Double materiality analysis
With the aim of adhering to the regulatory provisions of the Corporate Sustainability Reporting Directive (CSRD) and determining the main sustainability issues that, at a strategic level, can guide the Poste Italiane Group's commitment to ESG, in line with what was carried out in 2024, the Poste Italiane Group followed a Double Materiality Analysis process in line with the provisions of the ESRS standards and the Materiality Assessment Implementation Guidance (MAIG Guidance) developed by EFRAG, in order to include the two perspectives of impact materiality and financial materiality within the process itself. The Group's sustainability framework is defined by ensuring its harmonisation with the Enterprise Risk Management model also in terms of processes, tools and related methodologies. Furthermore, as part of the Double Materiality Analysis process, the Group takes the stakeholders' interests and opinions into account and orients its strategy according to the findings of this process. Following the analyses performed, the Poste Italiane Group's Double Materiality process took place in the following stages:
In order to identify risks and opportunities, first an analysis of the Group's relevant activities was carried out, consistent with the 2025 Double Materiality Analysis cycle, and then proceeded to relate them to the sustainability-related topics, subtopics and sub-sub-topics contemplated in ESRS 1. In particular, the assessment of strategic risks, carried out in relation to Poste Italiane's various Business Units, was performed paying particular attention to the context, also in consideration of the targets set in line with the country's general objectives for a sustainable economic recovery, as well as the current market scenarios also resulting from geo-political tensions. This activity was also carried out in accordance with the company's ESG and strategic performance objectives.
In addition, the analysis of emerging risks and opportunities with potential impacts on the Poste Italiane Group's strategies was carried out by identifying trends from exogenous factors, potential significant impacts for Poste Italiane Group (by indicating SBUs, risk categories, sustainability pillars and potentially impacted financial and non-financial capital) and the main ways in which the Poste Italiane Group manages emerging risks and opportunities. Following the verification of ESRS topic coverage, the list of potentially relevant risks/opportunities (long list) was consolidated. Based on this long list, an assessment of risks and opportunities was carried out in order to identify those relevant to the Poste Italiane Group. The assessment was carried out in consideration of the Impact Materiality and on the basis of possible dependencies of the Poste Italiane Group (e.g. energy resources for the corporate fleet), as well as considering the players in the value chain that contribute to the generation of the identified risks/opportunities and the reference time horizon, divided into short term (within 1 year), medium term (within the plan period) and long term (beyond the plan period).
In order to determine the significance of the impacts identified in the previous phase, a scoring mechanism was established by defining the significance and likelihood of occurrence for each impact.
With reference to the significance value of impacts, an assessment scale ranging from 1 (Negligible) to 5 (High) was defined on the basis of the following drivers:
- magnitude, measure of the positive or negative effects of the impact on the environment and people
- scope, extent of impact in terms of geography and/or number of individuals affected
- irreparable nature (only for negative impacts), Poste Italiane Group's ability to remedy the effects of the impact.
Furthermore, an additional increment of 1 was assigned to all potentially significant human rights impacts, with the aim of increasing their significance in line with the provisions of ESRS 1 and the MAIG Guidance.
The significance of the impacts was subjected to stakeholder assessment, as detailed below.
The analysis also took into account the internal assessments of the SSG Team, reviewed with the Consolidated Sustainability Statement Manager, based on the evolutions of the context and the business scenario of the Poste Italiane Group occurred in 2025, as well as the assessments expressed by the stakeholders on the occasion of the 2024 stakeholder engagement. The above analysis was conducted on the three dimensions (magnitude, scope and, for negative impacts, also irremediability) consistent with the methodology adopted in stakeholder engagement.
With reference to the probability of occurrence of impacts, a scale of values from 1 to 5 was defined, assigning a maximum value of 5 to all actual impacts and involving the specific reference functions to establish the probability of occurrence of potential impacts, based on evidence from an internal desk analysis.
The methodology for calculating the significance of each identified impact was defined as the product of its associated significance and probability. Finally, a conservative approach was adopted for determining the materiality threshold of impacts, so as to ensure the widest coverage of issues initially identified as potentially relevant to the Group, taking into account the ERM thresholds used for risk and opportunity assessment purposes. Therefore, a threshold of 8 was determined, which includes impacts classifiable by materiality value as Tier 1 and Tier 2.
