relevant employees and units, im­
plementing the actions related to the application and 
fulfilment of the requirements of Legislative Decree 
81/2008 as amended. The Health and Safety Man­
agement System thus defined applies to all Fineco­
Bank employees. 
Suppliers are also subject to appropriate profes­
sional and technical checks. These include checks 
carried out on insurance cover, collective bargaining 
agreements applied, average annual workforce, so­
cial security compliance, and any suspension orders. 
Where necessary, Fineco and the supplier discuss 
the Interference Risk Assessment Document or the 
Safety and Coordination Plan, where applicable, to 
identify any risks in the environments where the sup­
plier is called upon to operate.
The main occupational health and safety risks, 
along with the corresponding management ap­
proach and mitigation measures, are identified and 
outlined, based on the provisions of Legislative De­
cree 81/2008, as amended, through specific inspec­
tions, and at the PPOs, following which a new Risk 
Assessment Document was produced. These types 
of risk were deemed to be medium-low.
The Real Estate Unit and a specific email address are 
available to workers to report any hazards or risks. 
If workers consider it appropriate not to continue an 
activity that they believe is harmful to them, they can 
report this to the Human Resources officers and Fi­
necoBank will analyse the concerns raised, with the 
aid of the PPO and the Company Doctor. Suppliers, 
on the other hand, can contact the liaison staff of the 
7.5.

130
Real Estate Unit to report dangerous situations, ei­
ther by email or through the dedicated application 
(RefTree).
Fineco also provides its employees with an occu­
pational health service. In particular, the Company 
Doctor carries out an annual inspection of the com­
pany offices to check for any work-related risks, as­
sessing whether changes or improvements need to 
be made to the work environment or the equipment 
used. This process includes company medical exam­
inations, as required by Legislative Decree 81/2008 
as amended, whose type and frequency is defined 
according to the activities carried out by each work­
er and in relation to their age. 
As envisaged by Legislative Decree 81/2008, the 
two Worker Safety Representatives (WSRs), appoint­
ed from among the trade union representatives and 
who represent all the Group employees working in 
Italy, participate in specific activities such as safety 
meetings, inspections and the drafting of documents. 
To maintain the high level of attention to issues relat­
ed to workers’ health and safety, the Work-Related 
Stress Assessment was updated in 2022. To mitigate 
the effects of stress, the Company has put in place: 
·	 preventive treatments, contractual arrangements 
and company initiatives that promote physical, 
mental and social wellbeing within the organisa­
tion;
·	 restorative measures, helpful in mitigating new or 
possible stress conditions that may also originate 
from outside the work environment;
·	 alleviating measures to mitigate any issues identi­
fied during the Assessment. 
In addition, the regular updating and monitoring of 
data related to workloads and work rhythms con­
tinues, also in order to assess the possible imple­
mentation of improvement measures.
Lastly, a structured process for analysing occupa­
tional accidents has been put in place, which pro­
vides for immediate verification of incidents, with the 
involvement of the INPS (National Social Security In­
stitute) in the event of serious accidents. The process 
also includes an annual review of the risks, in col­
laboration with the WSRs, Company Doctor, 81/2008 
Representative and the PPO. There have been no 
work-related injuries or occupational illnesses in the 
last three years.
OUR PERSONAL FINANCIAL ADVISORS
Although FinecoBank does not have any specific 
health and safety obligations towards its Personal 
Financial Advisors as imposed by Legislative Decree 
no. 81/2008, as amended, the Bank has nevertheless 
adopted a number of measures for the prevention 
of risks present in the Corporate Fineco Centers, 
i.e. offices with leases in the name of the Bank.
Personal financial advisors working within build­
ings managed by FinecoBank receive appropriate 
training on health and safety. In addition, the Bank 
has decided to carry out specific inspections in the 
Corporate Fineco Centers, to check that the prem­
ises and equipment comply with current health and 
safety regulations, accompanied by training for the 
managers of the financial shops, to properly instruct 
them on how to maintain and run the Fineco Centers, 
in compliance with the provisions of Legislative De­
cree 81/2008. 
 The personal financial advisors working in buildings 
managed by FinecoBank can report any risks by 
contacting the real estate unit directly through the 
dedicated application (RefTree).

131

132
08

133
133
THE COMMUNITY
8.1. 	
FINANCIAL EDUCATION
8.2. 	
COMMUNITY SUPPORT

134
8.
8.1.	 
THE COMMUNITY
86	 https://www.fineconomy.it/: Information and financial education blog on topics related to savings.
FINANCIAL EDUCATION
In line with the previous year, in 2022 FinecoBank 
continued to strengthen its financial education ac­
tivities, engaging both customers and prospects in 
these initiatives. The main objective of these has re­
mained to increase awareness and knowledge of 
the way in which the financial markets function, 
and of the best and most appropriate use of finan­
cial instruments in order to better manage their as­
sets. 
The aim of the financial education offered by Fine­
co is to provide all the participants more in-depth 
knowledge of all the topics covered. To this end, a 
number of mini-surveys were introduced during the 
web sessions to check the level of understanding of 
the most relevant aspects, and at the end of the in­
dividual webinars, the comments made via chat are 
reviewed and a number of mini-surveys are carried 
out on the level of enjoyment of the event, in order 
to be able to continue improving the quality of what 
is offered. In addition to this, all the interventions pro­
posed by Fineco aim to provide the necessary tools 
to assess, understand and approach markets and 
instruments with full awareness of the risks involved. 
To this end, in 2022 the financial education activi­
ties were divided into two streams. In the first, relat­
ed to assets under administration products, Fineco 
focused on the characteristics and functioning of 
individual financial instruments (from bonds to gov­
ernment bonds to more speculative products), and 
on understanding the market environment in order 
to be able to use them most effectively. Through 
weekly columns and with the help of external and 
internationally renowned lecturers (Trading Titans), 
short-term market dynamics were discussed to gain 
a better understanding of the economic and finan­
cial aspects involved. Presentations on topics relat­
ed to operational strategies and risk management 
also played an important role. The second stream 
deals with asset management, in which importance 
is given to the concepts of financial planning, diver­
sification (also over time) of investments and finan­
cial methods, such as the Accumulation Plan (PAC), 
which enable investment in small steps and also with 
modest sums. 
To communicate these concepts in the best possible 
way, different types of content have been created, 
ranging from notions of behavioural finance and sup­
plementary pensions to the organisation of sessions 
running going the pages of Fineconomy86 to better 
explain the long-term market environment and its 
main drivers. 
In addition, in the area of raising awareness among 
savers, during the UN International Days for the 
Protection of the Planet (6-8 June 2022), Fineco or­
ganised two public webinars, in collaboration with 
LifeGate, aimed at exploring the megatrend of sus­
tainability and understanding how this can also be 
supported by investments, through ESG thematic 
funds, in specific sectors such as water, environ­
ment, nature, etc.
Lastly, in 2022 FinecoBank continued to contribute 
with its participation in Edufin’s initiative “Financial 
Education Month” organised by the Committee for 
the planning and coordination of financial education 
activities, with 4 webinars on financial planning and 
supplementary pensions.

135
 
2022
2021
2020
By type of 
delivery [no.]
Sessions
Parteci­
pants
Hours Sessions
Parteci­
pants
Hours Sessions
Parteci­
pants
Hours
Classroom87
-
-
-
-
-
-
22
937
66
Webex
190
30,577
190
309
60,675
309
372
101,734
372
Mini Videos88
190
n.a.
n.a.
349
n.a.
n.a.
261
n.a.
n.a.
Total
380
30,577
190
658
60,675
309
655
102,671
438
2022
2021
2020
Initiatives by target 
topic and participants 
[no.]
Sessions
Partecipants
Sessions
Partecipants
Sessions
Partecipants
Live trading and 
operating ideas
46
8,224
59
9,796
46
13,701
Trading courses
70
10,720
109
19,535
208
49,584
Operating strategies
30
4,448
65
12,474
71
23,500
Investing
37
5,695
71
17,369
43
14,098
Initiatives included in 
Financial Education 
Month and similar
7
1,490
5
1,501
4
851
Total
190
30,577
309
60,675
372
101,734
87	 In 2021 and 2022, the in-Classroom sessions were suspended due to the pandemic. 
88	 Data on the number of participants and training hours are not available as the use of the Mini Videos on the platform does not provide a breakdown over the different years.
The resumption of in-person customer events (start­
ing in March) encouraged a return to normal cus­
tomer and prospect contact activities, with physical 
events organised by Group and Area Managers. At 
the same time, digital continues to be a widely used 
channel, especially for certain types of events that 
are able to involve far more participants than the 
same initiatives in person. 
In 2022, market volatility offered an opportunity to 
bring the topic of financial planning and its key as­
pects back to the forefront. Also, it was possible to 
make more frequent use of qualified external speak­
ers able to offer customers specialist insights. In line 
with previous years, a total of 1,432 events were held 
in 2022, with the participation of almost 62,300 cus­
tomers and prospects.
There continues to be a strong commitment to rais­
ing awareness of the broader issue of asset plan­
ning for some years now. To this end, events are or­
ganised for high-end customers. The aim is to raise 
awareness among the advisors and customers of 
the need for proper management of all their assets 
and their effective transmission to future genera­
tions. The meetings of this type (52 during the year, 
involving around 4,400 private banking customers) 
are held by the Private Banking Advisory team (and, 
in some cases, by accredited external professionals). 
The digitalisation of the process for the end-to-end 
management of the engagement of customers and 
prospects in events organised by the Network and 
by the Bank for the Network provides a better cus­
tomer experience, as well as enabling a more pre­
cise monitoring of each individual step of the pro­
cess (from invitation, to registration, to post-event), 
while also obviously ensuring the management of 
data privacy consents.

136
COMMUNITY SUPPORT
Since its foundation, FinecoBank has been com­
mitted to supporting effective charitable projects in 
various areas of intervention, including social and 
healthcare, training, education, culture and art, sci­
entific research and environmental protection.
To be approved, projects must be promoted by 
non-profit organisations (NGOs, Foundations, Asso­
ciations, Religious bodies, Universities, Public Institu­
tions), whose activities cover a wide range through­
out the country. The projects supported by Fineco 
are all in Italy. The process of identifying associations 
and approving donations involves a careful selection 
by the Identity & Communications Structure and an 
assessment by the Compliance Department and Tax 
Affairs and Advisory Unit and by the associations 
themselves, by requesting and studying specific 
documentation concerning the association and the 
initiative for which the contribution is being request­
ed. A questionnaire is also submitted to the organ­
isations in order to avoid taking on initiatives that 
would benefit entities involved in acts of corruption.
During the first half of the year, in response to the 
emergency caused by the war in Ukraine, Fineco 
donated a total of €400,000 to the Soleterre and 
AiBi locally based associations providing support 
to the people affected by the conflict. In addition, a 
fundraising campaign was launched via the Fineco 
website, which raised more than €1 million. Fineco 
also supported Fondazione Theodora, through the 
“Pic Nic Solidale” project, an event that has been 
held for several years in Milan to raise funds for the 
activities of the Dottor Sogni, doctors dressed up as 
clowns who provide fun and entertainment to chil­
dren being treated in the paediatrics wards of sever­
al Milanese hospitals.  
The second half of 2022 saw the launch of Fineco’s 
traditional Christmas solidarity campaign, which 
combines a donation from the Bank with custom­
er participation via the company website. Four ar­
eas of intervention were selected, with support to 
projects selected from Associations operating in 
Italy, for a total donation of €120,000. In the cam­
paign, in 2022 Fineco focused on four projects: 
·	 in the fight against economic and educational 
poverty, the Bank contributed to the National Pro­
gramme “Varcare La Soglia”, promoted by the as­
sociation L’Albero della Vita. Running from North 
to South Italy, the programme involves families in 
a programme of social, economic and relational 
reintegration, providing material support and an 
educational project that also includes financial ed­
ucation. 
·	 In the area of social inclusion, Fineco contributed 
to the CESVI project “Le case del sorriso in Italia”, 
protected spaces to combat marginalisation, isola­
tion, educational, emotional and cultural poverty of 
children and families in the most deprived suburbs. 
·	 In the area of environmental sustainability, the 
Bank chose to support Legambiente’s national 
“Mosaico Verde” campaign, aimed at creating new 
green areas and restoring Italy’s forest resources 
in response to the climate and environmental cri­
sis. 
·	 With regard to support for childhood and the treat­
ment of illnesses, Fineco supported Make a Wish 
Italia with the project “Realizziamo sogni che cam­
biano la vita”, it was possible to make the wishes of 
children and young people aged 3 to 17 years with 
serious illnesses from paediatric wards all over It­
aly come true, giving them the chance to have an 
emotional experience, making them more resilient 
and physically and emotionally stronger in fighting 
their illness.
Lastly, in the second half of 2022, Fineco also di­
rectly supported 8 other non-profit associations, do­
nating a total of around €68,000. These consisted 
of (i) I Semprevivi, for support to adolescent patients 
suffering from mental disorders in expressing them­
selves and their personalities in an autonomous and 
conscious manner; (ii) AIL, with a project to support 
leukaemia, myeloma and lymphoma patients travel­
ling to receive treatment and their families; (iii) Fon­
dazione Monzino, to support research in the field of 
8.2.

