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.
With the aim of strengthening the monitoring, a partial review of the Policy of Compliance with European Union Competition Law - adopted in 2009 – was launched in order to incorporate some regulatory innovations and new legislative and jurisprudential guidelines regarding promotion and recognition by the Supervisory Authority of antitrust compliance programs, control of concentrations, corporate governance, state-aid and unfair trade commercial practices.
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 2015 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 of the Group. In this regard, the Team held several classroom courses in the following venues:
VÚB Banka, Slovakia
CIB Bank, Hungary
Banca Intesa Beograd, Serbia
Intesa Sanpaolo Banka Bosna i Hercegovina, Bosnia and Herzegovina
Intesa Sanpaolo Bank Romania
Intesa Sanpaolo Bank Albania
Privredna Banka Zagreb, Croatia
Banca Intesa, Russian Federation
Intesa Sanpaolo Bank, Slovenia
Global Transaction Banking di Intesa Sanpaolo, Italy
Banca dei Territori, Italy
Eurizon Capital, Italy
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 2015, these activities increased significantly through the following initiatives/awards:
participation to the conference "EU Competition Law Update", organised by ACC – Association of Corporate Counsel;
participation to the Hong Kong Antitrust Conference organised by ABA – American Bar Association;
participation to the conference "Cartels: Risks and Compliance", organised by IBC Legal in Brussels;
appointment of the Antitrust Team - within the European Counsel Awards - among the best antitrust teams in Europe.
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.