Intesa Sanpaolo constantly monitors and promotes free competition. In this regard, it renews its commitment, especially with the aim to:
ensure that European Union rules and procedures on the matter of free competition are actually applied and observed;
disseminate antitrust compliance culture across all Group levels and among third-party Stakeholders, commercial partners, suppliers and customers.
In order to guarantee an oversight that takes into account regulatory innovations and new legislative and case law guidelines, antitrust compliance has been extended to include, in addition to typical decrees of antitrust discipline (mergers, abuses of dominant position and agreements), Community legislation on state aid and the recent Italian rules to support the competitiveness of Italian companies.
In this context the International and Regulatory Affairs Department extended its scope of activities, taking care of the compliance monitoring, not only in reference to the most traditional antitrust forms (concentrations, abuses of dominant positions and agreements), but also with regard to the Community rules on state-aid and to the recent Italian regulations in support of Italy's competitiveness.
The natural points of contact of the Antitrust Team, specific team of experts on the matter within the Department, are colleagues and Italian and international Group companies on the one hand and national, European Union and international antitrust authorities on the other.
The voluntary choice to adopt a proper Antitrust Compliance Programme, which goes beyond the mere compliance with current regulations, sets higher standards of conduct. In order to ensure the compliance with such standards, also in the light of the Group’s reference values set forth by the Code of Ethics, in 2017 information and education activities towards the major internal and external stakeholders continued, in the belief that protecting and strengthening competition create benefits for everyone, also in terms of greater transparency and assumption of responsibilities as well as a significantly positive effect on reputation.
In respect of colleagues
With a view to increasing the colleagues' awareness regarding the risks arising from competition breaches and helping them foresee similar risk situations, the Antitrust Team launched a series of remote as well as classroom training initiatives, addressed to national and foreign structures targeting many different groups of the Group. In this regard the Antitrust team has conducted a classroom training course the for employees in the Banking Advisory Service and New Services of the Legal Affairs and Litigation Department; distance training was also carried out for the employees of Mediocredito Italiano and the Corporate and Investment Banking Division. Furthermore, the first training product about the main principles of antitrust regulations was set up on the innovative channel of the Managers’ School App, and was made available to more than 6000 Group managers.
In respect of third parties and Supervisory Authorities
For years, the Antitrust Team has promoted the dissemination of the antitrust culture in its relations with third parties and Supervisory Authorities, also through active participation in seminars, lectures and advocacy initiatives. During 2017 these activities increased significantly through the following initiatives/awards:
participation in the Conference of Studies organized by the Italian Competition Authority on the theme "The disruptive power of innovation: which challenges for the discipline of competition";
participation in the VI edition of the Trento Antitrust Conference and the III edition of the Trento Summer School on the Advanced EU Competition Law and Economics, organized by the Permanent Observatory on the Application of the Rules of Competition;
participation in the Competition Law in the Financial Services Conference, organized by IBC Legal in London;
attribution to the Antitrust Team of the award as best in-house antitrust team in Italy, as part of the Top Legal Counsel Awards.
With a view to ensuring the utmost transparency in its relations with the Authorities, the Antitrust Team manages notifications of concentration transactions with the competent Italian and international Antitrust Authorities and the information requests pertaining to fact-finding investigations and proceedings relating to possible breaches of the relevant regulations (e.g. regulations applicable to concentrations, agreements, abuses of dominant positions and state-aids).
Drawing on its own direct experience, the Antitrust Team is actively involved in the European debate on relevant competition matters, in the interest of an ongoing debate and cooperation with national and non-national competition Authorities.