Financial and
ESG report 2020

Transparent information about products and services

The Bank provides clients clear and understandable product information through its employees in sales and customer service channels such as branches and its phone information line, and in the form of texts in electronic channels.

All the employees who provide the clients with information are properly trained in the scope required by the law, sectoral regulations, best practices and quality standards implemented by the Bank. Bank employees are informed on an ongoing basis about any significant changes in sales and customer service through the Bank’s various internal communication channels. The product sales process is executed on the basis of standardized models to make it possible to present an offer customized to a client’s needs and expectations with options that may be of interest to him/her, along with the scope of information necessary to make an informed decision about the purchase of a given product. How sales standards are followed and the scope and quality of information provided to clients are evaluated on a regular basis through Mystery Shopper surveys and as part of client satisfaction surveys. The method of sales and customer service is also checked and streamlined through inquiries and client complaints. 

M2020-140 M2020-140

One of the primary objectives is to properly align the offer to the needs of each client. The Bank is committed to ensuring that offers/services are presented after an in-depth needs analysis and meet clients’ expectations, while being fully understandable and transparent. In the processes of account opening and establishing relationships with clients, employees use support materials provided in an attractive form, transparent, written in a language that is clear and easy to understand. These materials have been developed as a result of research and interviews with clients, and their use is aimed at correctly and accurately identifying the clients’ needs and properly adjusting the sales conversation. 

Each person visiting the website can obtain detailed information on the offer and on the dedicated services recommended by the Bank, depending on their current needs. A 24-hour Hotline is also available. 

Client filing a mortgage loan application with Bank Millennium receives, at each stage of the process, thorough information from a Bank employee about the product and the associated risks. In 2020, the Bank conducted a large-scale online training and webinars on product design and the lending process, reminding its employees how to convey the details of the offering made available to the clients in a comprehensible, reliable, and transparent manner. The training was attended by over 2,500 participants – both employees of the Bank’s sales network (approx. 1,000 participants) and the Bank’s sales partners (approx. 1,500 employees of all mortgage loan intermediaries cooperating with the Bank). 

Information regarding the mortgage products contained the Bank’s marketing materials and advertisements meets the standards set forth in the Mortgage Loan and Supervision of Mortgage Loan Intermediaries and Agents Act, and are updated on an ongoing basis.  

Information on insurance products is presented by the Bank in a manner adjusted to the sales channel of a given product, verbally or at specific stages of the sales process in the case of remote channels. Such information is also included in the insurance and/or banking documentation for the banking product for which the insurance is offered. 

The insurance documentation contains standardized detailed insurance provisions in line with the law and the guidelines of Recommendation U on good bancassurance practices with a view to ensuring a transparent presentation of the product, including: 

  • description of the insurance coverage,  
  • description of insurance benefits and rules for determining their amount in the event of occurrence of an insurable event,  
  • dates of payment and methods of calculating insurance premiums or fees,  
  • amount of the sum insured,  
  • description of the insurance coverage term and rules for continuation or renewal of such insurance,  
  • exclusions and limitations of the insurance company’s liability,  
  • principles and procedures of cancellation / termination of insurance coverage with respect to insurable event, as well as complaints and claims,  
  • name of the insurance company providing insurance coverage. 

Information on savings products in the form of a summary of the most important features or in more detail, highlighting the elements of the products concerned, can be found on the Bank’s website, obtained at any branch, via the Hotline or electronic banking channels. The Bank has been consistently improving the presentation of product information, in particular in remote channels. The employees are trained to provide a specific range of information in relation to each product, including uniform information material on savings products comparing the features of all products in an easy and accessible way. The Bank also reviews customer queries and complaints with a view to eliminating their causes. 

[GRI 419-1] In 2020, no penalties were imposed on the Bank with respect to savings products, and no consumer boycotts took place.  

With regard to investment products, the Bank issues commercial publications that are prepared with utmost care and in compliance with the applicable rules and regulations in this area, e.g. the Code of Best Practice for the Financial Market and the guidelines of the Polish Financial Supervision Authority. Bank Millennium constantly follows and adapts its materials to the recommendations of the Polish Financial Supervision Authority. Commercial publications are evaluated by the Legal Department and the Compliance Department. These units are responsible for ensuring that the materials are prepared in accordance with the law and the guidelines of the regulatory authorities.  

