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.