CONFIDENTIAL – NOT FOR PUBLICATION
Public Affairs
Institutional International Relations
29 April 2011
UniCredit’s reply to the European Commission Public Consultation
“Towards a Coherent European Approach to Collective Redress”
(ID Number 03094871618-32)
UniCredit agrees with the European Commission on the need for a coherent
European approach to Collective Redress.
However, we believe such approach should be based on the following main
principles:
- the EU should set out general and non binding rules while there is no
need for an EU legislative intervention;
- no collective redress mechanism should be established in sectors where
alternative dispute resolution mechanisms are already available, such
as in the financial sector;
- no abuse of collective redress should be possible: if on one side
consumer protection has to be improved by establishing an easy access to
efficient collective redress mechanisms, on the other side, no artificial
incentive to litigiousness has to be permitted.
- the opt-in mechanism according to which consumers which suffered an
infringement of law and want to submit a claim, have to join the action
which has been already promoted on that same infringement by consumer
associations or other consumers.
***
Q 1 What added value would the introduction of new mechanisms of
collective redress (injunctive and/or compensatory) have for the
enforcement of EU law?
UniCredit regards important that collective redress mechanisms are
introduced at national level through national legislative tools in full compliance
with the principles of subsidiarity and proportionality. Thus, Unicredit disagrees
with the proposal to possibly introduce a new mechanism at European level
but believes the EU should intervene only by setting out general principles.
1
CONFIDENTIAL – NOT FOR PUBLICATION
Moreover, in UniCredit’s opinion, a better coordination between existing
national systems – in the way specified further in the replies to questions n. 13
and 15- could permit a speedy solution of disputes by reducing burdens and
uncertainties for operators. This would enforce EU law and would make the
European market more competitive and dynamic.
Q 2 Should private collective redress be independent of, complementary
to, or subsidiary to enforcement by public bodies? Is there need for
coordination between private collective redress and public
enforcement? If yes, how can this coordination be achieved? In your
view, are there examples in the Member States or in third countries that
you consider particularly instructive for any possible EU initiative?
UniCredit believes that private collective redress cannot in any case limit the
guarantees that the public enforcement ensures to individuals for the
protection of their rights. Therefore the two tools should be complementary to
one another. A coordination among the two tools should be ensured at
national level in compliance with the specific legal traditions and civil
proceedings law of each country.
Q 3 Should the EU strengthen the role of national public bodies and/or
private representative organisations in the enforcement of EU law? If so,
how and in which areas should this be done?
No further strengthening is needed in areas such as Antitrust and Consumer
protection laws, where national public bodies and private representative
organizations are already given a significant role in the enforcement of EU
law. Countries that have not introduced collective redress mechanisms, should
strengthen the role of the private representative organizations according to the
general principles that UniCredit believes the Commission should set out in
this regard.
Q 4 What in your opinion is required for an action at European level on
collective redress (injunctive and/or compensatory) to conform with the
principles of EU law, e.g. those of subsidiarity, proportionality and
effectiveness? Would your answer vary depending on the area in which
action is taken?
As already stated, UniCredit considers that the EU should only establish
general and non binding principles, according to the EU fundamental
subsidiarity and proportionality principles, with the aim to ensure an effective
system of collective redress tailored on national legal traditions and systems.
UniCredit agrees with the European Commission on the following principles to
be applied to all forms of collective redress:
(1) the need for effectiveness and efficiency of redress;
(2) the importance of information and of the role of representative bodies;
(3) the need to take account of collective consensual resolution as a means of
alternative dispute resolution;
(4) the need for strong safeguards to avoid abusive litigation.
2
CONFIDENTIAL – NOT FOR PUBLICATION
Moreover, UniCredit suggests that the EU makes a careful analysis of the
different national systems and practices in order to eliminate those differences
which constitute an actual limit for an easy access by consumers to cross-
border collective redress mechanisms.
Q 5 Would it be sufficient to extend the scope of the existing EU rules on
collective injunctive relief to other areas; or would it be appropriate to
introduce mechanisms of collective compensatory redress at EU level?