137
cardiology, (iv) No Walls, for the inclusion of immi­
grants, to support employment and their integration 
into society; (v) Una Mano Alla Vita, which promotes 
health welfare and social initiatives aimed at improv­
ing the quality of life of people with progressive 
chronic illnesses in the advanced stages; (vi) Kyoto 
Club, with the environmental sustainability project 
“Frutteto solidale” for the planting of fruit trees in 
Sardinia; (vii) Associazione Amici Dell’ematologia 
Di Pavia, to support research and the treatment of 
patients suffering from blood diseases, leukaemia, 
lymphoma, myeloma, and anaemia; (viii) and I Gigli 
Del Campo, with a project to support children with 
autism in organising their free time, in the hours not 
taken up by school and therapy.  
ENVIRONMENTAL SUSTAINABILITY AND CULTURAL INITIATIVES
The Group confirmed its important collaboration with 
the Italian environmental association FAI (Fondo 
Ambiente Italiano): FinecoBank has been a Corpo­
rate Golden Donor of FAI since 2017, a title that rec­
ognises companies that are most active in the area 
of culture and the protection of artistic heritage. In 
addition, as in 2021, Fineco was the main sponsor 
of the 2022 edition of the “Giornate FAI di Primav­
era” and the “Giornate FAI d’Autunno”, the two most 
important public events dedicated to Italy’s cultural 
and environmental heritage, with 1,000 extraordinary 
openings during the weekends in hundreds of Italian 
towns and cities. Fineco distributed cards to all em­
ployees to enable them to access the resources free 
of charge during the two events.
The Bank’s participation continued in the project 
“Cura e adotta il verde pubblico” launched by the 
Milan City Council, involving a partnership for the 
redevelopment of urban green areas in the city, in 
the area between Corso Como, Corso Garibaldi and 
Largo La Foppa. The aim of the sponsorship project, 
which will last around three years, is to contribute 
to the conservation and improvement of existing 
green areas. In particular, several sets of decorative 
railings were built in 2022, which will then remain 
with the city to continue to preserve the green areas, 
including the beautiful ancient olive trees. The green 
area was enhanced through maintenance work, se­
lecting and planting various types of plants. In terms 
of support to local communities, the project for the 
regeneration of the NOLO district in Milan continued. 
The intervention is part of the “Tunnel Boulevard”, 
a wide-ranging regeneration initiative aimed at trans­
forming and renovating the entire route along the Via 
Pontano tunnel (linking Via Padova and Viale Monza) 
with participatory social design, public art and urban 
art, involving a total of five railway tunnels, starting 
from this one.
The collaboration with LifeGate, in the PlasticLess® 
project, continued in 2022 with the aim of not only 
consolidating the action begun in 2021 in the fight for 
the recovery of plastic materials in seas and lakes, 
but also to increase the extent of the commitment, 
increasing the number of Seabins supported to a 
total of 12. The new units that Fineco has support­
ed from 2022 are located in Naples, Lignano Sab­
biadoro (UD), Fiumicino (RM), Santo Stefano al Mare 
(IM), Menaggio (CO), Fano (PU), and Messina. This 
investment has brought tangible results, with 4.5 
tonnes of floating plastic waste collected in 2022. 
The initiative was also accompanied by the activa­
tion of a local campaign to raise awareness of the 
issue of plastic waste, meeting hundreds of people 
across the country.
In 2022, FinecoBank provided its support for the 
second time to TEDxMilano, the local TED event 
held in Milan, which was divided into two events:
·	 The first was held over two days in May at the Teatro 
Parenti in Milan. The event, called “Micro&macro”, 
was dedicated to discovering the links that, in an 
increasingly connected world, bring together the 
Micro and the Macro, to understand how each indi­
vidual, young or adult, can drive change towards a 
more human and sustainable environment.

138
·	 In November, the second event was held, entitled 
“Countdown”, which focused on the global climate 
emergency. The Countdown project was created 
to identify and promote concrete solutions and 
actions to tackle the climate emergency, with the 
aim of building a more responsible and sustainable 
future. 
Fineco gave employees access to all the events free 
of charge. 
In 2022, a 5-year sponsorship was also initiated in 
Genoa with the company Mobilità e Trasporti aimed 
at implementing a Mural representing shared values 
(innovation, localness, and sustainable ethics). 
89	   The amount shown includes VAT at 22%.
90	 The figures for donations by customers in 2022 and 2020 were significantly higher than in 2021 as a result of the highly successful fundraising campaigns in support of 
associations in relation to the Russia-Ukraine conflict and the Covid-19 epidemic, in the respective years.
As part of its activities aimed at supporting institu­
tional events, Fineco sponsored the “IOC Annual 
Forum & Auxiliary Corporate Governance Confer­
ence 2022”, the “Ghislieri Prize” organised by the 
University of Pavia and the “XVIII Forum del Private 
Banking” organised by AIPB (Italian Private Banking 
Association).
Lastly, with regard to social aspects, at the beginning 
of 2022 Fineco AM financed the AIxGirls project, 
a free weekly campus for girls finishing the fourth 
year of high school, aimed at encouraging their en­
rolment in degree courses in technological subjects. 
The initiative is the first of its kind in Italy.
Type of community contribution (€)
2022
2021
2020
By Fineco
1,099,144
480,950
679,000
Charitable donations
692,995
179,000
313,000
Sponsorship89
406,149
301,950
366,000
By customers through Fineco
1,169,955
250,862
2,153,000
Funds raised and donated90
1,169,955
250,862
2,153,000
Total
2,269,099
731,812
2,832,000

140
140
09

141
ENVIRONMENT
9.1.	
THE EMAS ENVIRONMENTAL MANAGEMENT SYSTEM
 
9.2. 	
ENVIRONMENTAL PERFORMANCE

142
Protecting the environment, fulfilling compliance 
obligations, adopting tools and operating methods 
aimed at limiting the consumption of natural resourc­
es, preventing and mitigating risks related to the en­
vironment and reducing the impacts that may arise 
from the Group’s activities are objectives that Fineco 
pursues along the entire value chain, from procure­
ment choices to the operations of the personal finan­
cial advisor network. 
These commitments are enshrined in the following 
company documents:
•	FinecoBank’s Code of Ethics, which is the cor­
nerstone of the Organisation and Management 
Model adopted pursuant to Legislative Decree 
No. 231/2001, and in which the Protection of the 
Environment is a key principle, aimed at ensuring 
full and substantial compliance with environmental 
91	 Registration number IT-002166; NACE reference code 64.19.1 (Monetary intermediation by monetary institutions other than central banks); EMAS registration valid until 28 
June 2024.
92	The methodology for assessing environmental aspects is described in the 2020 Environmental Statement, available at: https://about.finecobank.com/en/investors/
rendicontazione-societaria-di-sostenibilita/2020/
legislation in all the activities carried out and care­
fully assessing the environmental consequences 
of every choice it makes in carrying out its activi­
ties.
•	The FinecoBank Group’s Environmental Policy, 
approved by the Board of Directors in 2020, which 
sets out Fineco’s general intentions and direction 
with respect to its environmental performance, in­
cluding compliance with all relevant environmental 
regulatory obligations and a commitment to contin­
uous improvement in environmental performance.
•	Reducing energy consumption - Global Policy, 
containing guidelines on the reduction of energy 
consumption at buildings occupied and/or man­
aged by Group Companies, in order to promote 
virtuous personal behaviour and practices.
	
THE EMAS ENVIRONMENTAL MANAGEMENT SYSTEM
In September 2022 FinecoBank obtained the EMAS 
Registration91 on its Environmental Management 
System in accordance with Regulation 1221/2009/
EC (EMAS Regulation - Eco-Management and Audit 
Scheme), a voluntary European certification of the 
organisation’s compliance with all regulatory obliga­
tions relating to the environment and its commitment 
to continuously measure, assess and improve its en­
vironmental performance.
The scope of Fineco’s EMAS Registration (below 
“EMAS Scope”) comprises:
•	 FinecoBank’s company offices, where its employ­
ees work and which include the Registered Office, 
the Head Office and the two Data Processing Cen­
tres (DPCs) located in premises owned by third 
parties and leased to Fineco;
•	 the sales network of Fineco Centers (FCs).
The subsidiary Fineco Asset Management DAC in 
Dublin is not included in the scope of the EMAS Reg­
istration. 
The implemented and planned actions for improv­
ing environmental performance are contained in the 
2021-2024 Environmental Programme which is 
part of Fineco’s broader Sustainability Goals Plan, 
described in section “1.3 Sustainable Development 
Objectives and commitments subscribed” of this 
NFS. The environmental improvement objectives 
have been set in line with the results of the materi­
ality assessment of FinecoBank’s direct and indirect 
environmental aspects, including business-related 
environmental aspects and environmental aspects 
related to property management (the Bank’s compa­
ny offices and Fineco Centers)92.  
9.1.

143
ENVIRONMENTAL ASPECT
ACTIVITY
Significant environmental aspects
Environmental aspects connected to the offering of socially and environ­
mentally focused lending products (mortgages and loans)
Business
Environmental aspects connected to the offering of ESG investment prod­
ucts and services
Business
Energy consumption
Property management: i) company 
offices, ii) Fineco Centers
Air emissions
Property management: i) company 
offices, ii) Fineco Centers
Environmental aspects of medium significance
Environmental aspects related to green and social bond investment poli­
cies and their management in the Bank’s portfolio
Business
Non-significant environmental aspects
F-GASES – Ozone-depleting substances
Property management: i) company 
offices, ii) Fineco Centers
Water consumption
Property management: i) company 
offices, ii) Fineco Centers
Water discharges
Property management: i) company 
offices, ii) Fineco Centers
Paper consumption
Property management: i) company 
offices, ii) Fineco Centers
Consumption of other materials – Plastic
Property management: i) company 
offices
Waste production and management
Property management: i) company 
offices, ii) Fineco Centers
Emergency management
Property management: i) company 
offices, ii) Fineco Centers
Mobility 
Property management: i) company 
offices, ii) Fineco Centers
Other environmental aspects (storage of hazardous substances; asbestos; 
radon; noise; electromagnetic fields)
Property management: i) company 
offices, ii) Fineco Centers
MANAGEMENT OF LEGISLATIVE COMPLIANCE
With regard to environmental compliance, in ac­
cordance with the compliance model relating to 
sustainability, described in section “5.1 Governance 
System” of this NFS, the Real Estate Unit is identified 
as the Specialist function with regard to the regu­
lations on responsible consumption, waste dispos­
al and pollution reduction at buildings used by the 
Bank and the personal financial advisors with lease 
in the name of the Bank. With regard to environmen­
tal compliance, in the three-year period 2020-2022, 
no sanctions were imposed for non-compliance with 
environmental regulations and laws, nor were any 
complaints received.

144
OPERATIONAL MANAGEMENT OF BUILDINGS
The management of the buildings depends on the 
type of site: company offices and Fineco Centers 
(FCs). For the latter, in particular, these can be divid­
ed into two categories: 
·	 “Corporate” FCs: offices for which FinecoBank 
holds the lease, which are given on a free loan for 
use basis to the PFAs.
·	 “PFA and Personal Office” FCs: properties where 
the lease is held by the PFAs operating there.
In the Bank’s company offices and in the corporate 
FCs, the maintenance, management, organisational 
and design activities, aimed at maintaining the value 
of the buildings, are entrusted by the Bank to Global 
Service (GS) companies on the basis of specific con­
tracts; fire protection services are outsourced to oth­
er specialised companies. The services performed 
by GS companies include: electrical installations, 
mechanical installations (heating, air conditioning, 
plumbing, drainage), building and complementary 
structures (works by masons, locksmiths, carpenters, 
glaziers, etc.), and outdoor green areas. In addition 
to the activities of the GS, further services provided 
by external companies, such as cleaning and waste 
management services, are also provided at the com­
pany offices. 
In the “PFA and Personal Studio” FCs, the building 
management is the responsibility of the PFAs in 
charge of the offices. 
With regard to the management of the environmen­
tal aspects connected with the activities carried out 
by third-party firms in the company offices and the 
corporate FCs, the respective contracts set out the 
legislative and operational requirements that the 
contractors are required to meet in performing the 
services and the methods of verification adopted by 
Fineco to control and monitor compliance with the 
requirements by those firms.
For all the types of FCs, since 2021 Fineco has pro­
duced and supplied a handbook summarising the 
main obligations and operating procedures to en­
sure proper environmental management of the offic­
es. Guidelines for the environmental design of the 
Fineco Centers were also drawn up in 2022, with 
the aim of managing and mitigating the environmen­
tal impacts associated with the supply chain, which 
include the following criteria:
•	the optimisation of existing building features, 
linked to the desirability, when acquiring, maintain­
ing or renovating a property, of reusing pre-existing 
architectural elements, installations and furnish­
ings, adapting them to the Fineco layout, following 
an analysis of their condition;
•	the reuse of fixtures and fittings, in order to re-uti­
lise the components and fittings products of discon­
tinued FCs (furniture, seating, lighting, signs, etc.) as 
much as possible for new Fineco Centers and the 
image makeovers of existing financial shops.
The methods for selecting and controlling suppliers 
are described in section “1.2. Who we are, strategy 
and business model”.  
COMMUNICATION, AWARENESS AND INFORMATION
Fineco is committed to supporting tangible solidarity 
and awareness projects in various areas, including 
environmental protection, as described in section 
“8.2 Community support” of this NFS. In relation to 
EMAS, after having obtained the certification, a se­
ries of dedicated initiatives were carried out, aimed 
at communicating the result obtained to internal and 
external stakeholders and promoting the dissemi­
nation of the EMAS logo, including a press release 
and a news item on the internal portal aimed at em­
ployees. The recognition was also incorporated into 
the content of the social media communication cam­
paign on Fineco’s sustainability initiatives and com­
mitments.

