Transparency to customers:
Transparency requirements are managed in accordance with the law, in order to make the dissemination of information to our customers clearer and more comprehensible in all stages of the relationship with the Bank. Simplicity of language, information transparency and alignment of conditions within the various transparency documents relating to the same product/service are ensured.
In July 2015 new transparency provisions were issued, aimed at simplifying the reports. These provisions apply to all banking and financial products, with the exception of investment services, with impacts - both in terms of documents and methods of sale - on commercial processes in the pre-contractual, contractual and after-sales stages.
Customer protection is strengthened and the Bank is also required to implement a series of conducts and measures aimed at:
- offering understandable products in terms of their structure and characteristics;
- making a business proposition aligned to customer needs;
- providing answers to complaints within 30 days of receipt of the complaint by the Bank;
- informing the customer of the possibility of taking advantage of the various forms of extra-judicial protection available.
In implementing these principles, the Bank has adopted internal procedures to ensure specific supervision for the protection of Retail customers with specific reference to Product development, their Marketing and the Remuneration of the sales network.
Information Sheets @ A section of the Bank's Internet 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 this section of the website, so that they can be viewed, saved and printed.
Investments: Our advisory service
On 1 November 2007 the EU directive on investment services (MiFID) came into force, introducing new rules to better protect investors. The MiFID Directive has established the criteria by which banks are required to classify their customers - retail and professional - and set the rules of conduct to apply with respect to them. In line with the MiFID Directive, Intesa Sanpaolo has decided to offer all its customers the possibility to choose the advisory service in order to provide them with personalised advice in making their investment decisions.
The MiFID Directive has recognised advice as the investment service featuring the highest level of protection for customers. Offering advice means reflecting on the needs of customers and their assets as a whole, proposing customised recommendations consistent with their Financial Profile.
To support the investment choices we have developed the Recommended Portfolios that stem from a process of analysis that selects and combines the products and services offered by the Bank according to the consistency with the market scenario and the customer risk profiles. The combination of products and services present in the Recommended Portfolios seeks to ensure diversification by market and by instrument, using both asset management and assets under administration products/services.
If the customer chooses to make use of the "Investment advisory service", the Bank carries out the assessment of adequacy of all investment/disinvestment transactions proposed to the customer or requested by the latter on its own initiative against the customer’s Financial Profile emerged during the profiling stage. If the Bank deems that an investment transaction requested by the customer and concerning a financial product or an investment service falling within the scope of the Advice is "inadequate", the Customer will not be able to complete the requested transaction.
In 2014, Directive 2014/65/ EU (so-called MiFID II) and Regulation no. 600/2014 (MiFIR) were enacted, bringing significant changes to the applicable regulations. In order to adapt the organizational and procedural system to the new regulations, the Bank launched the MiFID II project.
During 2015 the Bank carried out a complete overhaul of its profiling questionnaire aimed at obtaining, in advance from the customer, information related to knowledge and experience in the field of investment, financial situation and investment objectives. Indeed, the new questionnaire, released last July, resulted in a significant revision of the profiling methods adopted by the Bank as the process for acquiring customer information:
- has changed from an assessment system based on self-declarations to a logic of exploiting the information already available to the Bank, both in terms of customer experience, and of its financial situation;
- provides for the formulation of questions which are not self-assessing, with questions mainly based on "objective" parameters (such as educational qualifications, profession, dependent family members, income, etc.).
Relations with the Consumer Associations
Intesa Sanpaolo has been developing for a long time an open and constructive dialogue with all the Consumers’ Associations recognised as representative at national level, starting from listening to requests and finalizing the collaboration at a design, technical and operational level.
During 2015 a plenary meeting was held between the Bank’s top management and all consumer organisations to plan joint actions, implement those in progress and update each other on the activities in the banking sector.
The best results can be summarised, at project level, in terms of a renewed strong commitment to the growth of the economic, banking and consumer culture through the “Mettere in Comune Competenze” (Sharing Expertise) project1 and in terms of “Conciliazione Permanente” (Standing Conciliation): the extra-judicial dispute resolution instrument adopted and managed together with the Associations in order to strengthen the relationship of trust with customers over time and offer an additional opportunity to ensure and protect customers' full satisfaction with the quality of the products and services used
The conciliation procedure, which concerns products offered to retail customers (current accounts and linked payment cards, mortgages and personal loans), is simple, free and fast, with maximum case resolution times of 60 days. Customers may decide to participate, at no cost and without compromising any other procedures they may wish to take subsequently, in order to protect their own interests. A total of 344 claims were received as at 31 December 2015.
Concerning the technical debate on specific issues of global significance, the Bank offered to establish technical working groups focused on credit, savings, digitization and new products: the most important products offered to household customers are widely debated with the Associations prior to their marketing.
1 For further information, please refer to the chapter “Growing with our stakeholders: financial culture for informed choices”.