Our Approach
Conflicts of Interest
UniCredit has put in place specific rules related to Conflicts of Interest spanning particular content and scopes,
including:
• Global Compliance Guidelines on Conflicts of Interest which defines conflicts of interest at the Group level;
assist employees in detecting and managing conflicts of interest and provides examples of potential conflicts of
interest. These Guidelines are addressed to all Group companies and allow identifing and managing any actual
or potential conflicts of interest and any circumstances of seeming conflict they may arise. The Guidelines are
applicable across all Group business activities and are applied in compliance with the legal requirements and
regulations locally in force
• Groupwide Compliance Policy on Conflicts of Interest which supplements the Guidelines. This Policy details
a more detailed representation of the activities and responsibilities that regulate conflicts of interest
management focusing particulary on conflicts of interest involving Group customers when providing investment
services and activities, ancillary services (as defined by the EU Markets in Financial Instruments Directive, MiFID)
and specific financial services. This Policy also applies to business conflicts
• Global Compliance Policy on Conflicts of Interest focuses on outside business interests, which supplements the
Guidelines and supports managers in the definition of restrictions, exclusions, behavior rules, and procedures for
notifying and monitoring cases related to employees’ outside business activities
• Process Regulation on operating processes for Conflicts of Interest detection and management defines the main
principles and rules to detect and manage conflicts of interest regarding investment services provided by UniCredit
SpA, the Holding Company of UniCredit Group, and by Italian legal entities. Processes are defined on the basis of
potential conflicts of interest, as identified in the Groupwide Compliance Policy on Conflicts of Interest
In 2012, the Guidelines on Conflicts of Interest and the Groupwide Compliance Policy on Conflicts of Interest
were reviewed following a merger of these regulations and an introduction of new conflicts of interest types.
This document is scheduled to be issued in 2013.
Moreover, UniCredit has made progress in rolling out the Group IT tool designed to identify and manage
conflicts of interest. This tool was adopted by UniCredit Bank AG, UniCredit Bank Austria AG, UniCredit Bulbank
AD and Cordusio SIM - Advisory & Family Office SpA, Pioneer Global Asset Management SpA, Bank Pekao SA,
Zagrebačka Banka DD, UniCredit Bank Serbia JSC, UniCredit Ţiriac Bank SA and ZAO UniCredit Bank. The Group
IT tool is expected to be adopted by the main legal entities of the remaining CEE countries (e.g. Bosnia and
Herzegovina, Hungary, Slovenia and Ukraine) by 2013. This initiative was developed in order to adopt and
apply the unique Group conflicts of interest management model at the Group level as well as to comply with
MiFID where applicable. The ultimate objective is to guarantee that the interests of our Group, our employees
(including members of the strategic, control and executive bodies) and our agents do not damage the interests of
UniCredit’s customers.
In the same year, the analysis for the adoption in the main legal entities of an IT tool for the notification and
monitoring of cases of conflicts of interest involving personal interest of employees proceeded.
The Guidelines on Conflicts of Interest acknowledgement process was completed in October 2012.
Finally, in 2012, UniCredit employees were provided with roughly 49,000 training hours on conflict of interest
policies and procedures.
12 2012 Sustainability Report · UniCredit