290 likes | 432 Views
“Arrangements and procedures on the sales of financial products: Good practices (to follow) and Poor practices (to avoid) to strengthen social dialogue and industrial relations at European and company level” VS/2010/0737. With EU contribution. APF-FIBA/CISL PROJECT AND PARTNERS
E N D
“Arrangements and procedures on the sales of financial products: Good practices (to follow) and Poor practices (to avoid) to strengthen social dialogue and industrial relations at European and company level”VS/2010/0737 With EU contribution APF-FIBA/CISL PROJECT AND PARTNERS “Arrangements and procedures on the sales of financial products: good practices (to follow) and poor practices (to avoid) to strengthen social dialogue and industrial relations at European and company level” (VS/2010/0737) Budget Heading: 04.03.03.01 (Social Dialogue) BBDSZ (Hungary), CFDT-Banques (France), FES-UGT (Spain), OSPPP (Czech Rep.), OTOE (Greece), OZPPaP (Slovakia), UNITE (UK), Federmanagement (Italy), UNI Europa
PROJECT’S OBJECTIVES • - INCREASE SPECIFIC TECHNICAL COMPETENCES AND EXPERTISE OF PARTICIPANTS • STRENGTHEN COMPANY AND SECTOR SOCIAL DIALOGUE AT NATIONAL AND TRANSNATIONAL • LEVEL • CONTRIBUTE TO EUROPEAN COMMISSION DG INTERNAL MARKET CONSULTATIONS ON THE • REVIEW OF THE MIFID AND/OR FURTHER DIRECTIVES WITH AN IMPACT ON THE SALE OF • FINANCIAL PRODUCTS
PROJECT’S STRUCTURE: • TRAINING AND INFORMATION STEPS • KICK-OFF MEETING: HARMONIZATION OF COMPETENCIES ON THE DIRECTIVE 2004/39/CE AND ANALYSIS OF NATIONAL FINANCIAL MARKETS STRUCTURE • (DIMENSIONS, COMPLEXITY, EEC MARKETS) • WORKSHOP MAY 2011: EMPLOYEES’ PROTECTION AND RESPONSIBILITIES, THE MIFID • COMPLIANT SYSTEM • SEMINAR JULY 2011: THE REVIEW OF THE MIFID WITH A FOCUS ON MARKETS, PRODUCTS • AND EMPLOYEES • 4) FINAL CONFERENCE OCT 2011
PROJECT’S STRUCTURE: QUESTIONNAIRE AND VIRTUAL FORUM FORUM: - VIRTUAL PLACE FOR DISCUSSION, DATABASE WITH ALL PROJECT’S DOCUMENTS, - CORNERSTONE FOR DISSEMINATION OF PROJECT’S RESULTS (OPEN TO PUBLIC CONSULTATION AT THE END OF THE PROJECT, LINK TO PARTNERS’ WEBSITES) AND FOLLOW UP (UPDATES) QUESTIONNAIRE: - A WAY TO ANALYSE AND SUM UP THE MOST SIGNIFICANT AND CRITICAL ASPECTS IN THE IMPLEMENTATION OF THE MIFID AND IDENTIFY GOOD AND POOR PRACTICES TO BE CAREFULLY CONSIDERED IN FUTURE ROUNDS OF SOCIAL DIALOGUE AT DIFFERENT LEVELS - FOCUS ON SPECIFIC MIFID RELATED ISSUES WITH A DIRECT IMPACT ON EMPLOYEES’ ROLES AND RESPONSIBILITIES: TRAINING AND INFORMATION, INCENTIVE SYSTEMS AND COMMERCIAL PRESSURES, PROFESSIONAL RISKS AND RESPONSIBILITIES