In line with the Enterprise Risk Management framework, risks and opportunities are assessed through the drivers of impact (quantitative and qualitative) and probability of occurrence of the risk event on a 5-value scale. In particular, the impact drivers considered are listed below:
- qualitative-descriptive
- reputational
- economic-indirect
- income
- physical security
- cybersecurity.
The assessment, in terms of inherent risk, was carried out consistently with the metrics adopted in the Enterprise Risk Management area and the reference thresholds, in order to attribute a scoring in line with the assessment criteria defined by the ESRS standards.
The combined assessment of probability by impact allows the risks to be classified as follows:
Tier 1: risks with rating of 12 or higher
Tier 2: risks with rating between 8 and 10
Tier 3: risks with rating lower than 8.
Based on the assessments performed, and in line with the Enterprise Risk Management methodology, risks and opportunities falling within Tier 1 were identified as relevant for the Poste Italiane Group.
With reference to the risks arising from the ERM Model, the analysis is updated on a quarterly basis as part of the monitoring activities carried out by the Group Risk and Compliance function. These activities normally envisage, for each relevant risk, the involvement of the competent corporate functions for the purposes of updating the quantitative and qualitative data/information on the basis of which the trend of the risks themselves is determined, reviewing, if necessary, their assessment, in accordance with the Group's Risk Management methodology. On the basis of the scoring mechanism and the materiality thresholds established, Poste Italiane identified a total of 35 impacts, 22 risks and 9 opportunities relevant to the Group (in 2024, 45 impacts, 22 risks and 9 opportunities were identified). These findings were shared with the Sustainability Committee, the Control and Risk Committee and the Board of Statutory Auditors. The Board of Directors subsequently approved the entire process.
It is specified that, regarding ESRS topic E3 "Water and marine resources", given its nature as a large integrated and omnichannel service platform in Italy, the Poste Italiane Group monitors water consumption for civil use at post offices, without significant impacts on water sources. An analysis of the Group's Companies, including those operating in non-EU countries with greater proximity to the oceans, shows that water withdrawal is limited to civil and non-productive uses, and is therefore not associated with impacts on marine waters. Furthermore, it should be noted that operations outside Italy are residual, with a total number of 58 employees in non-EU countries (China, Hong Kong and the UK) out of a total of 120,886 employees (calculated in FTE). Finally, the Group does not engage either directly or indirectly in activities related to the extraction or use of marine resources. Nevertheless, the Poste Italiane Group targets efficient water management, taking concrete actions to reduce water consumption and promote its proper use to prevent and avoid waste. Furthermore, within E3, the only impact identified as potentially relevant was found to be below the threshold after stakeholder assessments. For further details on the process for identifying and assessing relevant impacts, risks and opportunities, see the section "Disclosure Requirement ESRS 2 IRO-1”.
With reference to ESRS Topic E4 "Biodiversity and Ecosystems", the analysis led to the identification of the topic of biodiversity and ecosystems as substantially irrelevant in view of the nature, activities and sector in which the Group operates. Although impacts related to climate change (ESRS E1), water use and land use (ESRS E3 and E4) have been identified, these impacts are not material as they do not directly affect the loss of biodiversity, as they are mainly related to greenhouse gas emissions, energy consumption, water use for civil use, and limited soil alteration related to cement works. Furthermore, the Group neither directly nor indirectly engages in activities related to the direct exploitation of living organisms, does not contribute to the introduction of invasive exotic species, and has no other significant impact on biodiversity and ecosystems. Finally, due to the predominantly service-oriented nature of its activities, the Group has not identified significant dependencies on ecosystem services in its operations. Furthermore, under E4, the two impacts identified as potentially relevant were both found to be below thresholds after stakeholder assessments.
Material impacts, risks and opportunities
The Poste Italiane Group, in consideration of the unique characteristics of its business and on the basis of the operating context and the main players identified along the value chain, has identified the impacts, risks and opportunities relevant to it, by conducting the materiality analysis process, which is further detailed in the section ‘Managing impacts, risks and opportunities’.