In addition, prior to the purchase of an investment product, the client is required to complete the Target Group and Appropriateness Test, the purpose of which is, inter alia, to review the client’s knowledge of investment services and financial products and instruments, to assess the nature, size, and frequency of transactions, and to examine whether the client belongs to the target audience for a specific instrument or product.  

Based on the answers provided, the client is assigned the Target Group and Appropriateness Score with information on products with regard to which the client is the so-called target group and which products are appropriate. The Bank does not apply any restrictions on the sale of investment products to certain groups. 

Proposals to introduce a new product are subject to evaluation at several stages, inter alia, by the Risk Department, Compliance Department and Legal Department. Participation of these units in the assessment process makes it possible to evaluate the following: 

  • acceptability of significant risks identified and how to mitigate them related to the implementation or change of the product/service,  
  • compliance of the suggested product/service with the requirements in terms of provision of appropriate information to potential clients prior to signing the contract, fulfillment of information obligations during provision of a financial service, identification of potential conflicts of interest in order to take steps to prevent them, accuracy and completeness of information provided,  
  • compliance of the suggested product/service with the applicable laws and assessment of legal risks. 

The Bank observes the requirements of the MiFID2 directive (Markets in Financial Instruments Directive). In accordance with the requirements of the MiFID2, the Bank, by offering investment services, is obligated before the purchase of a product, in particular: 

  • to classify the Client to one of the three categories of investors 
  • to conduct a Test to evaluate target markets and appropriateness of investment products and services offered for the given Client 
  • to provide reliable and not misleading information about products and risks associated with investments in those products, 
  • to develop a policy of acting in accordance with the best interests of the Clients and a policy to prevent the conflict of interest and inform the Clients about these policies. 

To ensure the best possible protection level to its Clients, 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 products 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. 

[GRI 417-1] Any information documents concerning investment products offered by Bank Millennium provides relevant information on the following: the risk associated with investment, legal disclaimers as well as the sites where information on the funds, including financial data, is published.  

If a Client wishes to purchase a product which, according to the Bank, is not appropriate for the Client or if the Bank is not able to evaluate the given product, the Bank warns the Client of this fact via the Bank’s sales application when the order is placed. The Client receives the same warning in the order form. The Client is obliged to read the warning and, if they still wish to purchase the product, they are obliged to accept the warning by signing the form. 

Before starting to offer investment products, each Relationship Manager must have at least twelve months’ experience in offering those and must pass a test of knowledge of the products. Each Relationship Manager must also undergo mandatory training on the MiFID2 and a product training in the e-learning form. The product training describes detailed characteristics of the product and clearly points to the risks associated with investments in the product or financial instrument.  

If the law or internal regulations governing any investment product change, e-learning refresher training is made available to Relationship Managers. As a result, the employees have adequate and current knowledge of the investment products offered. Additionally, the Relationship Managers take advantage of regular market and product conference calls. The Bank’s employees also have permanent access to up-to-date current product presentations. 

[GRI 419-1]  In 2020, no penalties were imposed on the Bank with respect to non-compliance with the law, and no consumer boycotts took place with respect to the investment products offered by the Bank. 

Millennium TFI does not sell the Millennium Fund Management Companies’ units directly, but through licensed entities, i.e. distributors holding the appropriate licenses to accept and forward orders of purchase or sale of units. Information on the Millennium Fund Management Companies and documents concerning the funds containing information necessary for the clients are made available to participants and potential participants on the Fund Management Company’s website and at distributors’ customer service points.   

The Fund Management Company drafts various information materials for the clients, in particular: prospectuses, terms of issue, key investor information documents (KIID), information for participants of Alternative Investment Funds (AIF), or information sheets of investment sub-funds. Moreover, in 2020, the employees of Millennium TFI conducted training for the employees of the Bank Millennium’s distributor providing services directly to the investment fund participants. Training covered information on investment funds managed by the Millennium TFI, financial instruments, and the equity market mechanisms.  

[GRI 419-1] In 2020, no penalties with respect to non-compliance with the law or other standards were imposed, and no consumer boycotts took place. 

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