POOR PRACTICES (TRADE UNIONS, BANKS, AUTHORITIES) • ITALY • CONTRACTUAL RULES AND PROCEDURES ON INCENTIVE SYSTEMS OFTEN “ONLY” FORMAL, • WHILE BANKS CAN ANYWAY PROCEDE APPLYING THEM AFTER TRADE UNION CONSULTATION • INADEQUATE SPECIFIC PROFESSIONAL TRAINING (MAINLY E-LEARNING) • PRODUCT CAMPAIGNS DO EXIST WITH LITTLE CONCRETE CONTROL • SHORT TERM TARGETS ARE QUITE COMMON • EVIDENCE OF BANK MISCONDUCTS ON CLIENT PROFILING (TARGETS ON IT), FORCING ON • ADEQUACY AND APPROPRIATENESS TEST, PROFESSIONAL CLIENTS AND EXECUTION ONLY • INFORMATION ASIMMETRY EITHER BETWEEN BANKS AND EMPLOYEES OR EMPLOYEES AND • CLIENTS • COMMERCIAL PRESSURES ARE STILL THE MOST CRITICAL POINT
POOR PRACTICES • UNITED KINGDOM • - SIGNIFICANT INCREASE IN COMPLAINTS • - TO BECOME ‘QUALIFIED’ IS CAUSING CONCERNS AND PRESSURES TO REDUCED HOURS STAFF • (PART TIME WORKERS), WHICH USUALLY IMPACTS FEMALES • STAFF ARE STILL WORKING UNDER AN UNTENABLE AND UNREALISTIC SALES CULTURE • HIGH LEVEL OF COMMERCIAL PRESSURES • FAILURE TO REACH TARGET COULD AND STILL DOES ULTIMATELY LEAD TO DISMISSAL
POOR PRACTICES • SPAIN • INCREASED COSTS, WORKLOAD AND RESPONSIBILITIES, WITH NEGATIVE IMPACT ON • EMPLOYEMENT (LITTLE AWARENESS OF RISKS) • SOME FINANCIAL PRODUCTS EXCLUDED FROM MIFID APPLICATION • THE SOFTWARE SYSTEM CAN BE FOOLED • BAD CLIENT PROFILING • MAINLY ON-LINE TRAINING COURSES • NO ARBITRATION SYSTEM TO SETTLE PROBLEMS BETWEEN CLIENTS AND EMPLOYEES (INCREASE • OF COMPLAINTS, WITH ALREADY 262 COURT SENTENCES IN FAVOUR OF CLIENTS) • COMMERCIAL PRESSURES AND HIGH COMMERCIAL TARGETS • EMPLOYEES MAY BE DISMISSED IN CASE OF NO REACHING OF COMMERCIAL TARGETS
POOR PRACTICES • GREECE • INCREASE OF COSTS HIGHER THAN BENEFITS OF IMPLEMENTATION • INCREASE OF ORGANISATIONAL COMPLEXITY AND OPERATIONAL WORKLOADS DUE TO TRAINING • ISSUES AND COMMERCIAL PRESSURES • SIGNIFICANT INCREASE IN CLIENT’S COMPLAINTS (EVIDENCE OF BETTER CUSTOMER FINANCIAL • EDUCATION AND PROBLEMS IN COMMERCIAL BEHAVIOURS) • NO CONTRACTUAL PROVISIONS ON MIFID RELATED ISSUES
POOR PRACTICES • FRANCE • LESS TRASPARENCY, INCREASE OF ACTORS IN THE MARKET, CREATION OF ‘DARK POOLS’ AND • HIGH SPEED TRADING (RAPPORT FLEURIOT) • DIFFERENT QUESTIONNAIRES IN DIFFERENT BANKS, INDIVIDUAL JUDGEMENT RATHER THAN • OBJECTIVE CRITERIA (AMF REPORT) • TRAINING IS OFTEN ONLY FORMAL AND DONE BY E-LEARNING (CFDT REPORT) • INCENTIVE SYSTEMS ARE LARGELY UNDISCLOSED AND MAY LEAD TO THE SALE OF • INAPPROPRIATE PRODUCTS TO THE CLIENT • WORK ETHICS: IN MANY INTERNAL REGULATIONS A GENERAL PRINCIPLE STATES THE • EMPLOYEES MUST KNOW ALL INTERNAL RULES AND PROCEDURES, THIS WAY SHIFTING • RESPONSIBILITIES TO THE LEVEL OF STAFF IN DIRECT CONTACT WITH THE CLIENT. NON RESPECT • OF RULES MAY LEAD TO DISCIPLINARY ACTION. • - NO SECTOR AGREEMENTS DIRECTLY RELATED TO MIFID ISSUES.
