The distribution process

2009 saw the full application of the Bank’s organisational and management model for donations, defined a year earlier with the aim of providing an increasingly efficient response to the demands and needs of the community in which Intesa Sanpaolo operates, consistent with the principles of the Group’s Code of Ethics and with related regulations envisaged in the Articles of Association.
Efforts concentrated on implementation of the Regulation governing the Fund for charitable, social and cultural contributions, and definition of a distribution plan and distribution processes at both central and local level through the preparation of special operating guidelines.
In particular, the first operating guidelines governed the Fund’s planning through definition of the distribution plan. In fact, for the first time, in 2009 the Supervisory Board defined and approved an itemised distribution plan with guidelines on management of the demand for contributions during the year.
The Plan is based on a preliminary analysis that takes into account the consolidated features of the Bank’s donations activities to identify the specific footprint, and the specific role that Intesa Sanpaolo intends to play, through the Fund, in the complex scenario of community support activities at national and international level. In this respect, the plan offers guidance of a qualitative and quantitative nature.
In qualitative terms, the Plan is based on the key roles of the individual and solidarity, giving preference to projects with a specific social impact and strongly orientated towards being a complete gift, in such a way that the Bank’s charity donation does not call for any form of return in terms of either image or commercial aspects. In order to focus on the more important social problems, initiatives considered incompatible with the principle of solidarity or the extent of available resources are excluded.
At the same time, the focus has been on projects in support of the weaker members of the community (infancy, the elderly, persons in difficulty, the sick and disabled) with a specific accent on initiatives in favour of education, training, scientific research, health care and services, according to life and individual enhancement criteria.
In quantitative terms, the resources for allocation to donations were defined and divided between national and international projects and between the traditional social nvironmental, religious-charity and cultural areas.
The second operating guidelines concern centralised donations management, outlining the approval process for each donation. This process allows internal improvement of the selection procedures and externally steers applicants towards transparency, project planning and the organisation of a more responsible approach to a request for donations.
The third operating guidelines govern Fund monitoring. This translates into a well-defined reporting system for verification of the consistency between management and the distribution plan objectives. For distributions of a significant amount, the benefits produced from any support provided are also assessed.
In addition to Intesa Sanpaolo donations, several other Group banks have an independent charity fund and already donate to various social and cultural initiatives. An operating model that establishes shared Group guidelines in this sector will be completed in 2010.
During 2009 a policy applying to all the Group’s international companies was issued, which forbids donations to political parties, trade unions and public administration organisations and agents (implementing regulations already applied in Italy in compliance with Legislative Decree 231/2001).