145
ENVIRONMENTAL PERFORMANCE
93	The corporate Fineco Centers can be separated into FCs where Fineco is the registered user of electricity utilities (15% of all the Fineco Centers and 56% of the corporate 
Fineco Centers) and those where these utilities are registered to the PFA.
This section contains the environmental data for the 
Fineco Group. For the sites within the EMAS scope, 
in particular, the relevant KPIs (Key Performance Indi­
cators) are calculated, in accordance with the EMAS 
Regulation.
ENERGY CONSUMPTION
As part of its commitment to minimise its environmen­
tal impact, the Group monitors energy consumption 
at its offices in Milan, Reggio Emilia and Dublin, at 
its DPCs and at the Fineco Centers where the Bank 
is the registered user of the utilities93. The company 
Energy Manager is the Head of the Real Estate Unit. 
In October 2022, the Bank issued the Circular on 
“Operational Measures for Responsible Energy 
Consumption”, which implements the European 
Commission’s guidelines set out in Regulation (EU) 
2022/1369 and the related National Consumption 
Reduction Plan of the Ministry of Ecological Tran­
sition. The Circular envisaged the following for the 
Fineco Centers, for the 2022-23 winter season: re­
ducing the period and duration of switch-on of heat­
ing systems, reducing the temperatures set in the 
systems, as well as reducing the operating times of 
illuminated signs. The document was uploaded onto 
the X-Net platform, with the personal financial advi­
sors being required to read it, and sent to the Global 
Service companies, which have implemented it for 
the corporate FCs. 
In 2022, the Energy Manager initiated specific anal­
yses, in collaboration with a specialist energy man­
agement consulting firm, aimed at designing energy 
efficiency measures for the Milan office. In 2022, 
work also began in the offices on the columns serv­
ing the heating and cooling systems to add electro­
valves able to partition the operation of the systems, 
in order to optimise the utilisation of the spaces be­
ing used. 
In January 2022, a contract was signed with a single 
national supplier for the supply of natural gas and 
electricity. The supplier was chosen on the basis of 
the company’s certifications and the guarantees of 
origin envisaged by Directive  2009/28/EC, which 
certify that it uses renewable sources. In addition, 
for gas, the supplier buys a quantity of certified car­
bon credits (VER - Verified Emission Reductions) that 
enables the offsetting of 100% of the CO2 equiva­
lent of methane gas consumption. The agreement 
provides for the extension of the offer at the same 
financial conditions also to personal financial advi­
sors that are the registered users of the electricity 
supply at the Fineco Centers and Personal Studios. 
This will bring benefits in terms of increased use of 
renewable energy in the Fineco Centers and greater 
visibility of consumption data also for the utilities reg­
istered in the name of PFAs. By the end of the year, 
42 personal financial advisors had signed up to the 
agreement. 
In 2022, authorisation was obtained for the installa­
tion of photovoltaic panels at the Milan head office. 
The new installation, which will be built and activated 
by 2023, will have a capacity of around 190 kW and 
is expected to produce around 10% of the electricity 
used for the building’s overall needs. 
At the FAM offices in Dublin, in 2022 the building 
management work aimed at optimising space and 
rationalising the lighting system has been complet­
ed. Overall, the energy efficiency measures imple­
mented during the year resulted in energy savings 
9.2.

146
of around 30 GJ at Group level.
Below is a summary of the categories of sites includ-
ed in the scope of the NFS, including the classifica-
tion of the corresponding energy consumption and 
94	 The building is owned by UniCredit and the corresponding utilities are owned by UniCredit.
95	 FAM’s offices occupy part of one floor inside a building that is shared with other companies and utilities are shared based on the occupied commercial space.
96	 The management of the two data processing centres is outsourced to third-party companies that operate in buildings and with utilities over which Fineco has no operational 
control.
97	 FinecoBank does not own the utilities at any Fineco Center leased by PFAs.
related emissions. Lastly, the methods for classifying 
internal and external energy consumption and the 
respective Scope 1, 2 and 3 emissions are based on 
the operational control of the utilities. 
TYPE OF SITE
Energy consumption classification
Emission classification
Company offices
Milan FinecoBank
Internal to FinecoBank
- Scope 1 for fuels 
- Scope 2 for electricity
Reggio Emilia94 FinecoBank
External to FinecoBank
- Scope 3
Dublin95 Fineco AM
External to FinecoBank
- Scope 3
Service sites
Data Processing Centres96
External to FinecoBank
- Scope 3
Fineco Centers
Leased to FinecoBank 
Electrical utilities
Registered to FinecoBank 
Internal to FinecoBank
- Scope 2
Not registered to FinecoBank 
External to FinecoBank
- Scope 3
Natural gas utilities
Registered to FinecoBank 
Internal to FinecoBank
- Scope 1
Not registered to FinecoBank 
External to FinecoBank
- Scope 3
District heating utilities 
Registered to FinecoBank 
Internal to FinecoBank
- Scope 2
Not registered to FinecoBank 
-
-
Leased to the PFAs97
External to FinecoBank
- Scope 3
The Fineco Group’s total energy consumption in 
2022 was 47.7 TJ, of which approximately 75% due 
to indirect consumption, i.e. purchasing electricity 
and heat. With regard to the total electricity con-
sumption – therefore including utilities registered 
to Fineco and those registered to third parties – the 
Group consumed 66% of its electricity from renew-
able sources in 2022.

147
98	 For the year 2022, for the Milan and source text office, the allocation of assumption for electricity and heating was made on the basis of occupancy square metres 
apportioned based on the use of space (office, warehouse, bathrooms, etc.) of the individual companies operating in the buildings.  The common areas were also 
apportioned according to the same occupancy percentages. Based on this approach, the figures for 2020 and 2021 were restated. See the 2021 Sustainability Report, for 
the previously published historical figure. In addition, for the months of November and December 2022, a further parameter was introduced solely for Mondays and Fridays, 
because on these days almost all Fineco offices were closed to employees (unlike the other companies in the buildings), which meant that no electricity was used and the 
heating system was running at a minimum. 
99	  For employees, the KPIs are calculated on the number of FinecoBank employees as at 31/12 each year: 1,279 (in 2022), 1,261 (in 2021), and 1,222 (in 2020). For the advisors, 
the KPIs are calculated on the number of personal financial advisors as at 31 December of each year: 2,918 (in 2022), 2,790 (in 2021), and 2,606 (in 2020). 
100	Based on the invoice amounts for Fineco Centers where the utilities are registered to Fineco, the electricity and gas consumption per square metre of each FC was 
calculated, the average value of which was in turn used to estimate the total consumption of the Fineco Centers where the utilities are not registered to Fineco. 
101	It should be noted that, as indicated in the ABI Lab Guidelines on the application of GRI (Global Reporting Initiative) environmental standards in banks, December 2022 
version, 70% of overall consumption was for company cars under continuous mixed-use leasing, and that the consumption of the car fleet does not include Fineco Centers. 
With regard to the mobility associated with the operation of the Fineco Centers, please also note that the related vehicles are under the control of the PFAs.
Below are the main data and indicators on energy 
consumption, both direct (gas and diesel) and indi-
rect (purchased electricity and thermal energy), for 
the FinecoBank offices98, Fineco AM and Fineco 
Centers, and the respective EMAS KPIs for the sites 
included in the EMAS scope99. Information about the 
car fleet and the mobility initiatives, is provided in a 
specific section below. With regard to the sales net-
work, for the FCs where the utilities are registered 
to Fineco, metered consumption data are available, 
while for the remaining FCs, consumption is estimat-
ed100 on the basis of the characteristics of the offices, 
including in particular the surface area used for the 
activities.
Energy consumption within the organisation, 
by source [GJ]
2022
2021
2020
Natural gas for heating
4,007
5,283
5,163
of which Milan office
3,482
4,592
4,494
of which FCs utilities registered to FinecoBank
525
691
669
Fuel for FinecoBank car fleet101 
1,478
1,251
916
of which gasoline
537
239
120
of which diesel
941
1,012
796
Total direct energy consumption
5,485
6,534
6,079
Electricity
13,197
13,285
12,648
of which Milan office
6,336
6,375
6,688
of which FCs utilities registered to FinecoBank
6,861
6,910
5,960
From non-renewable sources
-
54
472
From renewable sources
13,197
13,231
12,175
District heating
-
68
70
of which FCs utilities registered to FinecoBank
-
68
70
From non-renewable sources
-
68
70
From renewable sources
-
-
-
Total indirect energy consumption
13,197
13,353
12,718
Total internal energy consumption
18,682
19,887
18,797

148
Energy consumption outside the organisation, 
by source [GJ]
2022
2021
2020
Natural gas for heating
6,352
5,768
 5,847
of which FCs utilities registered to third parties
6,032
5,610
5,548
of which Fineco AM
320
158
299
 Total direct energy consumption 
6,352
5,768
5,847
Electricity
21,415
23,229
 23,816 
of which Reggio Emilia office
735
770
839
of which DPCs
8,747
10,544
12,109
of which FCs utilities registered to third parties
11,577
11,786
10,703
of which Fineco AM
356
129
165
From non-renewable sources
11,681
11,915
 10,868 
From renewable sources
9,734
11,314
 12,948 
District heating
1,237
1,722
 1,219 
of which Reggio Emilia office
1,237
1,722
1,219
 of which FCs utilities registered to third parties
-
-
-
From non-renewable sources
1,237
1,722
 1,219 
From renewable sources
-
-
-
Total indirect energy consumption
22,652
24,951
25,035
Total external energy consumption
29,004
30,719
30,882
ENERGY CONSUMPTION - FINECO GROUP [GJ]
2022
2021
2020
DIRECT CONSUMPTION
11,837
12,302
11,926
INDIRECT CONSUMPTION
35,849
38,304
37,753
ENERGY PURCHASED FROM RENEWABLE 
SOURCES 
22,931
24,545
25,123
CONSUMPTION (DIRECT + INDIRECT)
47,686
50,606
49,679

149
EMAS KPI Italy - Energy
2022
2021
2020
DIRECT CONSUMPTION AT FINECOBANK 
OFFICES [GJ]
4,960
5,843
5,410
INDIRECT CONSUMPTION OF FINECOBANK 
OFFICES [GJ]
17,055
19,411
20,855
Energy consumption per employee [GJ per capita]
17.21
20.03
21.42
DIRECT CONSUMPTION FINECO CENTERS [GJ]
6,557
6,301
6,217
INDIRECT CONSUMPTION FINECO CENTERS [GJ]
18,438
18,764
16,733
Energy consumption per advisor [GJ per capita]
8.57
8.98
8.81
In 2022, 54% of the electricity consumption of the company offices was attributable to the consumption of the 
DPCs, which represent the most energy-intensive activities. Therefore, the weight of this consumption and the 
presence of only 6 employees at the Data Centres must be taken into account when analysing the per-capita 
indicator of the offices (also compared to that of the sales network). Indeed, if we consider the total consump-
tion per employee of the Milan and Reggio Emilia offices alone, removing the effect of the DPCs, the indicator 
in 2022 falls from 17.2 GJ/employee to 10.4 GJ/employee. In terms of performance, the DPCs show high levels 
of energy efficiency, as demonstrated by their respective Power Usage Effectiveness (PUE) values, a widely 
recognised standard, in comparison with the benchmarks.
PUE 
2022
2021
CED Pero
1.57
1.57
CED Milan 
1.48
1.55
PUE
LEVEL OF DPC EFFICIENCY
3.0
Very inefficient
2.5
Inefficient
2.0
Medium
1.5
Efficient
1.2
Very efficient
Source: https://www.42u.com/measurement/pue-dcie.htm