POOR PRACTICES FRANCE CFDT STUDY ON THE IMPACT OF MIFID ON BANK EMPLOYEES REPORTED CRITICALITIES ON: - TRAINING (ON NEW PRODUCTS AND ON GIVING ADVICE): CLIENT ADVISORS OFTEN UNDER TIME PRESSURE AND WITH NO SUFFICIENT TIME TO INFORM THEMSELVES ABOUT NEW PRODUCTS. TRAINING IS OFTEN ONLY FORMAL AND DONE BY E-LEARNING (25% SAID HAVING RECEIVED NO TRAINING AT ALL). - WORKLOAD: INCREASED DUE TO CLIENT RISK PROFILING AND MORE REPORTING REQUIREMENTS WITH NO ADDITIONAL RECRUITMENT. - VARIABLE REMUNERATION AND INCENTIVE SYSTEMS: TRADE UNIONS NOT INVOLVED IN TARGET SETTING, INCENTIVE SYSTEMS LARGELY UNDISCLOSED (ALMOST NO CHANGES AFTER THE TRANSPOSITION OF THE MIFID). - WORK ETHICS (CONFLICT OF INTERESTS, ACCOUNTABILITY ISSUES): INDUCEMENTS MAY LEAD TO THE SALE OF INAPPROPRIATE PRODUCTS, MANAGEMENT AND PRODUCT CREATORS SHOULD SHARE PART OF THE LIABILITY, LITTLE KNOWLEDGE OF RISKS (OF NOT APPLYING A PROCEDURE), BUT GENERAL FEAR OF DISCIPLINARY SANCTIONS. 21
POOR PRACTICES • HUN • NO LEGAL MINIMUM REQUIREMENTS OF PROFESSIONAL COMPETENCES FOR SALE EMPLOYEES • THE USE OF MIFID TESTS (PROFILING, ADEQUACY, APPROPRIATENESS) IS NOT HOMOGENEOUS • INVESTMENT ADVICE PRIOR TO/WITHOUT SUITABILITY TEST • NO DETAILED INFORMATION ON CERTAIN FINANCIAL PRODUCTS, REGARDING INDUCEMENTS, • HIDDEN FEES AND COMMISSIONS • FAILURE TO ADHERE TO THE INDIVIDUAL SELLING PLAN MAY LEAD TO DISMISSAL
POOR PRACTICES • CZECH REP • SPECIFIC PROFESSIONAL TRAINING IS MAINLY THROUGH E-LEARNING COURSES • LITTLE TRANSPARENCY ON BONUS/INCENTIVE SYSTEMS RULES AT COMPANY LEVEL (CONDITIONS • FOR INCENTIVES CAN BE CHANGED EVEN EACH QUARTER) • TOO MUCH INFORMATION TO CLIENTS, WITH A FINAL USELESS RESULTS IN TERMS OF LEVEL OF • PROTECTION • COMMERCIAL PRESSURES HAVE INCREASED ON THE SALE OF PRODUCTS (EG. DAILY SALES • RESULTS MUST BE REPORTED VIA SMS) • VERY AMBITIOUS PLANS SET FOR SELLERS • UNSUCCESSFUL EMPLOYEES RECEIVE REPROACHING/REPROVING LETTER THAT MAY RESULT • IN DISMISSAL.
