Governance and policies

Governance and policies

We have established a new sustainability governance model to achieve our goals through coordinated action between corporate functions and senior management.

 

Sustainability governance

The Governance system, structured around the Board of Directors, is geared towards sustainable development and is also reflected in the Articles of Association, which enshrine this principle.  

Through our Sustainability Policy Framework, we are committed to integrating sustainability into our business decisions and operational processes.  

The set of guidelines and procedures is implemented through a dedicated organisational structure, centred on the Risk and Sustainability Committee, the core body of our sustainability governance. The ESG Council – chaired by the Chief Executive Officer – was instituted in February 2024 with the role of ensuring ongoing strategic alignment and coordination across our ESG projects. 

With the aim of promoting increasingly cross-cutting management of environmental, social and governance issues, three Departments (Administration, Finance, Control and Sustainability; Investments, People, Transformation and External Relations; Sector Strategy and Impact), all reporting directly to the Chief Executive Officer, are responsible for enacting and communicating the Group’s sustainability commitment. 

The Risk Department also plays a key role, being responsible for defining, selecting and implementing models, methodologies and tools to assess and monitor emerging risks, including those related to ESG. An important contribution also comes from the People and Organisation function, which ensures that human resources are managed through a structured approach to change and inclusion. 

Our internal regulations

The organisational structure consists of policies, regulations and procedures. Our ambition is to be increasingly guided by policies that favour the implementation of our sustainability strategy and its natural development over time.  

Click on the arrow to access the main documents and policies adopted with the aim of integrating sustainability within our business and operating model:

Documents and regulations
   
Code of Ethics Group code of conduct containing a series of social and moral rules that it is mandatory to comply with.
Sustainability Framework Regulations Describes the guiding and methodological principles, the areas and the operating methods that CDP adopts and implements in managing sustainability within its organisational system, in compliance with external regulation and associated internal rules.
2025-2027 ESG  Plan Outlines CDP GROUP's sustainability goals and commitments.
2022-2024 ESG  Plan Outlines CDP's sustainability goals and commitments.
General Policy for Responsible Financing Guides business activities aimed at generating positive and measurable impacts in the field of ESG.
General Policy for Responsible Investing Defines the guiding principles of direct and indirect investments based on ESG criteria.
General Stakeholder Engagement Policy The document identifies ways of listening and dialogue for constant involvement of stakeholders in order to establish concrete collaboration and produce shared value.
Diversity, Equity and Inclusion Policy Sets out the guiding principles and operating methods to promote the values of diversity, equity and inclusion among internal and external stakeholders, with measures in four macro areas: people, business, purchasing and communication.

General Well-being Policy

 It defines CDP's commitment to guaranteeing a positive, fair and stimulating working environment, through the adoption of principles and initiatives aimed at its people, to promote their work-life balance and consequent psycho-physical well-being.
Energy Sector Policy< It outlines where we do and don’t make interventions in terms of our financing and investment activities in the energy sector; it also aims to integrate ESG aspects as part of business processes, identify criteria for the handling of areas to be promoted in line with the Strategic Guidelines developed for the sector and define the criteria governing limitations and exclusions.
Defence and Security Sector Policy

Establishing treatment, limitation and exclusion criteria to guide CDP's operations in the defence and security sector.
Transport Sector Policy It defines treatment, limitation and exclusion criteria to guide CDP's operations in the transport sector, relating to the building of infrastructure, the construction of vehicles (excluding the production of parts) and the provision of services for road transport, rail transport and fixed installations, transport by sea and inland waterways, and air transport.
Agrifood, Wood and Paper Industries sector Policy It establishes limitation, exclusion criteria and aspects to be promoted to guide CDP's operations in the Agrifood, Wood and Paper Industries Sector.
Stakeholder Grievance Mechanism Policy Describe the mechanism made available to the civil society in order to report current or potentially negative social/environmental impacts that may result from operations financed by CDP or from operations for which the financial support of CDP was requested within the scope of the International Cooperation and Development Finance Area (ICDF).
General Internal Footprint Policy Sets out the general principles and operating methods to promote best practices in environmental sustainability and reduce environmental impacts, with particular reference to those relating to CDP operating model, i.e. linked to the management of workplaces, ICT components and travel.

General Responsible Procurement Policy
Annex Supplier Code of Conduct

 Sets out the guiding principles and operating methods to continuously promote best practices in environmental and social sustainability and good governance in CDP supply chain.
Summary Document - Tax Integrity and Transparency  The document presents a concise overview of the guidelines that CDP and its Group Companies adopt to mitigate the Tax Integrity Risk associated with operations concerning the management of EU resources and other supranational funds, as well as the Risk of Tax and Financial Transparency linked to counterparties.  
Tax Strategy The Tax Strategy defines the objectives, principles and guidelines adopted by CDP for managing the tax matters and the risk associated.
Integrated Policy for Environment, Occupational Health & Safety and Energy States the principles and commitments made by the company's senior management for the continuous improvement of the management systems and is circulated to all levels of the organisation.
Scope of application of the Integrated Management System for the Environment, Occupational Health and Safety and Energy  Specifies the scope of application of the Integrated Environmental, Occupational Health and Safety and Energy Management System; the scope of application includes the activities, internal and external factors, the needs and expectations of the interested parties and the physical and organizational boundaries of the locations where CDP assumes the role of owner, lessor or lessee and in which CDP personnel are present.
Guidelines on Antitrust, Conflicts of Interest, Market Abuse and Privacy Summarizes - in line with the internal regulations approved by CDP’s competent bodies - the guidelines and key measures adopted by CDP in the following areas of paramount interest, considering its operational activities: Antitrust, Conflicts of Interest, Market Abuse and Privacy.