150
AIR EMISSIONS
Greenhouse Gas (GHG) emissions are calculated to identify and monitor the Group’s environmental perfor­
mance. Any misalignments of one unit are due to rounding.
TYPE OF EMISSION FINECOBANK 
OFFICES AND DPCs  [t CO2e]
CATEGORY
2022
2021
2020
Direct Emissions 
Natural gas 
203
266
260
Diesel
70
75
59
Gasoline 
40
18
9
TOTAL DIRECT EMISSIONS - SCOPE 1 
313
359
328
Indirect Emissions 
(Location-based)
Electricity
460
495
554
District heating 
-
-
-
TOTAL INDIRECT EMISSIONS  – SCOPE 2 
(Location-based)102
460
495
554
Indirect Emissions 
(Market-based)
Electricity
-
-
45
District heating 
-
-
-
TOTAL INDIRECT EMISSIONS – SCOPE 2 
(Market-based)
-
-
45
Other Indirect Emissions 
Natural gas 
-
-
-
Electricity103
-
-
-
District heating  
44
62
101
Office paper
3
2
3
TOTAL OTHER INDIRECT EMISSIONS – SCOPE 3
47
64
104
TOTAL EMISSIONS (with Scope 2 - “Location-based”)
819
918
985
TOTAL EMISSIONS (with Scope 2 - “Market-based”)
360
423
477
102	The energy conversion factors and emission factors used are those indicated in the ABI Lab guidelines on the application of the Global Reporting Initiative’s (GRI) 
environmental standards in banks, December 2022 version. In particular, the reporting standard used (GRI Sustainability Reporting Standards) provides for two different 
approaches to calculating Scope 2 emissions, namely Location-based and market-based. The location-based approach uses average emission factors relating to the 
specific national energy mix of electricity production (emission factor used of 261.2 gCO2e/kWh from the Italian Banking Association Guidelines 2022). The “Market-based” 
approach involves the separation of electricity and thermal energy purchased from renewable sources with certificates of Guarantees of Origin, as well as using the national 
“residual mix”, which is 457 gCO2/kWh for Italy (Source: European Residual Mixes 2021, Version 1.0, 2022-05-31, AIB).
103	 When drawing up the Net Zero Plan, in-depth studies were carried out on the calculation of greenhouse gas emissions, as a result of which the emissions associated with 
the electricity consumption of the two DPCs and the Reggio Emilia office were more accurately zeroed as they were covered by certificates of guarantee of origin. Based 
on this approach, the figures for 2020 and 2021 were restated. See the 2021 Sustainability Report, for the previously published historical figure.
TYPE OF EMISSION 
FINECO AM [tCO2e]
CATEGORY
2022
2021
2020
Direct Emissions 
Natural gas 
-
-
-
Diesel 
-
-
-
Gasoline 
-
-
-
TOTAL DIRECT EMISSIONS - SCOPE 1 
-
-
-
Indirect Emissions 
(Location-based)
Electricity
-
-
-
District heating 
-
-
-

151
TYPE OF EMISSION 
FINECO AM [tCO2e]
CATEGORY
2022
2021
2020
TOTAL INDIRECT EMISSIONS – SCOPE 2 
(Location-based)
-
-
-
Indirect Emissions  
(Market-based)
Electricity
-
-
-
 District heating   
-
-
-
TOTAL INDIRECT EMISSIONS  – SCOPE 2  
(Market-based)
-
-
-
Other Indirect Emissions 
Natural gas 
19
9
17
Electricity
8
10
14
District heating  
-
-
-
Office paper
0.02
0.01
0.08
TOTAL OTHER INDIRECT EMISSIONS - SCOPE 3
26
19
31
TOTAL EMISSIONS (with Scope 2 - “Location-based”)
26
19
31
TOTAL EMISSIONS (with Scope 2 - “Market-based”)
26
19
31
TYPE OF EMISSION 
FINECO CENTERS [t CO
 [t CO2e]
e]
CATEGORY
CATEGORY
2022
2022
2021
2021
2020
2020
Direct Emissions 
Natural gas 
31
31
40
40
39
39
Diesel 
-
-
-
Gasoline 
-
-
-
TOTAL DIRECT EMISSIONS - SCOPE 1 
31
31
40
40
39
39
Indirect Emissions 
(Location-based)
Electricity
498
498
536
536
493
493
District heating 
-
4
6
TOTAL INDIRECT EMISSIONS - SCOPE 2 
(Location-based)
498
498
540
540
499
499
Indirect Emissions 
(Market-based)
Electricity
Electricity
-
7
16
16
 District heating   
 District heating   
-
4
6
TOTAL INDIRECT EMISSIONS - SCOPE 2 
(Market-based)
-
11
11
22
22
Other Indirect Emissions 
Natural gas 
351
351
325
325
321
321
Electricity
Electricity
840
840
914
914
886
886
District heating  
-
-
-
Office paper
14
14
13
13
14
14
TOTAL OTHER INDIRECT EMISSIONS - SCOPE 3
1,205
1,205
1,253
1,253
1,221
1,221
TOTAL EMISSIONS (with Scope 2 - Location-based)
1,734
1,734
1,833
1,833
1,759
1,759
TOTAL EMISSIONS (with Scope 2 - Market-based)
1,236
1,236
1,304
1,304
1,282
1,282

152
EMISSIONS - FINECO GROUP [t CO2e]
2022
2021
2020
TOTAL SCOPE 1
344
399
367
of which FinecoBank Offices 
313
359      
328
of which Fineco Centers
31
40
39
TOTAL SCOPE 2 (“Location-based”)
958
1,035
1,053
of which FinecoBank Offices 
460
495
554
of which Fineco Centers
498
540
499
TOTAL SCOPE 2 (“Market-based”)
-
11
67
of which FinecoBank Offices 
-
-
45
of which Fineco Centers
-
11
22
TOTAL SCOPE 3104
1,279
1,336
1,356
of which FinecoBank Offices and DPCs 
47
64
104
of which Fineco Centers
1,205
1,253
1,221
of which Fineco AM
26
19
31
EMAS KPI Italy - Emissions [t CO2e]
2022
2021
2020
Emissions per employee (with Scope 2 - Location-based)
0.64
0.73
0.80
Emissions per employee (with Scope 2 - Market-based)
0.28
0.34
0.39
Emissions per advisor (with Scope 2 - Location-based)
0.59
0.66
0.67
Emissions per advisor (with Scope 2 - Market-based)
0.42
0.47
0.49
104	 The GHG Protocol identifies 15 categories of Scope 3 “Other indirect GHG emissions”, including activities upstream and downstream of the Company’s operations. The 
Scope 3 emissions included in this NFS are the following: i) Category 1 office paper consumption; ii) Category 8 electricity and district heating of the Reggio Emilia and 
Fineco AM Dublin offices; electricity of Data Processing Centres; iii) Category 14 electricity and gas for heating of FCs with lease registered to Fineco, but utilities registered 
to third parties.
Greenhouse gas emissions per employee in Italy have 
decreased over the last year, by around 12% consid­
ering Scope 2 emissions calculated using the Loca­
tion-based approach and by around 18% considering 
those calculated using the Market-based approach. 
This improvement in performance over the past year 
reflects the reduction in energy consumption. 
Similarly, the emissions per advisor for the Fineco 
Centers have decreased over the past two years, 
from 0.66 to 0.59 t CO2e (location-based Scope 
2 emissions) and from 0.47 to 0.42 t CO2e (mar­
ket-based Scope 2 emissions).
In August 2022, the Board of Directors approved 
the “Net-Zero Emission in 2050 Commitment” re­
lating to the Fineco Group’s zeroing of greenhouse 
gas emissions by the year 2050, envisaging both 
a significant reduction in operating emissions and 
the alignment of its assets with the Paris Agreement 
goals of limiting the global temperature increase to 
1.5° C above pre-industrial levels. See section “1.3. 
Sustainable Development Goals and commitments 
made” of this NFS for more details.

153
MOBILITY
105	The paper consumption for the sales network was estimated by collecting the number of reams consumed each year, from a sample of FCs, and, consequently, the total 
weight of paper consumed. This figure was used to obtain an indicator of the kg of paper consumed per PFA per capita, which was then multiplied by the total number of 
PFAs to obtain the total consumption.
106	For the year 2020, the consumption data for the offices is not fully comparable with the subsequent years 2021 and 2022, because it does not include the data on the 
consumption of paper at the DPCs, which was not available.
With regard to mobility management, in 2022 Fine­
coBank again drew up the Home-Work Travel Plan 
for the Milan and Reggio Emilia offices, based on the 
analysis of public transport in the areas concerned 
and the mobility habits and needs of employees 
gathered through a specific survey. The Plan has 
been drafted with the objective of developing sus­
tainable mobility tools to reduce the environmental 
impact of vehicle traffic in the urban and metropol­
itan areas where Fineco operates. The company 
Mobility Manager coordinates the drafting of the 
Plan and, with the support of the units concerned, 
oversees the effective implementation of initiatives 
to promote sustainable mobility and monitors emis­
sions from home-to-work journeys.
In 2022, a company portal dedicated exclusive­
ly to sustainable mobility was created, made up of 
specific sections for mobility-related services such 
as “traffic info”, “route finder”, “purchase of travel 
passes at reduced rates and in instalments”, etc., in 
addition to the initiatives already made available to 
employees (e.g. the reimbursement of bike-sharing 
subscriptions). In 2023, a new initiative dedicated to 
Sharing Mobility will be introduced, which will allow 
employees to use travel services such as car-shar­
ing, bike-sharing and scooter-sharing at subsidised 
prices.
The policy on the allocation of cars for mixed pri­
vate and business use includes a car list consist­
ing solely of hybrid/electric cars. With regard to the 
mobility associated with the operation of the Fineco 
Centers, the related vehicles are under the control 
of the PFAs.
Lastly, with regard to Fineco Asset Management 
DAC, several initiatives have been implemented to 
encourage sustainable mobility, including the possi­
bility of obtaining public transport passes at subsi­
dised prices and buying traditional or electric bicy­
cles without paying taxes.
CONSUMPTION OF MATERIALS
The initiatives described in the chapter on innova­
tion in dematerialisation, in particular the possibility 
for customers to provide digital and electronic hand­
written signatures and the use of digital signatures 
by the bank, have brought great benefits in terms of 
reducing paper consumption, enabling the Bank and 
its customers to save more than 44 tonnes of paper 
in 2022 alone. 
The paper consumption and related indicators are 
shown below. For the FCs, the data reported are the 
result of an estimate105 based on the consumption 
of reams of paper recorded in a sample of Fineco 
Centers.  
Paper consumption
2022
2021
2020
Total paper consumed - FinecoBank offices [kg]106 
6,836
5,755
7,125
of which FSC-certified paper [%]
100%
100%
100%

154
Paper consumption
2022
2021
2020
of which EU Ecolabel-certified paper [%]
100%
99%
100%
Total paper consumed - Fineco AM [kg]
64
14
195
of which FSC-certified paper [%]
100%
100%
100%
of which EU Ecolabel-certified paper [%]
-
-
-
Total paper consumed - Fineco Centers [kg]
36,156
34,455
36,043
of which FSC-certified paper [%]
51%
49%
47%
of which EU Ecolabel-certified paper [%]
61%
89%
62%
OVERALL TOTAL [kg]
43,056
40,224
43,363
of which FSC-certified paper [%]
59%
57%
52%
of which EU Ecolabel-certified paper [%]
67%
91%
63%
EMAS KPI Italy - Paper consumption [kg per capita]
EMAS KPI Italy - Paper consumption [kg per capita]
2022
2022
2021
2021
2020
2020
Paper consumption per employee
Paper consumption per employee 
5.3
5.3
4.6
4.6
5.8
5.8
Paper consumption per advisor
Paper consumption per advisor 
12.4
12.4
12.3
12.3
13.8
13.8
107 Legislative Decree 116/2020, transposing the EU Directive 2018/851 on waste, partially amended, with effect from 1 January 2021, the regulations of Part IV of Legislative 
Decree 152/2006 (Environmental Code). The amendment of Articles 183 and 184 of the Environmental Code revised the definition of waste, which can now be divided into 
municipal waste, special waste and “formerly assimilated” municipal waste. Annex L quinquies of Legislative Decree 116/2020 lists the economic activities that may produce 
such waste, including Banks (“Annex L-quinquies: Activities producing formerly assimilable, now municipal waste”). 
WASTE MANAGEMENT
The waste produced at FinecoBank’s sites mainly 
consists of non-hazardous materials such as paper 
and cardboard, toner and other waste that can be 
considered municipal waste (plastic, organic, various 
packaging)107. This waste is delivered to the respec-
tive municipal public collection service, except for 
paper produced at the company offices – for which 
the service of collection and delivery for treatment 
is contracted out to a specialised waste company – 
and for spent toners, which are managed by a sup-
plier as part of the maintenance of printing consum-
ables. At the DPCs, paper and cardboard waste is 
managed by the host companies. 
Below are the quantities of waste produced by Fi-
neco and managed by contracted companies, taken 
from the Waste Identification Forms accompanying 
their transport to recovery or disposal facilities; the 
figures refer exclusively to the Bank’s company of-
fices.