POOR PRACTICES • SLOVAKIA • TOO MUCH DETAILED INFORMATION HAS NO SIGNIFICANT INFLUENCE ON CLIENTS’ DECISIONS • - SPECIFIC PROFESSIONAL TRAINING IS MAINLY E-LEARNING • INCENTIVE SYSTEMS IN THE FORM OF ‘BEST SELLER COMPETITION’ • - SHORT TERM TARGETS ANS BONUSES • NO PROVISIONS ON MIFID RELATED ISSUES IN COLLECTIVE AGREEMENTS, PROVISIONS • ONLY FOR THIRD PARTIES (INVESTMENTS COMPANIES WHICH SELL BANKS PRODUCTS) • COMMERCIAL PRESSURES (MAINLY ON THE SALE OF BANK PRODUCTS, LOANS, DEPOSITS, • MORTGAGES) • - EMPLOYEES MAY BE DISMISSED IN CASE OF NO REACHING OF COMMERCIAL TARGETS
SYNTHESIS OF POOR PRACTICES • - SPECIFIC PROFESSIONAL TRAINING THROUGH E-LEARNING/ON LINE COURSES: • ITALY, SPAIN, FRANCE, FRANCE, HUNGARY, CZECH REP, SLOVAKIA • INCREASE OF WORKLOADS AND TRANSFER OF RESPONSIBILITIES TO SALE STAFF: • ITALY, UK, SPAIN, GREECE, FRANCE • HIGH LEVELS OF COMMERCIAL PRESSURES ON QUANTITATIVE/SHORT TERM TARGETS: • ITALY, UK, SPAIN, FRANCE, HUNGARY, CZECH REP, SLOVAKIA • DISCIPLINARY SANCTIONS UP TO DISMISSAL FOR “UNSUCCESSFUL” SALE EMPLOYEES: • HUNGARY, CZECH REP, SLOVAKIA, UK, SPAIN, 25
GOOD PRACTICES (TRADE UNIONS, BANKS, AUTHORITIES) • ITALY • - CIRCULARS AND REGULATION BY BANCA D’ITALIA: • LATEST 31ST MARCH 2011, WITH SPECIFIC DUTIES IN CHARGE OF THE STRUCTURE OF • COMPLIANCE WITH REFERENCE TO INCENTIVE SYSTEMS, • - REGULATION AND INITIATIVES BY CONSOB: • 5TH MAY 2010, WITH MANDATORY CONVENING OF THE BOARD OF DIRECTORS OF THE FIVE • BIGGEST BANKS TO STOP THEIR COMMERCIAL MISCONDUCTS • - TRADE UNIONS INITIATIVES: • FIBA-CISL INFORMATION AND TRAINING MEETINGS WITH AFFILIATES AND EMPLOYEES (ABOUT • ONE HUNDRED AND TWENTY MEETINGS WITH MORE THAN TEN THOUSAND SALE STAFF • PARTICIPANTS)
GOOD PRACTICES • ITALY • - SECTOR PROTOCOL ON CSR (2004): • QUALITY TARGETS, SPECIFIC TRAINING FOR SALE STAFF, SEARCH FOR SHARED SOLUTIONS • SECTOR COLLECTIVE AGREEMENT (PROVISIONS ON INCENTIVE SYSTEMS SINCE 1999): • TRANSPARENCY OF RULES, RECOGNITION OF INDIRECT CONTRIBUTIONS, MANDATORY TRADE • UNION CONSULTATION PRIOR TO APPLICATION, COHERENCE WITH THE DISPOSITIONS OF BANCA • D’ITALIA ON SUPERVISION AND COMPLIANCE • COMPANY CLIMATE COLLECTIVE AGREEMENTS (UNICREDIT, BANCA INTESA): • LIMITS TO COMMERCIAL PRESSURES, TOOLS TO PREVENT/MANAGE MISCONDUCTS, MONITORING • REQUESTS FOR NEW SECTOR C.A. (2011): • NEGOTIATE THE DISTRIBUTION CRITERIA OF BONUSES, MEDIUM-LONG TERM OBJECTIVES, LIMITS • TO PAYMENT OF BONUSES, SAME RULES FOR PRODUCT CAMPAIGNS
GOOD PRACTICES • UNITED KINGDOM • SIGNIFICANT BODY OF REGULATION IN NATIONAL LAW COVERING THE VAST MAJORITY OF RETAIL • FINANCIAL FIRMS AND PRODUCTS. • WELL-ESTABLISHED DIALOGUE WITH COMPETENT AUTHORITIES (FSA): TRADE UNIONS HAVE • REPORTED HIGHLIGHTS, FINDINGS AND THE RISK TO THE FINANCIAL INDUSTRY • ONLY ‘QUALIFIED’ EMPLOYEES CAN SELL REGULATED PRODUCTS • THE INTRODUCTION OF MIFID RESULTED IN A MORE ROBUST RISK AND CUSTOMER COMPLAINTS • PROCESS. • TRADE UNION REQUESTS (COMPANY LEVEL): TRANSPARENCY OF REMUNERATION SYSTEMS • (INCLUDING INCENTIVE SYSTEMS), TO TRY AND NEGOTIATE SALES TARGETS AS REALISTIC AND • ACHIEVABLE AND ONLY TO MEET CUSTOMER NEEDS.
