The Bank observes the requirements of the MiFID2 directive (Markets in Financial Instruments Directive). In accordance with them, when offering investment services the Bank is obligated to do the following before a product purchase is made by customer:
- classify the client to one of three investor groups,
- conduct a test to identity target markets and ensure that the offered investment products and services are suitable to a given client,
- provide reliable information that is not misleading about products and risks associated with investments in those products,
- to develop a policy of acting in the best interests of its clients and a policy to prevent the conflict of interest and inform the client about these policies.
To ensure the best possible protection level to its customers, the Bank applies some MiFID2 guidelines also to insurance and investment products, even though this is not required. All the marketing publications prepared by the Bank describe, among others, the risks associated with investments and sample scenarios related to the financial instrument or product. Clients are presented with complete and reliable information on the Bank’s products and financial instruments distributed by the Bank, including their issuers and the terms of the complaint process. Information on services, bank agreements and documents, letters sent to clients are drafted in a precise, comprehensible and transparent manner.
All information documents concerning investment products offered by Bank Millennium provides relevant information on the following: the investment risk, legal disclaimers and the sites where information on the funds, including financial data, is published.
Before starting to sell investment products on their own, employees must have at least six months’ experience in offering them and must pass a products knowledge test. Employees also go through mandatory training on MiFID2 and product training in the form of e-learning. Product training describes detailed characteristics of a given product and defines the risks associated with investing in a given product or financial instrument.
If the law or internal regulations governing any financial products change, e-learning refresher training is made available to employees. In addition, employees regularly take advantage of periodic market and product-related conference calls and have constant access to current product presentations. [GRI 103-2] [GRI 417-1]