155
EMAS KPI Italy - FinecoBank waste
2022
2021
2020
Paper and cardboard108 [kg]
33,530
29,070
26,050
Total waste produced [kg]
33,530
29,070
26,050
Waste generated per employee [kg pro-capite]
26.2
23.1
21.2
108	The figure for 2020 only comprises the Milan office. It was not possible to include the figure for Reggio Emilia because, as at 31/12/2020, paper and cardboard waste was 
mainly collected through the municipal collection service. Since 2021, this type of waste has been delivered to an external contracted firm for collection and sending for 
recovery.
109	 Analytical and systematic method for assessing the environmental footprint (defined as the impact on the ecosystem and natural resources) of a product or service over 
its entire life cycle. The calculation of the environmental impacts using LCA methodology was carried out in accordance with ISO 14041-14044.
110	  The environmental impact related to the production and disposal of electrical and electronic equipment does not end with the emission of greenhouse gases, but also 
involves other aspects, such as groundwater pollution (both river and sea), harmfulness to humans due to carcinogenic substances, and water consumption. The indicators 
for carcinogenic and ecotoxic substances shown in the table are normalised on the basis of the carcinogenicity of the aromatic compound 1,4-dichlorobenzene.
Form a circular economy perspective, electronic de-
vices that are no longer usable, if they are consid-
ered obsolete but still functional, are reconditioned 
for resale or sale for humanitarian purposes (e.g. 
missions and social works). If the goods have out-
lived their usefulness and are found to be non-func-
tional, they are transferred to specialist firms, which 
take care of their destruction and disposal in accord-
ance with the legal requirements. 
In 2022, a Life Cycle Assessment109 (LCA) study was 
carried out on the reconditioning and reuse of elec-
tronic equipment, in particular multifunctional devic-
es and monitors, compared to their disposal at me-
chanical recycling plants. Specifically, the reduction 
of environmental impacts due to the reuse of elec-
tronic equipment compared to a traditional scenario 
of delivery to WEEE facilities was calculated. 
Life Cycle Assessment KPIs110
2022
2022
Devices delivered [kg]
4,784
4,784
Devices delivered [no.]
429
429
Devices sent for reuse [no.]
313
313
% devices sent for reuse 
73%
73%
Greenhouse gas emissions avoided [tonnes CO2e]
126
126
Water consumption avoided [m3]
1,183
1,183
Emissions of human carcinogens avoided [tonnes]
18
18
Emission of ecotoxic substances in freshwater avoided [tonnes]
43
43
Emission of ecotoxic substances into the marine environment avoided [tonnes] 
56
56

156
WATER CONSUMPTION AND DISCHARGES
111	 For the estimate, the invoiced amounts were collected from the Fineco Centers where the utilities are registered to the Bank, to first quantify the consumption in cubic metres 
of each office and then a consumption per PFA, based on the number of personal financial advisors associated with the individual FCs considered. The average consumption 
of m3 of water per PFA was used to estimate the total consumption.
112	The figure for FinecoBank offices does not include the water consumption of Fineco staff at the DPCs. However, they represent a very low quantity due to the small number 
of staff in the centers (6) and their use exclusively for hygiene and sanitary purposes
113	Annex IV of the EMAS Regulation lists “land use in relation to biodiversity” as a key environmental performance indicator. In this regard, information must be collected on 
the following: total use of land, total sealed area, total nature-oriented area on site, total nature-oriented area off site. For FinecoBank’s EMAS registration, this indicator was 
constructed solely with respect to the m2 of land occupied in total by the Bank’s offices and sales network (total use of land).
The water supply is from the aqueduct and is mainly 
used for sanitary facilities and office cleaning. Water 
consumption has gradually increased over the last 
two years, linked to the steady return of employees 
and personal financial advisors to their respective of-
fices, compared to the extensive use of home work-
ing for employees in 2020 and the level of attend-
ance of the PFAs in FCs, due to the pandemic.
The water consumption of Fineco Centers is derived 
from an estimate111 based on the number of PFAs 
present at the FCs multiplied by an average con-
sumption per advisor. Wastewater is discharged into 
the public sewerage system, in accordance with the 
applicable regulations. 
Water consumption [m3] [m3]
2022
2021
2020
Water consumption - FinecoBank112 
6,452
3,291
1,343
Water consumption - Fineco AM
176
82
n.a.
Water consumption - Fineco Centers 
35,568
21,233
17,544
TOTAL 
42,196
24,606
18,887
EMAS KPI Italy - Water consumption [m3 per capita]
2022
2021
2020
Water consumption per employee 
5.0
2.6
1.1
Water consumption per advisor
12.2
7.6
6.7
BIODIVERSITY
The indicator of gross surface area per employee 
(used as an indicator of total land use in accordance 
with the EMAS Regulation113) is 16.2 m2 per employee 
for the company offices, and 26.3 m2 per advisor for 
the company FCs, as detailed below.

157
EMAS KPI Italy - Biodiversity
2022
2021
2020
Gross surface area FinecoBank offices [m2]
20,693
21,157
21,222
of which Registered Office
15,558
15,558
15,992
of which Head Office 
4,260
4,399
3,170
of which DPCs
875
1,200
1,310
of which business continuity site114
-
-
750
Number of employees FinecoBank [no.]
1,279
1,261
1,221
Gross surface area per employee [m2 per capita]
16.2
16.8
17.3
Gross surface area FCs [m2]
76,678
63,478
73,669
Number of advisors [no.]
2,918
2,790
2,606
Gross surface area per advisor [m2 per capita]
26.3
22.8
28.3
OTHER ENVIRONMENTAL ASPECTS 
114	The termination of the business continuity site in Milan was formalised on 01/03/2021. The site was still included in the Fineco scope in the first two months of 2021, but it 
was no longer operational.
The air conditioning of the premises is carried out 
through the operation of equipment containing fluor­
inated greenhouse gases (f-gases), which, in line 
with applicable regulations, are regularly checked 
for leaks and subject to routine and extraordinary 
maintenance. This activity is outsourced to mainte­
nance firms for the Bank’s company offices and the 
company FCs, and controlled using a specific elec­
tronic facility management platform. 
Within the EMAS scope, the management of emer­
gencies mainly concerns fire prevention measures. 
The Bank complies with all the general occupation­
al health and safety measures in accordance with 
Legislative Decree no. 81/2008 and organises the 
necessary relations with the competent public ser­
vices in terms of first aid, rescue, fire fighting and 
emergency management. An evacuation test is car­
ried out annually at the company offices, the results 
of which are duly recorded and any anomalies are 
promptly taken into account and addressed. The 
Milan Durante and Reggio Emilia offices have the 
respective Fire Prevention Certificates pursuant to 
Presidential Decree 151/2011. There are no activities 
in the FCs that are subject to fire prevention controls 
under the above-mentioned regulations.
The presence of asbestos is not a significant en­
vironmental aspect of FinecoBank’s business. For 
the assessment of the environmental significance 
of this aspect, the possible presence of asbestos in 
the sites is considered relevant in that it represents 
a problem for the external environment and for hu­
man health and safety. In this respect, the presence 
of asbestos can only be considered environmentally 
significant when it is detected in areas and parts of 
buildings in contact with the outdoors, such as chim­
neys and building roofs. There are no objects with 
Materials Containing Asbestos in contact with the 
external environment, either in the Milan office or in 
the company FCs.
With regard to the possible presence of radon gas,

158
an analysis was carried out on all the company FCs 
located in the Puglia and Campania Regions (both 
company FCs and PFA and Personal Studio FCs) and 
in the remaining corporate Fineco Centers located 
throughout the country, examining the basement and 
ground floor rooms of the buildings. In the FCs of the 
Puglia Region, no gas levels above the limits set by 
regional regulations were detected. In the FCs of the 
Campania Region, the presence of radon gas was 
detected inside three buildings. In the remaining FCs 
located throughout the country, the presence of Ra­
don gas was detected in eight buildings. In the FC 
buildings where the presence of radon gas was de­
tected, remedial works are planned and carried out 
on the premises under the responsibility of Fineco 
and/or the owner, based on their respective respon­
sibilities.
In general, Fineco’s activities do not give rise to ex­
ternal noise. The only noise sources can be found 
in the motors of the air conditioning systems, both 
in the company offices and at the Fineco Centers. 
However, in both cases these are not situations ca­
pable of generating significant disturbances. In the 
DPCs, the assessment of the risks related to the 
noise sources represented by the systems support­
ing the operations of the data centres, carried out 
from the perspective of occupational health and 
safety in fulfilment of the requirements of Legisla­
tive Decree 81/2008, has not identified any critical 
issues. Noise is consequently not a significant envi­
ronmental aspect. 
Within the EMAS scope, no problem issues related 
to the presence of electromagnetic fields and con­
sequent compliance with the applicable regulations 
have been identified. This environmental aspect is 
consequently not significant. 
The presence of hazardous substances in the Fi­
neco sites is not a significant environmental aspect. 
This environmental aspect may derive from the pos­
sible presence of stocks of diesel fuel serving pow­
er generators at company offices (for which checks 
are carried out periodically to ensure that they are 
properly maintained) or from the possible use of haz­
ardous substances by suppliers during maintenance 
or construction activities, the proper management of 
which is contractually regulated.

159
GRI CONTENT INDEX 
Statement of use
FinecoBank S.p.A. has reported in accordance with the GRI Standards for the 
period from 1 January 2022 to 31 December 2022
GRI 1 Used
GRI 1: Foundation 2021
Applicable GRI Sector 
Standard(s)
The Sector Standards for the financial services sector were not yet available 
at the date of publication of this document
GRI 
Standard/
Other 
source
Disclosure
Page No./
Notes
Omissions
GRI 2: General Disclosures 2021
The organization and its reporting practices
2-1
Organizational details
7, 11-12
2-2
Entities included in the organization’s sustainability reporting
7
2-3
Reporting period, frequency and contact point
6-7
2-4
Restatements of information
7, 23-25, 93, 
147, 150
2-5
External assurance
165-167
Activities and workers
2-6
Activities, value chain and other business relationships
12-16
2-7
Employees
112-113; 
 There are 
no non-
guaranteed 
hours 
employees 
2-8
Workers who are not employees
116
Governance
2-9
Governance structure and composition
66-67, 70-71
2-10
Nomination and selection of the highest governance body
66, 69, 72
2-11
Chair of the highest governance body
69-70
2-12
Role of the highest governance body in overseeing the man­
agement of impacts
67-69
2-13
Delegation of responsibility for managing impacts
67-69
2-14
Role of the highest governance body in sustainability report­
ing
7
2-15
Conflicts of interest
102-103
2-16
Communication of critical concerns
99-100

160
GRI 
Standard/
Other 
source
Disclosure
Page No./
Notes
Omissions
2-17
Collective knowledge of the highest governance body
66
2-18
Evaluation of the performance of the highest governance 
body
71
2-19
Remuneration policies
73-74
2-20
Process to determine remuneration
73-74
2-21
Annual total compensation ratio
75
Strategy, policies and practices
2-22
Statement on sustainable development strategy
4-5
2-23
Policy commitments
99, 103-104
2-24
Embedding policy commitments
98
2-25
Processes to remediate negative impacts
99-108
2-26
Mechanisms for seeking advice and raising concerns
99-100
2-27
Compliance with laws and regulations
No significant 
instances of 
non-compli­
ance with 
laws and reg­
ulations were 
recorded in 
2022
2-28
Membership associations
30
Stakeholder engagement
2-29
Approach to stakeholder engagement
34-38
2-30
Collective bargaining agreements
128
GRI 3: Material Topics 2021
3-1
Process to determine material topics
39
3-2
List of material topics
39-41
Cybersecurity and information security
GRI 3: Material Topics 2021
3-3
Management of material topics
45-48
Customer Satisfaction
GRI 3: Material Topics 2021 
3-3
Management of material topics
35