GOOD PRACTICES • GREECE • HIGHER TRANSPARENCY AND IMPROVED FUNCTIONING OF THE FINANCIAL MARKETS • INCREASED CUSTOMER FINANCIAL EDUCATION • - OBLIGATORY CERTIFICATION PROGRAMME OF EMPLOYEES’ EXPERTISE BY NATIONAL • AUTHORITIES (CENTRAL BANK OF GREECE AND HELLENIC CAPITAL MARKET COMMISSION) • CODES OF CONDUCT FOR EXPECTED EMPLOYEES’ BEHAVIOUR AND COMPLIANCE STANDARD • TRADE UNION REQUESTS FOR PRINCIPLES AND FRAMEWORKS FOR TARGET SETTING, • PERFORMANCE APPRAISAL, SUPPLEMENTARY REMUNERATIONS, CORPORATE SOCIAL • RESPONSIBILITY
GOOD PRACTICES • SPAIN • CODES OF CONDUCT AND GUIDELINES SIGNED BY THE BANKS • MORE QUALITY AND QUANTITY IN SPECIFIC TRAINING • TRADE UNION INITIATIVES AND REQUESTS FOR: • REVISION OF EMPLOYEES’ RESPONSIBILITY DUE TO COMMERCIAL PRESSURES AND • INADEQUATE SOFTWARE • ENTERING ARBITRATION ON MIFID ISSUES INTO SECTOR COLLECTIVE AGREEMENT • BUILDING AN OBSERVATORY ON THE IMPLEMENTATION OF THE MIFID
GOOD PRACTICES • FRANCE • GOVERNMENT REPORT ON THE IMPACT OF THE MIFID (RAPPORT FLEURIOT, 2010) FOCUSED ON • ORGANISATIONAL MATTERS OF THE MKT, PRODUCT DEFINITION AND TRADING ISSUES (CLIENT • PROTECTION IS NOT TREATED AS A PRIORITY). • FRENCH SUPERVISOR STUDY ON CLIENT PROFILING (FEB 2011. • CFDT STUDY ON THE IMPACT OF THE MIFID ON BANK EMPLOYEES ON FOUR TOPICS. • - EXTENSIVE OBLIGATION FOR THE TRAINING OF EMPLOYEES. • - CFDT HAS REQUESTED EMPLOYERS’ FEDERATION OF BANKS TO OPEN DISCUSSION ON • VARIABLE REMUNERATION SYSTEMS (INDUCEMENT SYSTEMS), PROFESSIONAL TRAINING, WORK • CONDITIONS, COMMERCIAL PRESSURES AND WORK RELATED STRESS. • CFDT HAS INFORMED FRENCH SUPERVISORS ABOUT THE OUTCOME OF THE INTERNAL STUDY • CFDT WILL ALSO INFORM THE EUROPEAN COMMISSION DG INTERNAL MARKET.