The following table represents the relevant IROs identified through the materiality assessment conducted, indicating their respective time horizons, their location in the value chain and their connection to the business model with reference to the Group’s Business Units.
| ESRS Sub-topic | IRO | Description |
Time horizon |
Value chain |
Impacts |
Business Unit |
|---|---|---|---|---|---|---|
| Adaptation to climate change | I | Production of greenhouse gas emissions throughout the value chain (-) (E) |
Short-term |
Upstream |
People |
Mail, Parcels & Distribution; Postepay |
| R | Deterioration of quality delivered Inadequate quality delivered and failure to meet regulatory and contractual standards resulting in fines and penalties |
Short-term |
Upstream |
- |
Mail, Parcels & Distribution |
|
| R | Restrictions on Poste Italiane’s business operations due to extreme weather conditions related to climate change |
Medium-term |
Upstream |
- |
Mail, Parcels & Distribution |
|
| Mitigation of climate change | I | Production of greenhouse gas emissions throughout the value chain (-) (E) |
Short-term |
Upstream |
People |
Mail, Parcels & Distribution; |
| I | Contribution to combating climate change through the use of energy from renewable sources, fleet renewal and energy efficiency measures (+) (E) |
Short-term Medium-term Long-term |
Upstream Own operations Downstrea m |
People Environment |
Mail, Parcels & Distribution; Postepay Services; Financial Services; Insurance Services |
|
| R | Underestimating sustainable development and not actively pursuing decarbonisation can lead to serious consequences in terms of corporate reputation, with negative impacts on stakeholder trust, market opportunities and overall company value |
Long-term |
Upstream |
- |
Mail, Parcels & Distribution |
|
| O | Reduction of emissions related to the use of the vehicles making up the corporate fleet by virtue of a review of business models resulting from the transformation of mobility |
Long-term |
Own operations |
- |
Mail, Parcels & Distribution |
|
| Energy | I | Energy consumption for Group activities and services with negative consequences on the environment and reduction of the energy stock (-) (E) |
Short-term |
Upstream |
People |
Mail, Parcels & Distribution; |
| R | Non-/partial achievement of growth targets in the Energy market Non-achievement of business objectives related to the energy sector, due to strong market competition and regulatory issues |
Short-term |
Upstream |
- |
Postepay Services |
|
| R | Rising cost of raw materials and supply difficulties (e.g. oil, gas and energy) resulting from the current geopolitical context |
Medium-term |
Upstream |
- |
Cross-sectional |
|
| O | Decrease in the Group’s total energy consumption from non-renewable sources (e.g. fossil fuels) due to a review of business models resulting from the transformation of mobility |
Long-term |
Own operations |
- |
Mail, Parcels & Distribution |
| ESRS Sub-topic | IRO | Description |
Time horizon |
Value chain |
Impacts |
Business Unit |
|---|---|---|---|---|---|---|
| Air pollution | I | Production of air pollutants throughout the value chain (-) (E) in addition to the production of CO2 (-) (E) |
Short-term |
Own operations |
People |
Mail, Parcels & Distribution |
| R | Restrictions on Poste Italiane’s operations, with particular reference to deliveries, due to traffic restrictions (e.g. restrictions on polluting vehicles) |
Long-term |
Own operations |
- |
Mail, Parcels & Distribution |
| ESRS Sub-topic | IRO | Description |
Time horizon |
Value chain |
Impacts |
Business Unit |
|---|---|---|---|---|---|---|
| Inflows of resources, including use of resources | I | Contribution to the conservation of resources through the use of recyclable and sustainable materials in carrying out the Group's activities (+) (E) |
Short-term |
Upstream |
Environment |
Mail, Parcels & Distribution; |
| Waste | I | Production of waste throughout the value chain (-) (E) |
Short-term |
Upstream |
Environment |
Mail, Parcels & Distribution |
| R | Incorrect/non-compliant waste management |
Short-term |
Upstream |
- |
Cross-sectional |
| ESRS Sub-topic | IRO | Description | Time horizon | Value chain | Impacts | Business Unit |
|---|---|---|---|---|---|---|
| Working conditions | I | Lack of protection of rights with respect to to contractual conditions, with reference to working hours, secure employment and adequate wages (-) (P) |
Short term Medium-term |
Own operations | People | Mail, Parcels & Distribution; Postepay Services; Financial Services; Insurance Services |
| I | Lack of protection of rights with respect to freedom of association and collective bargaining (-) (P) |
Short-term Medium-term |