161
GRI 
Standard/
Other 
source
Disclosure
Page No./
Notes
Omissions
Innovation
GRI 3: Material Topics 2021
3-3
Management of material topics
60-61
Responsible Finance
GRI 3: Material Topics 2021
3-3
Management of material topics
49-54
GRI-G4 Financial Services Sector Disclosures
G4 - FS7
Monetary value of products and services designed to deliver 
a specific social benefit for each business line broken down 
by purpose
50-51, 54
G4 - FS8
Monetary value of products and services designed to deli­
ver a specific environmental benefit for each business line 
broken down by purpose
50-51, 54
G4 - FS11
Percentage of assets subject to positive and negative envi­
ronmental or social screening
54
G4 - FS14
Initiatives to improve access to financial services for disad­
vantaged people
55
Group’s solidity and resilience
GRI 3: Material Topics 2021
3-3
Management of material topics
64-89, 95
GRI 201: Economic Performance (2016)
201-1
Direct economic value generated and distributed
90-92
Correctness and transparency of information 
GRI 3: Material Topics 2021 
3-3
Management of material topics 
56
GRI 417: Marketing and Labeling (2016)
417-3
Incidents of non-compliance concerning marketing 
communications
56
Business ethics and compliance culture
GRI 3: Material Topics 2021
3-3
Management of material topics
98-101, 104
GRI 205: Anti-Corruption (2016)
205-3
Confirmed incidents of corruption and actions taken
101-102

162
GRI 
Standard/
Other 
source
Disclosure
Page No./
Notes
Omissions
GRI 206: Anti-competitive Behavior (2016)
206-1
Legal actions for anti-competitive behavior, antitrust, and mo­
nopoly practices
103
GRI 415: Public Policy (2016)
415-1
Political contributions
30
GRI 418: Customer privacy (2016)
418-1
Substantiated complaints concerning breaches of customer 
privacy and losses of customer data
104
Financial education and advice
GRI 3: Material Topics 2021
3-3
Management of material topics
115-116, 134-135
GRI-G4 Financial Services Sector Disclosures 
G4 - FS16
Initiatives to enhance financial literacy
134-135
Fair and inclusive work environment through talent attraction and retention strategies and meritocratic 
remuneration policies
GRI 3: Material Topics 2021
3-3
Management of material topics
112, 114-128
GRI 401: Employment (2016)
401-1
New employee hires and employee turnover
114-115, 117
GRI 404: Training and Education (2016)
404-1
Average hours of training per year per employee
122, 126
GRI 405: Diversity and Equal Opportunity (2016)
405-1
Diversity of governance bodies and employees
70, 113, 116
405-2
Ratio of basic salary and remuneration of women to men
119
GRI 406: Non-discrimination (2016)
406-1
Incidents of discrimination and corrective actions taken
118
Protection of the environment
GRI 3: Material Topics 2021
3-3
Management of material topics
142-147, 149, 
152-158
GRI 301: Materials (2016)
301-1
Materials used by weight or volume
153-154

163
GRI 
Standard/
Other 
source
Disclosure
Page No./
Notes
Omissions
GRI 302: Energy (2016)
302-1
Energy consumption within the organization
147
302-2
Energy consumption outside of the organization
148
GRI 305: Emissions (2016)
305-1
Direct (Scope 1) GHG emissions 
152
305-2
Energy indirect (Scope 2) GHG emissions 
152
305-3
Other indirect (Scope 3) GHG emissions
153
Indicators according to Annex IV Regulation 1221/2009/EC (EMAS)
Letter C, 
point 2. 
a) i) c i) d)
Direct energy consumption, total and per employee
149
Letter C, 
point 2. 
a) ii) c ii ) d)
Annual mass flow of main materials used, total and per em­
ployee
153-154
Letter C, 
point 2. 
a) iii) c iii) d)
Annual water consumption, total and per employee
156
Letter C, 
point 2. 
a) iv) c iv) d)
Annual waste production, total and per employee
155
Letter C, 
point 2. 
a) iv) c iv) d)
Annual production of hazardous waste, total and per em­
ployee
No hazardous 
waste was pro­
duced in the 
three-year peri­
od 2020-2022
Letter C, 
point 2. 
a) v) c v) d)
Use of land, total and per employee
157
Letter C, 
point 2. 
a) vi) c vi) d)
Annual atmospheric emissions, total and per employee
152
Other GRI disclosures not related to material topics
GRI 207: Tax (2019)
207-1
Approach to tax
106-107
207-2
Tax governance, control, and risk management
107
207-3
Stakeholder engagement and management
of concerns related to tax
107
207-4
Country-by-country reporting
108
GRI 402: Labor/Management Relations (2016)
402-1
Minimum notice periods regarding operational changes
128

164
GRI 
Standard/
Other 
source
Disclosure
Page No./
Notes
Omissions
GRI 403: Occupational Health and Safety (2018)
403-1
Occupational health and safety management system
129
403-2
Hazard identification, risk assessment, and incident investi­
gation
129-130
403-3
Occupational health services
130
403-4
Worker participation, consultation, and communication on oc­
cupational health and safety
130
403-5
Worker training on occupational health and safety
121, 130
403-6
Promotion of worker health
128, 130
403-7
Prevention and mitigation of occupational health and safety 
impacts directly linked by business relationships
130

165
Ancona Bari Bergamo 
Bologna Bolzano Brescia  
Catania Como Firenze Genova  
Lecce Milano Napoli Novara  
Padova Palermo Parma Perugia 
Pescara Roma Torino Treviso  
Trieste Varese Verona  
Società per azioni 
Capitale sociale 
Euro 10.415.500,00 i.v. 
Registro Imprese Milano Monza Brianza Lodi 
e Codice Fiscale N. 00709600159 
R.E.A. Milano N. 512867 
Partita IVA 00709600159 
VAT number IT00709600159 
Sede legale: Via Vittor Pisani, 25 
20124 Milano MI ITALIA 
KPMG S.p.A. è una società per azioni di diritto italiano e fa parte del  
network KPMG di entità indipendenti affiliate a KPMG International 
Limited, società di diritto inglese. 
KPMG S.p.A. 
Revisione e organizzazione contabile 
Via Vittor Pisani, 25 
20124 MILANO MI 
Telefono +39 02 6763.1 
Email it-fmauditaly@kpmg.it  
PEC kpmgspa@pec.kpmg.it 
(This independent auditors’ report has been translated into English solely for the convenience of 
international readers. Accordingly, only the original Italian version is authoritative.) 
Independent auditors’ report on the consolidated non-financial 
statement pursuant to article 3.10 of Legislative decree no. 254 of 30 
December 2016 and article 5 of the Consob Regulation adopted with 
Resolution no. 20267 of 18 January 2018 
To the board of directors of FinecoBank S.p.A. 
Pursuant to article 3.10 of Legislative decree no. 254 of 30 December 2016 (the “decree”) and article 5 of 
the Consob (the Italian Commission for listed companies and the stock exchange) Regulation adopted 
with Resolution no. 20267 of 18 January 2018, we have been engaged to perform a limited assurance 
engagement on the 2022 consolidated non-financial statement of the FinecoBank Group (the “group”) 
prepared in accordance with article 4 of the decree and approved by the board of directors on 14 March 
2023 (the “NFS”). 
Our procedures did not cover the information set out in section 5.5 “Environmentally sustainable assets”  
of the NFS required by article 8 of Regulation (EU) 852 of 18 June 2020. 
Responsibilities of the directors and board of statutory auditors (“Collegio Sindacale”) 
of FinecoBank S.p.A. (the “parent”) for the NFS 
The directors are responsible for the preparation of an NFS in accordance with articles 3 and 4 of the 
decree and the “Global Reporting Initiative Sustainability Reporting Standards” issued by GRI - Global 
Reporting Initiative (the “GRI Standards”), which they have identified as the reporting standards. 
The directors are also responsible, within the terms established by the Italian law, for such internal 
control as they determine is necessary to enable the preparation of an NFS that is free from material 
misstatement, whether due to fraud or error.  
Moreover, the directors are responsible for the identification of the content of the NFS, considering the 
aspects indicated in article 3.1 of the decree and the group’s business and characteristics, to the extent 
necessary to enable an understanding of the group’s business, performance, results and the impacts it 
generates.  
The directors’ responsibility also includes the design of an internal model for the management and 
organisation of the group’s activities, as well as, with reference to the aspects identified and disclosed in 
the NFS, the group’s policies and the identification and management of the risks generated or borne. 
The Collegio Sindacale is responsible for overseeing, within the terms established by the Italian law, 
compliance with the decree’s provisions.

166
 
2 
FinecoBank Group 
Independent auditors’ report 
31 December 2022 
Auditors’ independence and quality control 
We are independent in compliance with the independence and all other ethical requirements of the 
International Code of Ethics for Professional Accountants (including International Independence 
Standards, the IESBA Code) issued by the International Ethics Standards Board for Accountants, which 
is founded on fundamental principles of integrity, objectivity, professional competence and due care, 
confidentiality and professional behaviour. Our company applies International Standard on Quality 
Control 1 (ISQC Italia 1) and, accordingly, maintains a system of quality control including documented 
policies and procedures regarding compliance with ethical requirements, professional standards and 
applicable legal and regulatory requirements. 
Auditors’ responsibility 
Our responsibility is to express a conclusion, based on the procedures performed, about the compliance 
of the NFS with the requirements of the decree and the GRI Standards. We carried out our work in 
accordance with the criteria established by “International Standard on Assurance Engagements 3000 
(revised) - Assurance Engagements other than Audits or Reviews of Historical Financial Information” 
(“ISAE 3000 revised”), issued by the International Auditing and Assurance Standards Board applicable to 
limited assurance engagements. This standard requires that we plan and perform the engagement to 
obtain limited assurance about whether the NFS is free from material misstatement. A limited assurance 
engagement is less in scope than a reasonable assurance engagement carried out in accordance with 
ISAE 3000 revised, and consequently does not enable us to obtain assurance that we would become 
aware of all significant matters and events that might be identified in a reasonable assurance 
engagement. 
The procedures we performed on the NFS are based on our professional judgement and include 
inquiries, primarily of the parent’s personnel responsible for the preparation of the information presented 
in the NFS, documental analyses, recalculations and other evidence gathering procedures, as 
appropriate. 
Specifically, we performed the following procedures: 
1. Analysing the material aspects based on the group’s business and characteristics disclosed in the 
NFS, in order to assess the reasonableness of the identification process adopted on the basis of the 
provisions of article 3 of the decree and taking into account the reporting standards applied. 
2. Analysing and assessing the identification criteria for the reporting scope, in order to check their 
compliance with the decree.  
3. Comparing the financial disclosures presented in the NFS with those included in the group’s 
consolidated financial statements. 
4. Gaining an understanding of the following: 
- 
the group’s business management and organisational model, with reference to the management 
of the aspects set out in article 3 of the decree; 
- 
the entity’s policies in connection with the aspects set out in article 3 of the decree, the achieved 
results and the related key performance indicators; 
- 
the main risks generated or borne in connection with the aspects set out in article 3 of the decree. 
Moreover, we checked the above against the disclosures presented in the NFS and carried out the 
procedures described in point 5.a).

