Internal Dealing

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.

Policy on Internal Dealing and key personnel

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 requirements related to identifying Key Personnel and the persons who are “closely associated” with them;
  • The management of information regarding transactions above the minimum amount threshold on shares, negotiable instruments or associated instruments issued by Banca Ifis, directly or indirectly executed by a Key Personnel member or by a “Closely Associated Person” and subject to notification requirements;
  • The management of the “closure period”, that is, those periods in which Key Personnel must abstain from executing transactions in shares and other negotiable instruments issued by Banca Ifis, as well as on financial instruments associated with them.

The list of key personnel reads as follows:

  • The members of the Board of Directors Simona Arduini, Monica Billio, Beatrice Colleoni, Luciano Colombini, Roberto Diacetti, Sebastien Egon Fürstenberg, Ernesto Fürstenberg Fassio, Frederik Geertman, Luca Lo Giudice, Antonella Malinconico, Riccardo Preve, Daniele Umberto Santosuosso.
  • The members of the Board of Statutory Auditors Giacomo Bugna (President), Marinella Monterumisi (Standing Auditor), Franco Olivetti (Standing Auditor). 
  • Executives with strategic responsibilities:
    o Chief Executive Officer: Luciano Colombini
    o General Manager: Alberto Staccione
    o Chief Financial Officer: Mariacristina Taormina
    o Head of Central Affairs Directorate: Raffaele Zingone
    o Head of Central NPL Directorate: Katia Mariotti
    o Head of Central Capital Markets Directorate: Saverio Bonavita
    o Head of Planning, Control and Annual Business Plan Development: Paolo Formigoni
    o Head of Communication, Marketing and External Relations: Rosalba Benedetto
    o Head of Investor Relations and Corporate Development: Andrea Martino Da Rio
    o Head of Legal Affairs Department: Lucia Martinoli
    o Chief Risk Officer: Walter Vecchiato
    o Head of Compliance: Francesco Peluso
    o Head of Internal Audit: Angelo Ferracchiati

The policy on internal dealing also applies to “persons closely associated” with Key Personnel.

Internal Dealing

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Related-party transactions

In December 2020, 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 February 2020) 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:

  • Mergers, demergers into two separate companies or demergers that are not strictly proportional, when carried out with related parties;
  • All decisions that relate to the allocation of remuneration and economic benefits, in any form, to the members of the management and control bodies and to executives with strategic responsibilities.

Transactions with Associated Persons include but are not limited to:

  • Granting of loans;
  • The provision of banking services (current account, savings deposits, etc.);
  • System service and/or maintenance contracts;
  • The sale/purchase and lease of real estate;
  • All actions that pertain to rights to a share of the Bank’s equity.

Transactions with Associated Persons are classified into:

  • Material transactions
  • Transactions of minor value.

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:

  •  Counter-value materiality indicator
  • Asset materiality indicator
  • Liability materiality indicator.

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.