GOOD PRACTICES • HUNGARY • DETAILED INFORMATION PROVIDED TO CLIENTS • DIFFERENT EXECUTION VENUES AVAILABLE IN THE INTEREST OF CLIENTS • STRUCTURED SOCIAL DIALOGUE WITH NATIONAL FINANCIAL AUTHORITIES (HFSA) • - PROFESSIONAL TRAINING AND MONITORING BY INDEPENDENT UNITS • - TRADE UNION REQUEST TO INCLUDE MIFID RELATED ISSUES IN COLLECTIVE AGREEMENTS
GOOD PRACTICES • CZECH REPUBLIC • SOME ASPECTS OF MIFID RELATED ISSUES (EG. INCENTIVE SYSTEMS, STAFF RESPONSIBILITIES) • ARE USUALLY COVERED BY COMPANY INTERNAL REGULATION (BUT LITTLE TRANSPARENCY). • MANDATORY TRAINING (E-LEARNING*) AND REGULAR UPDATE OF INTERNAL CERTIFICATION OF • TRAINING. • STRUCTURED SOCIAL DIALOGUE BETWEEN TRADE UNIONS AND MANAGEMENT AT SECTOR AND • COMPANY LEVEL, WITH • JOINT EFFORT TO PROMOTE A TRANSPARENT DISTRIBUTION MODEL (WITH AN EMPHASIS ON • RESPONSIBLE AND QUALIFIED PRODUCT SALES) AND TO ELIMINATE COMMERCIAL PRESSURES • ON EMPLOYEES • SOCIAL DIALOGUE AT EWC LEVEL (SOME BIG BANKS) IS ALSO INVOLVED
GOOD PRACTICES • SLOVAKIA • SEVERAL SPECIFIC LAW ACTS DEFINE DETAILED PROCEDURES OF MIFID IMPLEMENTATION • (BANKS, STOCK EXCHANGE, CONSUMERS’ PROTECTION, FINANCIAL CONSULTANTS) • CERTIFICATION OF EMPLOYEES’ EXPERTISE BY THE FIN MKT SUPERVISION UNIT (NATIONAL BANK) • PROFESSIONAL EXAMS FOR SALE STAFF PLANNED EVERY FOUR YEARS • COMPLEX AND RISKY PRODUCTS ARE ONLY PROVIDED TO THE CENTRAL DEPT OF BANKS • THE VOLUME OF FINANCIAL PRODUCTS SOLD TO RETAIL CLIENTS DOES NOT HAVE A SIGNIFICANT • IMPACT ON BANK PROFITS (HISTORICAL AND CULTURAL REASONS) • NO SPECIAL BONUSES ARE PROVIDED FOR SELLING FINANCIAL PRODUCTS
SYNTHESIS OF GOOD PRACTICES - CONSOLIDATED DIALOGUE WITH NATIONAL FINANCIAL AUTHORITIES: ITALY, UK, HUNGARY, FRANCE - SPECIFIC PROFESSIONAL TRAINING CERTIFICATION FOR SALE STAFF: GREECE, UK, CZECH REP, SLOVAKIA, HUNGARY, SPAIN, FRANCE - SIGNED COLLECTIVE AGREEMENTS ON MIFID RELATED ISSUES: ITALY - TRADE UNIONS REQUESTS FOR FUTURE NEGOTIATIONS ON MIFID RELATED ISSUES: ITALY, UK, CZECH REP, HUNGARY, FRANCE, SPAIN, GREECE, SLOVAKIA 14
