BUSINESS & HUMAN RIGHTS

1. BUSINESS & HUMAN RIGHTS UniCredit on its sustainability path: understanding and managing the financial sector’s responsibilities in terms of human rights” Sebastian Marcusanu – UniCredit Group Corporate Sustainability Bucharest, May, 15th 2012

2. AGENDA • UNICREDIT, SUSTAINABILITY AND HUMAN RIGHTS • UNICREDIT APPROACH TO HUMAN RIGHTS • CONCLUSIONS

3. UNICREDIT AT A GLANCE • Employees: over 160,0001 • Branches: nearly 9,5002 • Banking operations in22 countries • International network spanning : ~ 50 countries • Market leader in Central and Eastern Europe leveraging on the region’s structural strengths 1 Data as at December 31, 2011. FTE “Full Time Equivalent”= number of employees counted for the rate of presence. Figures include all employees of subsidiaries consolidated proportionately, such as Koç Financial Service Group employees. 2Data as at December 31, 2011. These figures include all branches of subsidiaries consolidated proportionately, such as Koç Financial Services Group branches.

4. The capability to find valuable ways to do with our customers, selecting investments that create value on an (both in the short term and long term) of and contributeto sustainabledevelopment in a mannerthat meets the UNICREDIT HAS DEFINED A CLEAR SUSTAINABILITY PATH TO TRANSLATE ITS MISSION INTO PRACTICAL BEHAVIORS AND ACTIONS

5. ENSURING BUSINESS RESPECT FOR HUMAN RIGHTS MUST BE ADDRESSED WHILE MEETING DIFFERENT STAKEHOLDER EXPECTATIONS… Corporate Sustainability, as expression of companies’ responsibilities not only from a purely economic perspective but also for consequences of their actions in terms of social/environmental impact, requires to addresshuman rights Column Head: 14-pt. Bold WHY HUMAN RIGHTS FOR FINANCIAL SECTOR ARE BECOMING RELEVANT • ENLARGMENT AND DIVERSIFICATION OF THE TYPE OF BANK OPERATIONS • INCREASING NUMBER OF PERCEIVED HUMAN RIGHTS’ ABUSES INVOLVING BANKS • INCREASING SCRUTINY OF WATCHDOGS AFFECTING PUBLIC OPINION • FOCUS OF SUSTAINABILITY RATING AGENCIES AS EXPRESSION OF INVESTORS • PERFORMANCE OF STAFF AND MANAGEMENT • THE REGULATORS’ AND INTERNATIONAL INSTITUTIONS’ RECENT EVOLUTIONS

6. … SUCH AS THE MAIN RECENT EVOLUTIONS OF REGULATORS AND OTHER INTERNATIONAL RECOGNIZED ORGANIZATIONS, REQUIRING MORE BUSINESS RESPONSABILITY FOR RESPECTING HUMAN RIGHTS Dec 2010 • The International Organization for Standardization(ISO) adopted a new social responsibility standard (ISO 26000) which includes a Human Rights chapter March 2011 • The Global Reporting Initiative (GRI) launched thelatest version of the Guidelines for the Sustainability Reporting (G3.1) focusing on Human Rights, Local Community, and Gender • Ministers from 42 countries that adhere to the OECD Guidelines for Multinational Enterprises adopted an updatethat for the first time includes a Human Rights chapter May 2011 • International Finance Corporation (IFC) a member of the World Bank Group approved an update of the IFC’s Sustainability Framework; for the first time, IFC specifically references the business responsibility to respect Human Rights • UN Human Rights Councilapproved theGuiding Principles for Business and Human Rights: implementing the United Nations “Protect, Respect and Remedy” Framework developed by Professor John Ruggie (UN Secretary-General’s Special Representative for Business and Human Rights). June 2011 Oct 2011 • EU Commission renewed the EU strategy (2011-2014) for Corporate Responsibility by emphasizing the coherence of EU policies relevant to business and human rights

7. UNICREDIT APPROACH TO HUMAN RIGHTS STARTED WITH THE ADOPTION OF ITS INTEGRITY CHARTER UniCredit Integrity Charter defines the values that should lead behavior of the UniCredit group's employees with respect to each of our stakeholders Stakeholders WITH OUR INTEGRITY CHARTER WE AIM AT CREATING A CORPORATE CULTURE BASED ON A STRONG AND SHARED SET OF VALUES

8. IN ADDITION SEVERAL SPECIAL INTERNAL RULES* HAVE BEEN DEVELOPED THAT ADDRESS ALSO ASPECTS OF HUMAN RIGHTS… Nuclear Energy Policy Green & social Procurement Policy Code of Conduct Mining Policy Defence/Weapons Policy Privacy Global Compliance Guidelines Water Infrastructure Policy SUCH POLICIES AND GUIDELINES AIM TO AVOID ALSO POTENTIAL VIOLATIONS OF HUMAN RIGHTS ACROSS GROUP ACTIVITIES *List not exhaustive

9. … WHILE ADHERING TO SOME OF THE MAIN INTERNATIONAL GUIDELINES AND STANDARDS IN THE FIELD UniCredit was pioneer in adhering to several international standards and guidelines that have been developed in the last years UNICREDIT KEY INTERNATIONAL STANDARD MEMBERSHIPS 2003 2004 2009 THE GUIDELINES AND STANDARDS WE ARE ADHERING TO, ARE VOLUNTARY BASIS INITIATIVES THAT DO NOT ALWAYS INCLUDE REGULATORY INSTRUMENTS NOR ENFORCEMENT PROVISIONS

10. A SPECIFIC PROJECT WAS LAUNCHED IN 2011 TO BETTER UNDERSTAND THE ISSUE AND IMPROVE UNICREDIT CAPABILITY TO ADDRESS HUMAN RIGHTS WITHIN OUR SPHERE OF INFLUENCE CHALLENGES AND GOALS • Identify or anticipate human rights “rules” relevant for business and banks, thus ensuring compliance • Improve the reputation risks management by integrating Human Rights risks and reduce potential violations 4 STEPS PROJECT TO ADDRESS HUMAN RIGHTS “As is” analysis Benchmark & gap analysis Human Rights approach development Human Rights approach implementation We are here

11. UNICREDIT HUMAN RIGHTS COMMITMENT What is the human rights Commitment ? • The Human Rights Commitment includes the principles and systems adopted by UniCredit for its operations pertaining to human rights Why the Human Rights Commitment ? • The Human Rights Commitment aims to define a reliable and inclusive approach that allows UniCredit to identify and manage human rights risks and reduce potential human rights violations What is the scope of application ? • Employees, Customers and Suppliers • With regards to Community, UniCredit strives to provide an example of good practice through our own business conduct • Communication and training for the employees • Leveraging on the existing monitoring processes that are linked to the systems adopted pertaining to human rights • A set of KPYs included in the annual Sustainability Report (GRI requirements) • Stakeholder feedback and expectations How it is implemented ?

12. CONCLUSIONS Banks are increasingly placed at the center of a global responsibility network Ensuring compliance to relevant human rights “rules” is key to manage our day by day business Corporate sustainable culture increasingly counts