Own operations | People | Mail, Parcels & Distribution; Postepay Services; Financial Services; Insurance Services |
|
| I | Promotion of a Work-life balance (+) (E) |
Short-term Medium-term |
Own operations | People | Mail, Parcels & Distribution; Postepay Services; Financial Services; Insurance Services |
|
| I | Accidents, injuries and occupational illnesses (-) (E) |
Short-term Medium-term |
Own operations | People | Mail, Parcels & Distribution; Payments and Mobile; Energy; Financial Services; Insurance Services |
|
| R | Trade Union Conflicts: Tensions and states of industrial unrest related to the launch of the new delivery model and other ongoing transformation actions | Short-term Medium-term |
Own operations | - | Cross-sectional | |
| R | Accidents/Injuries to workers or contractors at the workplace Accidents to workers or collaborators at the workplace resulting from the execution of operational activities (e.g. acceptance, transport and sorting activities; postal product delivery activities with particular reference to the use of company motor vehicles and vehicles, counter activities) | Short-term Medium-term |
Own operations | - | Cross-sectional | |
| R | Disputes and litigation: Disputes and litigation, judicial and extrajudicial, with suppliers, employees, customers or third parties that may involve compensation and/or payment of penalties. | Short-term Medium-term |
Upstream Own operations Downstream |
- | Cross-sectional | |
| R | DDelayed re-engineering of operations and delivery processes Difficulties/delays in the implementation and development of the operating model due to various constraints (personnel management policies, operations and delivery processes, technological innovation, labour relations) resulting in failure to achieve plan targets | Short-term Medium-term |
Upstream Own operations Downstream |
- | Mail, Parcels & Distribution | |
| O | Possibilities to implement staff welfare and well-being plans (e.g. promotion of active parenting), taking advantage of changes in demographic and social composition, in order to increase labour market attractiveness | Medium-term Long-term |
Own operations | - | Cross-sectional | |
| Equal treatment and opportunities for all | I | Promotion of gender pay equality (+) (E) |
Short-term Medium-term |
Own operations | People | Mail, Parcels & Distribution; Postepay Services; Financial Services; Insurance Services |
| I | Employee attraction, development and training (+) (E) |
Short-term Medium-term |
Own operations | People | Mail, Parcels & Distribution; Payments and Mobile; Energy; Financial Services; Insurance Services |
|
| I | Incidents of violence and harassment in the workplace (-) (E) |
Short-term Medium-term |
Own operations | People | Mail, Parcels & Distribution; Payments and Mobile; Energy; Financial Services; Insurance Services |
|
| I | Promoting a work environment that fosters plurality and social and labour inclusion of people with disabilities (+) (E) |
Short-term Medium-term |
Own operations | People | Mail, Parcels & Distribution; Postepay Services; Financial Services; Insurance Services |
|
| R | Operational difficulties related to absenteeism rates and high rate of inability among employees Operational difficulties related to absenteeism rates and high rate of inability among employees (temporary or permanent unfitness for work, employment limitations), with potential impact on planned initiatives to increase productivity | Short-term Medium-term |
Own operations | - | Cross-sectional | |
| O | Increased ability to attract talent to the market through equal treatment, opportunities, the development of employment protection practices and plurality of the work environment | Medium-term Long-term |
Own operations | - | Cross-sectional | |
| Other work-related rights | I | Incidents of violation of workers’ privacy (-) (P) |
Short-term Medium-term |
Own operations | People | Mail, Parcels & Distribution; Postepay Services; Financial Services; Insurance Services |
| R | Non-compliance with privacy regulations Processing of personal data in violation of applicable regulations | Short-term Medium-term |
Upstream Own operations |
- | Cross-sectional |
| ESRS Sub-topic | IRO | Description |
Time horizon |
Value chain |
Impacts |
Business Unit |
|---|---|---|---|---|---|---|
| Working conditions | I | Lack of protection of of workers'rights in the value chain with respect contractual working conditions regarding working hours, secure employment, adequate wages and work-life balance, as well as with respect to freedom of association, social dialogue and collective bargaining (-) (P) |
Short-term |
Upstream |
People |
Mail, Parcels & Distribution; |
