Responsible sales of products and services

Reliable Marketing Communication

Marketing communication standards

Marketing materials prepared by the Bank are compliant with the laws and regulations applicable to this area, including the Canon of Best Financial Market Practices and guidelines of the guidelines laid down by the Financial Supervision Commission. Bank tracks the recommendations formulated by the Financial Supervision Commission and adapts its advertising message to those recommendations on an ongoing basis. The employees of Bank Millennium involved in the advertising work are formally obligated to observe the provisions of the Code of Ethics in Advertising defined by the Advertising Council. The Bank has also adopted its internal regulations in this respect.

Clear and advertising messages

Any change or introduction of a document or marketing material for buyers of respective products is preceded by consultations within the Bank, verification by the legal team, compliance, marketing communication and product, in order to provide clients with a clear and reliable, legally-required information about the products offered.

In accordance with the principles of advertising banking services, which were prepared by the Financial Supervision Commission Bank Millennium's advertisements are not misleading and show the important features of the products and services and related benefits and costs. They also depict their legal nature and provide information about the level of possible risk carried by the customer. If the message focuses on a promotional offer, its conditions and term of its validity are specified. Clients also receive information where they can learn about the details of the promotion.

G4-DMA PR7, G4-FS15

In 2015, there were no cases of non-compliance of Bank Millennium with regulations relating to marketing communications.

G4-PR7

Transparent Information about Products and Services

In addition to the reliable marketing communication, clients are offered tools that make it easier for them to select a product to match their needs. The Bank also applies solutions that are aimed at protecting the client’s investments.

Assistance in selection of financial products

In order to give the clients an easier choice of product matching the needs, the Bank’s website offers two solutions:

• Your Needs section, where the client receives directions on products and services that would be the most adequate for his/her financial requirements;
• tools to assist the client in selecting the most adequate product, such as a deposit comparison tool or a cash loan calculator.

Security of investments

The Bank complies with the requirements of the Markets in Financial Instruments Directive (MiFID), which obligates the Bank to convey information to clients aligned to their knowledge and experience in investing in financial instruments and products. The Bank is also obligated to provide reliable and not misleading information about products and risks associated with investments in those products and to apply the policy of acting to the best interest of its clients and the policy to prevent the conflict of interest.

Every Relationship Manager who offers investment products must undergo a mandatory product training. It includes presentation of product features as well as risks associated with investments in each product or financial instrument. Additionally, Relationship Managers take advantage of regular market conference calls and have constant access to current product presentations.

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 also 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.

G4-DMA PR3, G4-PR3, G4-FS15

Ethical Standards in Customer Service

Standards of selling products and services

Employees of the Bank’s branches are obligated to observe ethical selling standards included in the Code of Ethics and in the Book of Customer Service Standards and sales standards for individual products, such as personal accounts and credit products.

These standards contain elements such as e.g. reliable analysis of client needs, presenting the product offering with all related costs and conditions required to obtain one, diagnosing the client’s concerns, providing clarification and finally making sure that the client is familiar with the principles of the product’s operation before the agreement is concluded.

Employees have also been trained in practical application of the standards. Compliance with standards and the scope of information provided to clients by employees is regularly controlled during the evaluation of quality of the selling process using a Mystery Shopper study. All of the Bank’s outlets are subject to inspection.

G4-DMA FS15, G4-FS15

Assistance in repayment of debt

If a liability has become overdue, a client may request from the Bank to enter into an annex amending the initial agreement or, if the liability has become due and payable in full – to enter into a composition agreement for the repayment of the matured liability. If both parties accept the terms and conditions of repayment, it is possible, among others, to: reduce the repayment amount for some time, change the payment date, extend the lending period, reduce interest rates, change the order of crediting payments and, in the case of mortgage loans, a monthly repayment break.

In 2015, 6.8% of clients with significant delays in repayment took advantage of the above assistance.

Solutions for clients with a CHF loan

To curtail the adverse consequences for Clients ensuing from the growth in the Swiss franc (CHF) exchange rate at the outset of 2015 we introduced a number of solutions incorporating the Polish Bank Association’s recommendations facilitating the debt service of mortgage loans:

• The negative level of the Libor reference rates was taken into consideration in the calculation of mortgage loan rates. This caused a reduction of interest rates charged on the loans. The negative level of the reference rate drives down the CHF installment amount for clients, which offsets the increase of the installment amount (after conversion to PLN) caused by the higher CHF exchange rate.
• The spread for CHF used to settle CHF loan-related transactions was reduced to 3%.
• For Clients interested in converting the loan from CHF to PLN, the Bank introduced the possibility to convert it using the exchange rate equal to the average NBP rate on the date the conversion application is submitted.
• In the case of changes where an annex must be concluded to the loan agreement, the Bank decided not to charge fees.
• Subsidies to installments were introduced in the cases where the negative reference rate exceeded the margin.

In addition, every Client holding a mortgage loan in CHF received a proposal of special conditions for converting the currency and early repayment of CHF loans.

• currency conversion of the loan from CHF to PLN with a simultaneous reduction of the current margin by 0.2% points;
• split of the current CHF loan to two loans: one loan equal to 50% of the outstanding CHF debt on the same terms and conditions and the other equal to 50% of the currently outstanding CHF debt converted into PLN with a margin reduced by 0.2% points;
• reduction of the CHF loan margin as a result of prepayment of a portion of the current debt.

Education Programs for Clients

Publications in the media

The media publish educational and guidance statements by the Bank’s experts. In 2015, the subjects of such publications included, among others: effective saving methods, criteria to consider when applying for a cash loan or when shopping for a good personal account or a credit card, as well as convenient solutions for electronic banking.

Guide for Corporate Clients

Corporate clients receive a bulletin along with their monthly account statements containing a legal calendar including legislative changes affecting the operation of businesses, macroeconomic forecasts and an article on a specific Bank product or service.

The bulletin is also available on the Bank’s website at https://www.bankmillennium.pl/en/corporate/support

Meetings for Corporate Clients

Meetings with Clients are aimed at spreading economic knowledge, in particular knowledge about trends existing in the economy and macroeconomic forecasts. In 2015, the meetings of the Bank’s Chief Economist with representatives of companies addressed issues such as the economic growth outlook for Poland, risks and their impact on Polish companies, and many others.

Financial Manager – household budget management assistant

Every Client of the Bank’s Millenet web banking and mobile application may access, free of charge, an extensive Financial Manager, which makes it possible to manage a home budget in a simple and transparent manner. The tool offers an additional function of creating a Savings Plan based on the history of transactions from previous months.

G4-FS16