"Banking Transparency" is meant to give customers information more clear and understandable at all stages of the relationship with the bank, through simplicity of language, transparency of information and alignment of conditions within the various transparency documents relating to the same product/service.
A section of the Bank's website presents the main transparency documents of the offer. In particular, the Information Sheets of the products and services offered, the specific Guidelines (The Current Account, The Home Mortgage, The Consumer credit) and the Reports on the conditions offered to customers are available at the branches and in the section of the website, so that they can be viewed, saved and printed.
With reference to the area of investments, following the entry into force of the MiFID II Directive and the European Regulations on investor protection, the Bank has further strengthened its model in order to be able to offer a higher level of protection to investors and greater transparency in the negotiations that take place on the financial instruments markets. In particular, Intesa Sanpaolo has introduced new obligations in terms of governance of financial instruments, knowledge requirements and competence of the personnel responsible for providing investment services as well as ex ante and ex post information on costs, charges and incentives for financial products and services offered.
Within the Progetto Multicanalità Integrata (Integrated Multichannel Project), information sheets and pre-contract documents were made available on the WEB platform for the distance marketing of financial products.
The new products and services marketed by Intesa Sanpaolo, as well as the changes to existing products and services, are subject to compliance clearing, a prior verification of compliance with applicable regulations. In the same way, innovative projects that involve the start-up of activities or inclusion in new markets, are assessed in advance to ensure substantial and formal compliance with internal and external regulations. Conformity assessments are conducted in compliance with the principles of fairness and protection of the customers' interests and also relate to the quality of the information provided and to the consistency of the same services, products or transactions with the expectations of the customers to whom they are addressed.
Intesa Sanpaolo has for some time developed an open and constructive dialogue with the Consumer Associations recognized as representative at national level, starting from listening to the requests and finalizing the collaboration at project and technical-operational level. In 2018, a meeting was held between the Bank's top management and the heads of all the Associations to establish the methods of reporting, current and future designs, technical tables on specific categories of products / services. Permanent Conciliation activities continued (see Website Conciliation Agreement) as an out-of-court resolution tool adopted and managed together with Consumer Associations. The conciliation procedure, which concerns the products offered to private customers (current accounts and connected payment cards, mortgages and personal loans), is simple, free and fast and provides for a maximum resolution time of 60 days. The customer can decide to join, without any charge and with the knowledge of not compromising in no way any different roads that wanted to undertake, even later, to protect his interests. In 2018, 51 applications for permanent conciliation were received.
The main objective is to communicate the initiatives that are strategic or important from an operational viewpoint to all stakeholders, ensuring the utmost transparency. Information is made available through the dedicated section of the website and individuals or entities can also subscribe to a mailing-list to receive press releases and information about major corporate events directly by e-mail or mobile phone. There is also an option for requesting that documentation is mailed to the user’s home address.
Intesa Sanpaolo adheres to UPA (Utenti Pubblicità Associati) and “Codice di Autodisciplina Pubblicitaria” (Publicity Governance Code), promoted by the Istituto di Autodisciplina Pubblicitaria (IAP) to ensure that publicity is transparent, true and correct. The close collaboration with these Associations ensures that any updates or amendments in the regulations to which we have adhered are immediately put into effect. As for advertisements of investment products, all scripts are always submitted to the Legal Affairs Department and to the Compliance Department and when necessary, communicated to Consob to examine their compliance with laws and their adherence to the principles of truthfulness and transparency.
In 2018, there were no remarks by the Istituto di Autodisciplina Pubblicitaria, nor penalties or warnings by the Authority for Competition and Market for misleading or comparative advertising.