| I | Occupational accidents, injuries and diseases at work with reference to workers in the value chain (-) (P) |
Short-term |
Upstream |
People |
Mail, Parcels & Distribution; |
|
| R | Inefficiencies related to supplier relations within the procurement process: Possible inefficiencies in the definition of relations with external suppliers, in operational activities, as well as in the Group’s dependence on external suppliers, which may jeopardise the success of procurement activities |
Short-term |
Upstream |
- |
Cross-sectional |
|
| R | Accidents/Injuries to workers or collaborators at the workplace Accidents to workers or contractors at the workplace resulting from the execution of operational activities (e.g. acceptance, transport and sorting activities; postal product delivery activities with particular reference to the use of company motor vehicles and vehicles, counter activities) |
Short-term |
Upstream |
- |
Cross-sectional |
|
| Equal treatment and opportunities for all | I | Promotion of the plurality of the labour context in the value chain, with reference to gender and pay equality, measures against gender-based violence and harassment, training and inclusion of persons with disabilities (+) (P) |
Medium- |
Upstream |
People |
Mail, Parcels & Distribution; |
| I | Lack of protection of human rights along the value chain, such as child labour, forced or compulsory labour (-) (P) |
Short-term Medium-term |
Upstream Downstream |
People | Mail, Parcels & Distribution; Postepay Services; Financial Services; Insurance Services |
|
| Other work-related rights | I | Incidents of breaches of workers’ privacy in the value chain (-) (P) |
Short-term |
Upstream |
People |
Mail, Parcels & Distribution; |
| R | Non-compliance with privacy regulations Processing of personal data in violation of applicable regulations |
Short-term |
Upstream |
- |
Cross-sectional |
|
| R | Deterioration of reputation and non-compliance with human rights standards resulting from relations with suppliers who exploit child/forced labour in non-EU countries |
Short-term |
Upstream |
- |
Mail, Parcels & Distribution |
| ESRS Sub-topic | IRO | Description | Time horizon | Value chain | Impacts | Business Unit |
|---|---|---|---|---|---|---|
| Economic, social and cultural rights of communities | I | Contribution to the development of peripheral areas through the presence of Group services and infrastructures that promote the social inclusion of people living in economic hardship (+) (E) |
Short-term Medium-term |
Downstream | People | Mail, Parcels & Distribution; Postepay Services; Financial Services; Insurance Services |
| I | Promoting the country's Digital transformation through the introduction and delivery of innovative services (+) (P) |
Medium-term | Upstream Own operations Downstream |
People Environment |
Mail, Parcels & Distribution; Postepay Services Financial Services; Insurance Services |
|
| I | Creating shared economic and social value for the community (+) (E) |
Short-term Medium-term |
Upstream Own operations Downstream |
People Ambiente |
Mail, Parcels & Distribution; Postepay Services; Financial Services; Insurance Services |
|
| O | Possibility of accessing funds and contributions for the realisation of initiatives benefiting outlying urban areas, also taking advantage of the widespread presence in Italy that allows for visibility of the products and services offered throughout the Country | Long-term | Own operations | - | Cross-sectional |
| ESRS Sub-topic | IRO | Description |
Time horizon |
Value chain |
Impacts |
Business Unit |
|---|---|---|---|---|---|---|
| Information-related impacts for consumers and/or end users |
I | Incidents of breaches of consumer privacy, cyber attacks and data theft (-) (E) |
Short-term |
Downstream |
|
Mail, Parcels & Distribution; |
| R | Computer system malfunctions and/ or security failures that may lead to personal data breaches, loss or compromise of information, operational blockages or slowdowns, customer disruptions |
Short-term |
Own operations |
|
Cross-sectional |
|
| R | Non-compliance with privacy regulations Processing of personal data in violation of applicable regulations |
Short-term |
Own operations |
|
Cross-sectional |
|
| R | Inadequate use of big data and artificial intelligence and an increase in privacy violations |
Long-term |
Own operations - Cross-sectional |
|
Cross-sectional |
|
| R | Risks related to the regulatory/ legislative framework for competition and consumer protection Tightening of regulations for competition and consumer protection, as well as unfavourable outcomes of investigations conducted by the competent authorities |
Short-term |
Own operations |
|
Cross-sectional |
|
