The policy on internal dealing governs the transactions carried out by Key Personnel and by people closely associated with them regarding securities and financial instruments issued by Banca Ifis.
Banca Ifis’s internal dealing rules are aligned with the relevant EU legislation (Regulation (EU) No 596/2014, known as Market Abuse Regulation) and aim to ensure that the market receives full and transparent information.
The “Policy on transactions carried out by Key Personnel and by People Closely Associated with them regarding shares, negotiable instruments and associated financial instruments issued by Banca Ifis” (Internal Dealing Policy) was reviewed in October 2018.
This policy governs:
The list of key personnel reads as follows:
The policy on internal dealing also applies to “persons closely associated” with Key Personnel.
In June 2018, the Board of Directors of Banca Ifis approved the update of the “Internal policies on the control of risk-bearing assets and of conflicts of interest concerning associated persons” and of the “Procedure for the management of transactions with Associated Persons”. These documents outline the Bank’s approach in effectively monitoring the risks related to conflicts of interest arising in transactions with related parties and persons related thereto.
The Board also adopted a Policy on Personal Transactions (last updated in July 2019) to facilitate the identification and proper management of situations in which a director holds an interest on their own behalf or on that of third parties.
The regulation of related-party transactions aims to monitor the risk that the proximity of certain persons to the decision-making organs of the Bank and its subsidiaries may compromise the objectivity and impartiality of decisions that relate to the granting of loans and other transactions, with possible distortion of the process by which resources are allocated, the exposure of the bank to inadequately measured or monitored risks and potential damage to depositors and shareholders.
In this perspective, the term “related parties” refers, first of all, to the representatives, main shareholders and other persons who can affect the Bank’s management as they are able to exercise control, also jointly with other persons, or significant influence. Conflict of interest situations may also arise in relation to – often industrial – undertakings that are controlled or subject to significant influence in relation to which the bank is significantly exposed in the form of loans and ownership interests.
Transactions with Associated Persons
They are transactions that entail the assumption of risk activities, transfer of resources, services or obligations between the Bank and one or more Associated Persons. The following transactions are deemed to belong to this category:
Transactions with Associated Persons include but are not limited to:
Transactions with Associated Persons are classified into:
A specific procedure applies to transactions of major value, i.e. material transactions that exceed the threshold of 5% in one of the three applicable indicators depending on the specific transaction:
Download the Procedure for managing transactions with associated persons.
Download the Policy regarding control of risk assets and conflicts of interest in relation to associated persons.
Go to the archive of procedures and policies on transactions with associated persons.