“GOOD” TARGETS & LEVELS EUROPEAN SECTOR SOCIAL DIALOGUE: - CREATION OF AN OBSERVATORY ON THE IMPLEMENTATION OF THE MIFID, - MINIMUM REQUIREMENTS FOR SPECIFIC PROFESSIONAL TRAINING (AS A FOLLOW UP OF LIFE LONG LEARNING JOINT DECLARATION) AND ASSESSMENT, - JOINT DECLARATION ON RESPONSIBLE SALES EUROPEAN COMMISSION DG INTERNAL MARKET: - CREATION OF AN OBSERVATORY ON THE IMPLEMENTATION OF THE MIFID, - EXTERNAL CERTIFICATION OF PROFESSIONAL TRAINING AND COMPETENCES, - CONDITIONS FOR VARIABLE REMUNERATION SYSTEMS AND RISK MANAGEMENT NATIONAL SUPERVISORY AUTHORITIES: - CREATION OF AN OBSERVATORY ON THE IMPLEMENTATION OF THE MIFID, - EXTERNAL CERTIFICATION OF PROFESSIONAL TRAINING AND COMPETENCES, - BOTTOM-UP APPROACH WITH INFORMATION/CONSULTATION STRUCTURE 15
“GOOD” TARGETS & LEVELS SECTOR COLLECTIVE AGREEMENTS: - CREATION OF AN OBSERVATORY ON THE IMPLEMENTATION OF THE MIFID, - PROVISION OF ARBITRATION PROCEDURES (CLIENT/EMPLOYEES, BANK/EMPLOYEES), - MINIMUM REQUIREMENTS FOR SPECIFIC PROFESSIONAL TRAINING AND ASSESSMENT, - CONDITIONS FOR INCENTIVE SYSTEMS AND RESPONSIBLE SALES, - WORK-RELATED STRESS COMPANY COLLECTIVE AGREEMENTS/EWC LEVEL: - PROVISION OF ARBITRATION PROCEDURES (CLIENT/EMPLOYEES, BANK/EMPLOYEES), - “CLIMATE AGREEMENTS” ON INCENTIVE SYSTEMS, RESPONSIBLE SALES AND MONITORING, - CONDITIONS FOR SPECIFIC PROFESSIONAL TRAINING AND ASSESSMENT, - WORK-RELATED STRESS AND WORKING CONDITIONS, - CODES OF CONDUCT 16
OVERALL CONCLUSIONS AND RESULTS • - THE DIRECTIVE: • IMPLEMENTATION OF THE MIFID IS NOT ENOUGH HOMOGENEOUS • PROTECTION OF CLIENTS AND BANK EMPLOYEES HAS NOT SIGNIFICANTLY INCREASED • - JOINT INITIATIVES OF UNI EUROPA FINANCE AFFILIATES ON RESPONSIBLE SALES: • BELGIUM: NEW PROVISIONS IN BANK SECTOR COLLECTIVE AGREEMENT • BARCLAYS: JOINT DECLARATION ON RESPONSIBLE SALES AT EWC LEVEL • UNICREDIT: EWC REQUEST TO NEGOTIATE A JOINT DECLARATION ON RESPONSIBLE • SALES • EUROPEAN BANK SOCIAL DIALOGUE: REQUEST OF UNI EUROPA FINANCE TO NEGOTIATE A JOINT DECLARATION ON RESPONSIBLE SALES 26
DISSEMINATION AND FOLLOW UP - PROJECT’S WEB SITE: DATABASE WITH ALL PROJECT’S DOCUMENTS, CORNERSTONE/CENTRAL POINT FOR DISSEMINATION OF PROJECT’S RESULTS (OPEN TO PUBLIC CONSULTATION) LINK TO TRADE UNION PARTNERS’ WEBSITES LINK TO UNI EUROPA FINANCE WEBSITE - PRESENTATION OF PROJECT’S RESULTS IN UNI EUROPA FINANCE AND EUROCADRES MEETINGS - PRESENTATION OF PROJECT’S RESULTS TO THE EUROPEAN COMMISSION DG INTERNAL MKT - PARTICIPATION IN SOCIAL DIALOGUE AND COLLECTIVE BARGAINING INITIATIVES AT EUROPEAN, SECTOR, COMPANY AND TRANSNATIONAL LEVEL (EWCs) - FUTURE PROJECTS
THANKS! Luciano Malvolti Project Manager lucianomal@libero.it