Intesa Sanpaolo constantly monitors and promotes free competition. In this regard, it renews its commitment, especially with the aim to:
ensure that national and european 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), european legislation on state aid and the recent Italian rules to support the competitiveness of Italian companies.
The natural points of contact of the Antitrust Team, specific team of experts on the matter within the Institutional Affairs 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 2018 education and information 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 was created the first digital training product, the Collection Antitrust, which consists of 10 Learning objects and is accessible from about 70,000 colleagues of the Italian perimeter through the platform “Apprendo”. The Team organized a distance training meeting regarding "Merger Antitrust Assessment-Theoretical and operational aspects in M&A operations" aimed at about 30 resources identified among the collaborators of the structures most affected by this kind of operations.
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 Roundtable "Big Data and their impact on consumers, banks and companies", organised by the ICC in Rome;
participation in the IV edition of the Trento Summer School on Advanced EU Competition Law and Economics, organised by the Permanent Observatory on the Application of Competition Rules;
participation in the Roundtable Intesa Sanpaolo “Digital revolution and the impacts in the world of payments-opportunities, business scenarios and regulatory framework in a cashless society”;
participation in the Conference "whistleblowing: application and protection requirements to one year by law 179/2017", organized by Unione Fiduciaria in Milan;
participation in the Conference "Antitrust facing the digital challenge: anachronistic instrument or guarantee for the market?", organized by political Agenda in Milan.
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.