Transactions with Related Parties and Connected Parties

In accordance with applicable regulations issued by the Bank of Italy and Consob, illimity has adopted a Policy on Transactions with Persons within the Perimeter of the illimity Banking Group with the aim of establishing, within the sphere of operations (i) of the Bank, (ii) of the Bank’s direct and/or indirect subsidiaries, pursuant to article 2359 of the Italian civil code and article 23 of Legislative Decree no. 385/1993 (the Consolidated Banking Law or “TUB”), as well as (iii) of companies in any case subject to management and coordination by the Bank, the principles and rules to be followed in order to monitor the risk that the proximity of such parties to the Bank’s decision-making centres may impair the objectivity and impartiality of assessments made for the granting of loans and for performing other transactions with such parties. The objective of this policy is to prevent possible distortions in allocating assets and resources – generated by potential conflicts of interest – and limit the Bank’s exposure to risks not adequately measured or controlled, as a means of safeguarding depositors and shareholders.

Given the points of contact between the provisions of the Consob Regulation and those of Circular 285 of the Bank of Italy, and for the purpose of rationalising and simplifying the identification and management of transactions with the Group’s related parties and/or connected parties, illimity has created a perimeter of application (the “Perimetro Unico”), which encompasses the “related parties” identified in accordance with the Consob Regulation (the “Related Parties”) and the “connected parties” referred to in Circular 285 of the Bank of Italy (the “Connected Parties”). In this respect, the policy also describes the homogeneous process adopted by illimity for properly identifying and managing transactions with parties included in the Perimetro Unico.