Sustainability Report 2012 - Generali Versicherung AG

the best companies in relation to the corporate socialresponsibility and sustainable development policies adopted,and in support, through private equity initiatives, of certaincompanies operating in the renewable energy and innovationsector.For more in-depth information on these aspects, see thechapter Clients, section Socially responsible investmentproducts, and the chapter Environment and Climate Change,section Climate change risks and opportunities.In 2012, through the Council on Ethics for Investments, thededicated company body composed of managers of thedepartments most involved in investments and managersof the Corporate Social Responsibility department, inaddition to two external members from the academic world,the Group successfully evaluated the re-admission of apreviously excluded company to the investment universe,given the reasons for the exclusion no longer existed, andproposed the exclusion of a new company, as the dialogueentered into did not produce the desired outcome.In addition, through Generali Investments, in-depth analyseswere conducted on a sample of companies belonging to thesectors considered at risk from a sustainability point of view,such as those involved in the extraction of oil from bituminoussands and companies operating in the tobacco industry. Afterevaluating the general consistency of the conduct observedwith the Group’s ethics criteria, dialogue was entered intowith those entities that did not meet the criteria.The list of companies considered unethical by the Groupcurrently contains about thirty companies.At the end of 2012, unethical investments in the portfoliototalled around 200 thousand euros.The Environmental Policy of the Generali Group,approved by the Parent Company’s Board of Directors on31 July 2009, has been defined as part of the project for theintroduction of a Group Environmental Management System(EMS), launched in 2009 and still being implemented.The document is a statement of Generali’s commitmentto protecting the environment and contains the guidingprinciples which must be complied with in the managementof all significant environmental aspects, in order to ensure thatcompany development and protection of the environmentare compatible.The Environmental Policy also defines the Generali objectivesand commitments in this respect. The Group aims tocontribute positively to sustainable development throughmanagement decisions geared towards a reduction in thedirect and indirect environmental impacts of its business.The chapter Environment and Climate Change in thisdocument provides insights on the subject.The Environmental Policy of the GeneraliGroup is available on the websitewww.generali.com/SustainabilityThe Generali Group has prepared and adopted varioustools for preventing and counteracting conduct that is notin keeping with the principles of correctness, legality andtransparency.In Italy, the Organisation and Management Model wasadopted, targeted at preventing the possible commission ofthe offences envisaged by Legislative Decree no. 231/2001by employees, agents and anyone having relations with theGroup, hence helping companies to avoid incurring anyadministrative liability.In order to acknowledge the legislative amendmentsmade recently, and the organisational changes whichoccurred within the Group, in view of a constant process ofimprovement, a series of activities were launched in 2012,targeted at updating the Model, by making its contents andstructure more consistent with the actual operating situation.The document is composed of a General Section whichoutlines, among other things, the Supervisory Body incharge of overseeing the functioning and observance of theModel, as well handling its updating, and various SpecialSections, containing legislative analyses of the offences citedby the Decree and the main principles of conduct on whichbehaviour in all areas potentially at the risk of offence mustbe based. Each of these sections identifies: the companydepartments involved, the so-called sensitive activities,the specific offences theoretically possible, the associatedmethods of commission or the conduct instrumental in thecommission of the offences, the preventive controls andthe relevant duties of the Supervisory Body.For more details on the Organisation andManagement Model, see the CorporateGovernance and Share Ownership Report2012, available on the websitewww.generali.com/GovernanceMartha Argerich Project, Switzerlandthe group | 33