167
3 
FinecoBank Group 
Independent auditors’ report 
31 December 2022 
5.
Understanding the processes underlying the generation, recording and management of the
significant qualitative and quantitative information disclosed in the NFS.
Specifically, we held interviews and discussions with the parent’s management personnel. We also
performed selected procedures on documentation to gather information on the processes and
procedures used to gather, combine, process and transmit non-financial data and information to the
office that prepares the NFS.
Furthermore, with respect to significant information, considering the group’s business and
characteristics:
-
at group and subsidiaries level
a)
we held interviews and obtained supporting documentation to check the qualitative
information presented in the NFS and, specifically, the business model, the policies applied
and main risks for consistency with available evidence,
b)
we carried out analytical and limited procedures to check, on a sample basis, the correct
aggregation of data in the quantitative information;
-
through remote meetings, we held discussions with the parent’s management, which we have
selected on the basis of its business, contribution to the key performance indicators at
consolidated level and location, to obtain documentary evidence supporting the correct
application of the procedures and methods used to calculate the indicators.
Conclusion 
Based on the procedures performed, nothing has come to our attention that causes us to believe that the 
2022 consolidated non-financial statement of the FinecoBank Group has not been prepared, in all 
material respects, in accordance with the requirements of articles 3 and 4 of the decree and the GRI 
Standards. 
Our conclusion does not extend to the information set out in section 5.5 “Environmentally sustainable 
assets” of the NFS required by article 8 of Regulation (EU) 852 of 18 June 2020. 
Other matters 
The NFS presents the corresponding figures included in the 2021 consolidated non-financial statement 
for comparative purposes, on which other auditors performed a limited assurance engagement and 
expressed an unqualified conclusion on 31 March 2022. 
Milan, 23 March 2023
KPMG S.p.A. 
(signed on the original) 
Roberto Spiller 
Director of Audit

168
ANNEX I – Principles for Responsible Banking - Reporting 
e Self-Assessment Template
Principle 1: Alignment
We will align our business strategy to be consistent with and contribute to individuals’ needs 
and society’s goals, as expressed in the Sustainable Development Goals, the Paris Climate 
Agreement and relevant national and regional frameworks.
Business model
Describe (high-level) the Bank’s business model, including the main customer segments served, types of 
products and services provided, the main sectors and types of activities across the main geographies in 
which your bank operates or provides products and services. Please also quantify the information by di­
sclosing e.g. the distribution of the Bank’s portfolio (%) in terms of geographies, segments (i.e. by balance 
sheet and/or off-balance sheet) or by disclosing the number of customers and customers served.
Links and references
1.2.Who we are, strategy and business model (pages 11-16)
Strategy Alignment
Does your corporate strategy identify and reflect sustainability as strategic priority/ies for your bank?
 Yes
☐ No
Please describe how your bank has aligned and/or is planning to align its strategy to be consistent with the 
Sustainable Development Goals (SDGs), the Paris Climate Agreement, and relevant national and regional 
frameworks.
Does your bank also reference any of the following frameworks or sustainability regulatory reporting 
requirements in its strategic priorities or policies to implement these?
 UN Guiding Principles on Business and Human Rights 
 International Labour Organization fundamental conventions
 UN Global Compact
☐ UN Declaration on the Rights of Indigenous Peoples
 Any applicable regulatory reporting requirements on environmental risk assessments, e.g. on climate risk 
- please specify which ones: FinecoBank Group Public Disclosure – Pillar III115
 Any applicable regulatory reporting requirements on social risk assessments, e.g. on modern slavery - 
please specify which ones : FinecoBank Group Public Disclosure – Pillar III
☐ None of the above
Links and references
2022 Consolidated Non-Financial Statement:
1.3 Sustainable Development Goals and commitments made (pages 17-27)
FinecoBank Group Public Disclosure – Pillar III as at 31/12/2022:
Disclosure of environmental, social and governance risks (pages 109-131)
115	Article 449a of Regulation (EU) No 575/2013 of 26 June 2013 on prudential requirements for credit institutions and investment firms and amending Regulation (EU) No 
648/2012.

169
Principle 2: Impact and Target Setting
We will continuously increase our positive impacts while reducing the negative impacts on, 
and managing the risks to, people and environment resulting from our activities, products and 
services. To this end, we will set and publish targets where we can have the most significant 
impacts.
a. Impact Analysis (Key Step 1)
Show that your bank has performed an impact analysis of its portfolio/s to identify its most significant impact 
areas and determine priority areas for target-setting. The impact analysis shall be updated regularly and fulfil 
the following requirements/elements (a-d):  
a) Scope: What is the scope of your bank’s impact analysis? Please describe which parts of the bank’s core 
business areas, products/services across the main geographies that the bank operates in (as described 
under 1.1) have been considered in the impact analysis. Please also describe which areas have not yet been 
included, and why.
Response
The Impact Analysis takes into account the business areas that 
make up the Bank’s business model, starting with the Banking & 
Credit and Investing areas, which together account for 80% of the 
Group’s revenues in 2022. The Brokerage area will be examined 
later, as it is the component with the lowest percentage weight in 
terms of revenue among the business areas. 
Links and references
2022 Consolidated Non-Financial 
Statement:
1.2.Who we are, strategy and busi­
ness model (pages 11-16)
2022 Results presentation: 
https://images.finecobank.com/
docs/pdf/pub/corporate/investors/
FY22-Results.pdf (page 30)
b) Portfolio composition: Has your bank considered the composition of its portfolio (in %) in the analysis? 
Please provide proportional composition your portfolio globally and per geographical scope:
i) by sectors & industries116 for business, corporate and investment banking portfolios (i.e. sector exposure 
or industry breakdown in %), and/or 
ii) by products & services and by types of customers for consumer and retail banking portfolios. 
If your bank has taken another approach to determine the bank’s scale of exposure, please elaborate, to 
show how you have considered where the bank’s core business/major activities lie in terms of industries or 
sectors.
Response
The Impact Analysis considers the composition of the Bank’s 
portfolio. As described in section 1.2 of this NFS, FinecoBank is a 
retail bank, with 93% of customers belonging to the retail segment 
in 2022. The company strategy does not include the provision of 
credit to corporate clients. 
Links and references
1.2.Who we are, strategy and busi­
ness model (pages 11-16)
116	 “Key sectors” relative to different impact areas, i.e. those sectors whose positive and negative impacts are particularly strong, are particularly relevant here.

170
c) Context: What are the main challenges and priorities related to sustainable development in the main 
countries/regions in which your bank and/or your clients operate?117 Please describe how these have been 
considered, including what stakeholders you have engaged to help inform this element of the impact anal­
ysis.
This step aims to put your bank’s portfolio impacts into the context of society’s needs.
Response
The Impact Analysis takes into account the context in which the Bank 
operates, particularly with respect to its sustainability challenges 
and priorities. The goals set in the ESG Plan 2020-2023 are related 
to the UN Sustainable Development Goals and the Italian National 
Sustainable Development Strategy. For example, the development 
of credit products with environmental value, including the green 
mortgages, is linked to the national objective of “Increasing energy 
efficiency and energy production from renewable sources”. 
Moreover, within the scope of the Materiality Analysis described 
in sections 2.1 and 2.2 of this NFS, the potentially relevant sustain­
ability topics emerging from the context, identified through desk 
research, were investigated through engagement with the priority 
stakeholders, by means of a survey. The results of the Materiality 
Analysis provide input to the Impact Analysis.
Links and references
1.3 Sustainable Development Goals 
and commitments subscribed (pages 
17-27)
2.1 Stakeholder engagement (pages 
34-38)
2.2 Material topics (pages 39-41)
Based on these first 3 elements of an impact analysis, what positive and negative impact areas has your 
bank identified? Which (at least two) significant impact areas did you prioritize to pursue your target setting 
strategy (see 2.2)?118 Please disclose.
Response
The Impact Analysis is underway and will be completed during 2023, also based on the drafting of the new 
Set of ESG Goals. 
d) For these (min. two prioritized impact areas): Performance measurement: Has your bank identified which 
sectors & industries as well as types of customers financed or invested in are causing the strongest actual 
positive or negative impacts? Please describe how you assessed the performance of these, using appropri­
ate indicators related to significant impact areas that apply to your bank’s context. 
In determining priority areas for target-setting among its areas of most significant impact, you should consid­
er the bank’s current performance levels, i.e. qualitative and/or quantitative indicators and/or proxies of the 
social, economic and environmental impacts resulting from the bank’s activities and provision of products 
and services. If you have identified climate and/or financial health&inclusion as your most significant impact 
areas, please also refer to the applicable indicators in the Annex [of the PRB Template]. 
If your bank has taken another approach to assess the intensity of impact resulting from the bank’s activities 
and provision of products and services, please describe this. 
The outcome of this step will then also provide the baseline (incl. indicators) you can use for setting targets 
in two areas of most significant impact.
Response
The Impact Analysis is underway and will be completed during 2023, also based on the drafting of the new 
Set of ESG Goals.
117	Global priorities might alternatively be considered for banks with highly diversified and international portfolios.
118	To prioritize the areas of most significant impact, a qualitative overlay to the quantitative analysis as described in a), b) and c) will be important, e.g. through stakeholder 
engagement and further geographic contextualisation.

171
Self-assessment summary:
Which of the following components of impact analysis has your bank completed, in order to identify 
the areas in which your bank has its most significant (potential) positive and negative impacts?119?
Scope: 	 	
	
	
 Yes	
	
☐ In progress 	
	
☐ No 
Portfolio composition:   	
   	
 Yes       	
☐ In progress 	
	
☐ No  
Context: 	
	
	
☐ Yes 	
	
 In progress	
	
☐ No  
Performance measurement:  	
☐ Yes	
	
 In progress	
	
☐ No  
Which most significant impact areas have you identified for your bank, as a result of the impact 
analysis? 
In progress. 
How recent is the data used for and disclosed in the impact analysis?
 Up to 6 months prior to publication
☐ Up to 12 months prior to publication 
☐ Up to 18 months prior to publication 
☐ More than 18 months prior to publication
Open text field to describe potential challenges, aspects not covered by the above etc.: (option)
2.2	
Target Setting (Key Step 2)
Show that your bank has set and published a minimum of two targets which address at least two different 
areas of most significant impact that you identified in your impact analysis. 
The targets120 have to be Specific, Measurable (qualitative or quantitative), Achievable, Relevant and Time-
bound (SMART121). Please disclose the following elements of target setting (a-d), for each target separately:
a)	 Alignment: which international, regional or national policy frameworks to align your bank’s portfolio 
with122 have you identified as relevant? Show that the selected indicators and targets are linked to and 
drive alignment with and greater contribution to appropriate Sustainable Development Goals, the goals 
of the Paris Agreement, and other relevant international, national or regional frameworks. 
You can build upon the context items under 2.1.
Response
The Impact Analysis and target setting on the most significant impact areas are in progress and will be com­
pleted during 2023, also based on the drafting of the new Set of ESG Goals.
119	  You can respond “Yes” to a question if you have completed one of the described steps, e.g. the initial impact analysis has been carried out, a pilot has been conducted.
120	 Operational targets (relating to for example water consumption in office buildings, gender equality on the bank’s management board or business-trip related greenhouse 
gas emissions) are not in scope of the PRB.
121	 Specific, Measurable, Achievable, Relevant, Time-bound (SMART).
122	  Your bank should consider the main challenges and priorities in terms of sustainable development in your main country/ies of operation for the purpose of setting targets. 
These can be found in National Development Plans and strategies, international goals such as the SDGs or the Paris Climate Agreement, and regional frameworks. Aligning 
means there should be a clear link between the bank’s targets and these frameworks and priorities, therefore showing how the target supports and drives contributions to 
the national and global goals.

172
b)	Baseline: Baseline: Have you determined a baseline for selected indicators and assessed the current 
level of alignment? Please disclose the indicators used as well as the year of the baseline.
You can build upon the performance measurement undertaken in 2.1 to determine the baseline for your 
target.
A package of indicators has been developed for climate change mitigation and financial health & inclusion 
to guide and support banks in their target setting and implementation journey. The overview of indicators 
can be found in the Annex of this template.
If your bank has prioritized climate mitigation and/or financial health & inclusion as (one of) your most sig-
nificant impact areas, it is strongly recommended to report on the indicators in the Annex, using a summary 
table such as the one below, including the impact area, all relevant indicators and the corresponding indi-
cator codes:
Impact area
Indicator code
 Response
Climate change 
mitigation
 ...
 ...
 ...
Impact area
Indicator code
  Response
Financial health 
& inclusione
 ...
 ...
 ...
If you have identified other and/or additional indicators that are relevant for determining the baseline and 
assessing the level of alignment with the impact-driven targets, please indicate them.
Response
The Impact Analysis and target setting on the most significant impact areas are in progress and will be com­
pleted during 2023, also based on the drafting of the new Set of ESG Goals.
c)	SMART targets (including key performance indicators, KPIs123): Please disclose the targets for your first 
and your second area of most significant impact, if already in place (as well as further impact areas, if in 
place). Which KPIs are you using to monitor progress towards reaching the target? Please disclose.
Response
The Impact Analysis and target setting on the most significant impact areas are in progress and will be com­
pleted during 2023, also based on the drafting of the new Set of ESG Goals.
d)	Action Plan: which actions including milestones have you defined to meet the set targets? Please 
describe. 
Please also show that your bank has analysed and acknowledged significant (potential) indirect impacts 
of the set targets within the impact area or on other impact areas and that it has set out relevant actions to 
avoid, mitigate, or compensate potential negative impacts.
Response
The Impact Analysis and target setting on the most significant impact areas are in progress and will be com­
pleted during 2023, also based on the drafting of the new Set of ESG Goals.
123	  Key Performance Indicators are chosen indicators by the bank for the purpose of monitoring progress towards targets.