| Social inclusion of consumers and/or end users | I | Lack of access to products and services for the most disadvantaged user groups (-) (P) |
Short-term |
Downstream |
|
Mail, Parcels & Distribution; |
| I | Customer access to digital and innovative products and services (+) (E) |
Short-term |
Downstream |
|
Mail, Parcels & Distribution; |
|
| I | Customer satisfaction (+) (E) |
Short-term |
People |
|
Mail, Parcels & Distribution; |
|
| I | Disinformation with respect to the Group's products and services that may cause economic harm to users (-) (P) |
Short-term |
People |
|
Mail, Parcels & Distribution; |
|
| R | Failure to meet customer needs Provision of services and/or placement of products (also in integrated mode) that do not meet the real needs of business and retail customers in the postal/ logistics, banking, insurance, payments, mobile and energy fields. Limited satisfaction of business and consumer customer needs, for different products and services, throughout all stages of the customer life cycle |
Short-term |
Own operations |
|
Cross-sectional |
|
| R | Risks related to the regulatory/legislative framework for competition and consumer protection Tightening of regulations for competition and consumer protection, as well as unfavourable outcomes of investigations conducted by the competent authorities |
Short-term |
Own operations |
|
Cross-sectional |
|
| O | Opportunity to ensure accessibility to health protection even for the weaker sections of the population by contributing to sustainable development |
Long-term |
Own operations - Insurance Services |
|
Insurance Services |
|
| Social inclusion of consumers and/or end users |
O | Greater ability than competitors to understand customer needs, also with reference to targets in the “digital divide” |
Long-term |
Own operations |
|
Postepay Services |
| O | Acceleration of the transition to digitisation, with a consequent increase in demand for the digital products offered by Poste Italiane |
Medium- |
Own operations |
|
Cross-sectional |
| ESRS Sub-topic | IRO | Description |
Time horizon |
Value chain |
Impacts |
Business Unit |
|---|---|---|---|---|---|---|
| Corporate culture | I | Breaches of the Code of Ethics throughout the value chain (-) (P) |
Short-term |
Upstream |
People |
Mail, Parcels & Distribution; |
| R | Growing regulation in the field of artificial intelligence and consequent increase in compliance pressure |
Medium-term |
Own operations |
- |
Cross-sectional |
|
| Political influence and lobbying | I | Anti-competitive practices and antitrust violations (-) (P) |
Short-term Medium-term |
Upstream Own operations Downstream |
People | Mail, Parcels & Distribution; Postepay Services; Financial Services; Insurance Services |
| Protection of whistleblowers | I | Incidents of violation of the whistleblowing system (-) (E) |
Short-term |
Own operations |
People |
Mail, Parcels & Distribution; |
| R | Failure to comply with whistleblowing legislation |
Short-term |
Own operations |
- |
Transversal |
|
| Policy engagement and lobbying | I | Anti-competitive practices and antitrust violations (-) (P) |
Medium-term |
Own operations |
People |
Mail, Parcels & Distribution; |
| Management of relationships with suppliers including payment practices | I | Raising supplier awareness of ESG issues (+) (E) |
Short-term |
Upstream |
People |
Mail, Parcels & Distribution; |
| R | Inefficiencies related to supplier relations within the procurement process: Possible inefficiencies in the definition of relations with external suppliers, in operational activities, as well as in the Group’s dependence on external suppliers, which may jeopardise the success of procurement activities |
Short-term |
Upstream |
- |
Cross-sectional |
|
| Active and passive corruption | I | Promotion of workers’ awareness of active and passive corruption (+) (E) |
Short-term |
Own operations |
People |
Mail, Parcels & Distribution; |
| R | Non-compliance/adaptation with regulatory provisions on corruption |
Short-term |
Own operations |
- |
Cross-sectional |
| ESRS Sub-topic | IRO | Description |
Time horizon |
Value chain |
Impacts |
Business Unit |
|---|---|---|---|---|---|---|
| I | Contribution to the country's sustainable growth through the Group's investment and insurance products (+) (E) |
Short-term |
Own operations |
People |
Financial Services; |
|
| I | Promotion of responsible investment and insurance practices (+) (E) |
Medium-term |
Own operations |
People |
Financial Services; |
|
| O | Increased market attractiveness resulting from an increase in investment operations/practices that take ESG profiles into account, as well as the offering of sustainable insurance products/solutions |
Medium-term |
Own operations |
- |
Financial Services; |

