Transparency policy

Transparency regulation of customer relations

1. Foreword
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This document regulates the obligations set forth in Title IV of the TUB – and thus what is regulated regarding transparency and fairness in customer relations which refers Bankitalia document adopted on July 29, 2009 with subsequent additions.

The company in compliance with the principles of transparency and fairness with its customers has, provided itself with a clear and comprehensive pre-contractual and contractual information in line with the requirements of industry regulations in order to:

-Make known to customers the essential elements of the relationship;
-Highlight to customers clearly and comprehensively the characteristics of the relationship.

2. Advertising and Pre-contractual Information
In line with the provisions in transparency, the company has prepared the mandatory pre-contractual disclosure.

3. Notice on the main transparency regulations
The form of the main transparency rules is made available to customers at the company’s headquarters at the disposal of contracted suppliers, as well as published within the company’s website. The same is drafted through a graphic design that allows for easy reference and within which the following information is specified:

-The possibility for the customer to be able to have available and take away within the premises open to the public, on the website, a copy of the information sheet on the financing contract;
-To obtain before the conclusion of the financing contract, without terms and conditions, a copy of the suitable contract including the relevant summary document;
-The obligation of the written form of the contract;
-The possibility of being able to withdraw from the contract within 14 days;
-The procedure provided for being able to file a complaint with the company;
-The clarification of the existing mechanisms for out-of-court settlement of credit disputes and the relevant procedures for accessing these procedures.

4. Information Sheet.
The form is made available to customers at the company’s headquarters as well as published within the company’s website.

5. Framework contract
In application of the provisions with the industry regulations, the company has a contract form for which the written form is used; this form is prepared in 3 copies namely:

-Customer Copy, which is to be filled out and handed to the customer;
-Copy Company, which is to be filled out and signed by the customer to acknowledge receipt of the contract copy;
-Copy Stipulation Use made available to customers and removable at the offices of the company, indirect employees and within the company’s website.

Attached to this contract form is the relevant summary document, which forms its title page, and where the most significant economic conditions and main contractual clauses are specified in outline.

6. Advertising Messages
Regarding the creation of advertising messages for customers, they are prepared by the body with management function with prior feedback from the compliance function.

Employees of the company are prohibited from disseminating advertising messages that have not been authorized by the company in writing. Such advertising messages must mandatorily be recognizable as such and specify the following information:

-Their nature as promotional messages;
-That reference must be made to the information sheets for the terms and conditions relating to the contract and specify how these are made available to customers;
-If the advertising message is made, with reference to financing operations by highlighting the interest rate, all the costs of the operation should be specified analytically.

7. Controls
Transparency documentation within the company is prepared and updated by the Body with Management function in cooperation with the Compliance Function. All forms are coded with a unique code, with the relevant date of issuance of the form and revision number, if any.

Proper fulfillment of transparency obligations and, therefore, compliance with internal procedures and regulatory compliance includes:

-The proper provision of transparency forms to customers;
-The correct Updating of transparency forms;
-The verification of compliance with the procedures of customer contact personnel.

The second level control exercised by the compliance function, which reviews and evaluates the adequacy and effectiveness of the Company’s systems, processes, procedures and control mechanisms and verifies their compliance.