173
Self-assessment summary:
Which of the following components of target setting in line with the PRB requirements has your bank com­
pleted or is currently in a process of assessing:
First area of most significant im­
pact: (please name it)
Second area of most significant 
impact: (please name it)
Alignment
☐ Yes
 In progress
☐ No
☐ Yes
 In progress
☐ No
Baseline 
☐ Yes
 In progress
☐ No
☐ Yes
  In progress
☐ No
SMART Targets 
☐ Yes
 In progress
☐ No
☐ Yes
 In progress
☐ No
Action Plan
☐ Yes
 In progress
☐ No
☐ Yes
 In progress
☐ No
2.3	
Target implementation and monitoring (Key Step 2)
For each target separately:
Show that your bank has implemented the actions it had previously defined to meet the set target. 
Report on your bank’s progress since the last report towards achieving each of the set targets and the im­
pact your progress resulted in, using the indicators and KPIs to monitor progress you have defined under 
2.2.
Or, in case of changes to implementation plans (relevant for 2nd and subsequent reports only): de­
scribe the potential changes (changes to priority impact areas, changes to indicators, acceleration/review 
of targets, introduction of new milestones or revisions of action plans) and explain why those changes 
have become necessary.
Response
The Impact Analysis and target setting on the most significant impact areas are in progress and will be com­
pleted during 2023, also based on the drafting of the new Set of ESG Goals.

174
Principle 3: Clients and Customers 
We will work responsibly with our customers and our customers to encourage sustainable 
practices and enable economic activities that create shared prosperity for current and future 
generations.
3.1 Customer engagement 
Does your bank have a policy or engagement process with customers and customers in place to encour­
age sustainable practices?
 Yes	
	
☐ In progress	
	
☐ No
Does your bank have a policy for sectors in which you have identified the highest (potential) negative im­
pacts?
 Yes      	
☐ In progress	
	
☐ No
Describe how your bank has worked with and/or is planning to work with its customers and customers to 
encourage sustainable practices and enable sustainable economic activities124. It should include information 
on relevant policies, actions planned/implemented to support customers’ transition, selected indicators on 
customer engagement and, where possible, the impacts achieved.
This should be based on and in line with the impact analysis, target-setting and action plans put in place 
by the bank (see P2).
Links and references
3.2 Responsible Products and Investments (pages 49-54)
3.2	
Business opportunities
Describe what strategic business opportunities in relation to the increase of positive and the reduction of 
negative impacts your bank has identified and/or how you have worked on these in the reporting period. 
Provide information on existing products and services, information on sustainable products developed in 
terms of value (USD or local currency) and/or as a % of your portfolio, and which SDGs or impact areas you 
are striving to make a positive impact on (e.g. green mortgages – climate, social bonds – financial inclusion, 
etc.)
Links and references
3.2 Responsible Products and Investments (pages 49-54)
124	  Sustainable economic activities promote the transition to a low-carbon, more resource-efficient and sustainable economy.

175
Principle 4: Stakeholders
We will proactively and responsibly consult, engage and partner with relevant stakeholders 
to achieve society’s goals.
4.1 Stakeholder identification and consultation
Does your bank have a process to identify and regularly consult, engage, collaborate and partner with 
stakeholders (or stakeholder groups125) you have identified as relevant in relation to the impact analysis and 
target setting process?
 Yes	
	
☐ In progress	
	
☐ No
Please describe which stakeholders (or groups/types of stakeholders) you have identified, consulted, enga­
ged, collaborated or partnered with for the purpose of implementing the Principles and improving your ban­
k’s impacts. This should include a high-level overview of how your bank has identified relevant stakeholders, 
what issues were addressed/results achieved and how they fed into the action planning process.
Links and references
2.1. Stakeholder engagement (pages 34-38)
2.2 Material topics (pages 39-41)
Principle 5: Governance & Culture
We will implement our commitment to these Principles through effective governance and a 
culture of responsible banking.
5.1 Governance Structure for Implementation of the Principles
Does your bank have a governance system in place that incorporates the PRB?
 Yes	
	
☐ In progress	
	
☐ No
Please describe the relevant governance structures, policies and procedures your bank has in place/is 
planning to put in place to manage significant positive and negative (potential) impacts and support the 
effective implementation of the Principles. This includes information about:
·	 - which committee has responsibility over the sustainability strategy as well as targets approval and 
monitoring (including information about the highest level of governance the PRB is subjected to),
·	 - details about the chair of the committee and the process and frequency for the board having over­
sight of PRB implementation (including remedial action in the event of targets or milestones not being 
achieved or unexpected negative impacts being detected), as well as
·	 remuneration practices linked to sustainability targets.
Response
FinecoBank has a sustainability governance structure, described in section 5.1 
of this NFS. The sustainability aspects subject to supervision, approval and mon­
itoring by the governance bodies described include the commitments made 
through the subscription to PRBs.  
Links and references
5.1 Governance System 
(page 66-75)
125	 Such as regulators, investors, governments, suppliers, customers and customers, academia, civil society institutions, communities, representatives of indigenous population 
and non-profit organisations.

176
5.2 Promoting a culture of responsible banking:
Describe the initiatives and measures of your bank to foster a culture of responsible banking among its 
employees (e.g., capacity building, e-learning, sustainability trainings for customer-facing roles, inclusion 
in remuneration structures and performance management and leadership communication, among others). 
Links and references
5.1 Governance System (page 66-75)
6.2 Compliance culture (page 99-100)
7. Our people (page 111)
7.3 Promoting and developing human resources (page 121-126) 
5. Policies and due diligence processes
Does your bank have policies in place that address environmental and social risks within your portfolio?126 
Please describe.
Please describe what due diligence processes your banks has installed to identify and manage environmental 
and social risks associated with your portfolio. This can include aspects such as identification of significant/
salient risks, environmental and social risks mitigation and definition of action plans, monitoring and reporting 
on risks and any existing grievance mechanism, as well as the governance structures you have in place to 
oversee these risks.
Links and references
2022 Consolidated Non-Financial Statement
5.1 Management of ESG risks (pages 76-88)
FinecoBank Group Public Disclosure – Pillar III as at 31/12/2022
Disclosure of environmental, social and governance risks (pages 109-131)
Self-assessment summary:
Does the CEO or other C-suite officers have regular oversight over the implementation of the Principles 
through the bank’s governance system?
 Yes	 	
	
	
	
☐ No
Does the governance system entail structures to oversee PRB implementation (e.g. incl. impact analysis 
and target setting, actions to achieve these targets and processes of remedial action in the event 
targets/milestones are not achieved or unexpected neg. impacts are detected)?
 Yes	 	
	
	
	
☐ No
Does your bank have measures in place to promote a culture of sustainability among employees (as 
described in 5.2)?
 Yes     	
☐ In progress	
	
☐ No
126	 Applicable examples of types of policies are: exclusion policies for certain sectors/activities; zero-deforestation policies; zerotolerance policies; gender-related policies; 
social due diligence policies; stakeholder engagement policies; whistleblower policies, etc.

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Principle 6: Transparency & Accountability
We will periodically review our individual and collective implementation of these Principles 
and be transparent about and accountable for our positive and negative impacts and our 
contribution to society’s goals.
Assurance
Has this publicly disclosed information on your PRB commitments been assured by an independent 
assurer?
☐  Yes	
	
 Partially	
	
☐ No
If applicable, please include the link or description of the assurance statement
Response
The information contained in this NFS referred to in 
the PRB Template is subject to limited assurance by 
KPMG S.p.A. The compilation of this PRB Template is 
not subject to limited assurance. 
Links and references
External Auditors’ Report (page 165) 
6.2 Reporting on other frameworks
Does your bank disclose sustainability information in any of the listed below standards and frameworks?
	GRI
☐	 SASB
	CDP 
☐	 IFRS SSustainability Disclosure Standards (to be published)
☐	 TCFD
	Other: EMAS Regulation No. 1221/2009/EC
Links and references
2022 Consolidated Non-Financial Statement:
Methodological note (page 6-7) 
GRI Content Index (page 159-164)
CDP Climate Change Questionnaire:
https://www.cdp.net/en/responses
6.3 Outlook 
What are the next steps your bank will undertake in next 12 month-reporting period (particularly on
impact analysis127, target setting128 and governance structure for implementing the PRB)? Please describe 
briefly
Response
The next steps are the completion of the Impact Analysis and the subsequent identification of
impact areas and setting of their targets.
127	 For example outlining plans for increasing the scope by including areas that have not yet been covered, or planned steps in terms of portfolio composition, context and 
performance measurement.
128 For example outlining plans for baseline measurement, developing targets for (more) impact areas, setting interim targets, developing action plans etc.

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ANNEX II - SDGs and related relevant targets
Below are the 12 of the 169 targets of the 17 Sustainable Development Goals (SDGs) considered most relevant 
on the basis of their commonalities with the material topics and objectives of the Sustainability Goals Plan to be 
pursued in the years 2020-2023..
SDG
TARGET
1.4 By 2030, ensure that all men and women, particularly the poor and vulnerable, have equal 
rights to economic resources, as well as access to basic services, ownership and control over 
land and other forms of property, inheritance, natural resources, appropriate new technologies 
and financial services, including micro-finance.
4.4 By 2030, substantially increase the number of youth and adults who have relevant skills, 
including technical and vocational skills, for employment, decent jobs and entrepreneurship
5.1 End all forms of discrimination against all women and girls everywhere
5.5 Ensure women’s full and effective participation and equal opportunities for leadership at all 
levels of decision-making in political, economic and public life
7.3 By 2030, double the global rate of improvement in energy efficiency
8.5 By 2030, achieve full and productive employment and decent work for all women and 
men, including for young people and persons with disabilities, and equal pay for work of equal 
value
8.10 Strengthen the capacity of domestic financial institutions to encourage and expand access 
to banking, insurance and financial services for all
10.4 Adopt policies, especially fiscal, wage and social protection policies, and progressively 
achieve greater equality
12.2 By 2030, achieve the sustainable management and efficient use of natural resources
12.6 Encourage companies, especially large and transnational companies, to adopt sustainable 
practices and to integrate sustainability information into their reporting cycle
13.2 Integrate climate change measures into national policies, strategies and planning
16.b Promote and enforce non-discriminatory laws and policies for sustainable development

179
ANNEX III – ORGANISATIONAL CHART
Chief People 
Officer Dept
People 
Management & 
Development
Total Reward & 
People Analytics
Trade Union, 
Labour & 
People Care
People Learning 
& Becoming PFA
Compliance 
Dept
Ethics & 
Compliance 
Culture
Management
Secretary’s Office
Regulatory Affairs 
& Resolution Unit 
Identity 
& Communications
Transparency 
& Customer 
Protection 
Investment 
Services
DPO Outsourcing 
& ICT Compliance
Risk Assessment 
& Controls
Antimoney-
Launding 
Function
Network Controls, 
Monitoring and 
Service Dept
Network Controls
Commercial 
Monitoring
Commissioning & 
Network Assistance
Legal & Corporate 
Affairs Dept
Corporate Affairs 
& Financial Legal 
Advice
Legal Advice & 
Legal Network PFA
Complaints & 
Litigations
Chief Lending 
Officer Dept
Chairman
BOARD OF DIRECTOR
CHIEF EXECUTIVE 
OFFICER & GENERAL 
MANAGER
Credit Lines & 
Collection
Mortgages & 
Loans
Credit Monitoring

180
Chief Risk 
Officer Dept
Internal 
Validation
Operational & 
Reputational Risk
Credit Risk & 
Internal Capital
Market & 
Liquidity Risk
Risk Integration 
& Reporting
Chief Financial 
Officier Dept
Accounting &
Regulatory 
Reporting Dept
Planning
Management 
Control
Tax Affairs & 
Advisory
Finance
Investor 
Relations
Sustainability
Deputy PFA e Private 
Banking Dept
Network
PFA Development & 
Support Dept
Regional Network 
PFA Referent
Private Banking
Advisory
Network PFA
Deputy GM Global 
Business Dept
Marketing, Advertising 
& Events Dept
Products
& Services Dept
Exchange Traded &
OTC Markets
Advisory, Third Party 
& Private Banking 
Solutions Dept
Deputy GM Global 
Banking Service 
Dept
Precurement Office
ICT & Security Offi­
ce Dept (CIO)
Customer 
Relationship Mngt 
Dept
Organization & 
Bank Operations 
Dept
Financial 
Operations Dept
Real Estate
Genaral Services
PFA Operational 
Monitoring & 
Private Bankers
Quality e remote 
Controls
Processes Audit
Network Audit
 Internal Audit Dept

182
FinecoBank Banca Fineco S.p.A. 
in abbreviated form “FinecoBank S.p.A.”, or “Banca Fineco S.p.A.” or “Fineco Banca S.p.A.”. 
Registered Office Piazza Durante 11, Milan 20131 
Headquarters Via Rivoluzione d’Ottobre 16, Reggio Emilia 42123
www.finecobank.com
e-mail: sostenibilita@fineco.it
This Non Financial Statement has been prepared by the Sustainability Function – CFO 
Department of FinecoBank S.p.A. 
Special thanks to all Group’s Departments and Offices for their support  in drawing up this 
document. 
Layout and graphics: Bertani & C. Srl (Cavriago – RE)
Images: Fineco, www.gettyimages.it
Typeset and print: Bertani & C. Srl (Cavriago – RE)
Translation: STAR7 S.p.A.

183
finecobank.com