In order to respect the subsidiarity principle and in consideration of the fact
that many Member States adopted collective redress mechanisms at national
level, UniCredit sees no reason to extend or introduce new collective redress
mechanisms at European level in banking and financial sector. UniCredit
regards however important that the EU adopts general common principles
which should encourage the Member States that have not adopted such
mechanisms to adopt them and comply with such principles.
Q 6 Would possible EU action require a legally binding approach or a
non-binding approach (such as a set of good practices guidance)? How
do you see the respective benefits or risks of each approach? Would
your answer vary depending on the area in which action is taken?
In UniCredit’s opinion, the role of the EU in relation to consumer collective
redress should only be issuing non binding general principles.
As to the proposal to introduce a European collective redress, UniCredit
regards time as not being ripe, since initiatives for collective redress adopted
in some Member States have been introduced only recently. Moreover the
introduction of a legally binding approach at EU level through a single court
procedure, valid for all Member States, seems difficult given the diversity of
legal systems in different Member States, based on different legal principles
even at times difficult to reconcile. It is believed that the involvement of
Member States in creating better systems for settlement of collective disputes
could be effectively pursued through the adoption of non-binding instruments.
The adoption and the use of non binding instruments, but equally authoritative
(inducing Member States or directly the companies to the implementation of
the objectives through an action of a moral suasion) are appreciated. The
advantage of this approach is to allow each State to assess the best practices
on the basis of the findings emerging from the concrete application of the
institution at national level. The risk is clearly to greater uncertainty about the
effective coordination at European level on this issue. Moreover UniCredit
believes that best practices, in the long period, should be made of application
in all those States that want to really enhance the competitiveness and
effectiveness of a single market.
Q 7 Do you agree that any possible EU initiative on collective redress
(injunctive and/or compensatory) should comply with a set of common
principles established at EU level? What should these principles be? To
which principle would you attach special significance?
3
CONFIDENTIAL – NOT FOR PUBLICATION
As said above, UniCredit believes the EU intervention in this domain has to
limit itself to set general principles. In UniCredit’s opinion such principles
should consist in :
1. no artificial incentives to litigiousness: UniCredit is of the opinion that if
consumer protection has to be improved by establishing an easy access to
efficient collective redress mechanisms, artificial incentives to litigiousness
could come into being. The bank-financial sector is exposed to even
greater risks of degeneration of the use of class actions compared to other
sectors, since it is easy to confuse consumers’ protection, as regards to
the alleged illegal behavior of operators, with a general need of protection
against possible losses caused by financial investments. That is why
UniCredit observes that, based on the American experience, it is
necessary to avoid a class action which is managed by lawyers with the
total lack of participation by the client or the class represented in the
proceedings. The assessment of the admissibility of an action has to be
conducted on the basis of the probabilities of its success in court and not in
relation to the total amount of the damages on which legal fees are based.
Otherwise, the risk is that lawyers could distort the aims of this tool and
raise possible conflict of interests issues with their clients. It is therefore
necessary to avoid those mechanisms which, by supporting the interests of
the lawyers, allow initiating class actions against solvent defendants
claiming exorbitant damages, even if they are affected by an intrinsic
weakness of the arguments that can be put forth in defense of these
claims, to the detriment of cases with greater chances of success in court
but which have a lower value.
2. no collective redress in case of ADR mechanisms already available:
when alternative dispute resolution mechanisms exist for specific sectors,
such as those foreseen for banks in Italy, class action should not be
allowed for companies belonging to such sectors. Such mechanisms have
the unquestionable advantages of lower charges and greater efficiency
while decreasing the workload of judicial bodies.
3. the “loser pays” principle, according to which who loses the dispute has
to pay all the costs and fees of the relative procedure. This would be an
effective safeguard to avoid abusive claims;
4. the opt-in mechanism according to which consumers who suffered an
infringement of law and want to submit a claim, have to join the action
which has been already promoted on that same infringement by consumer
associations or other consumers;
5. representativeness of the bodies entitles to initiate a collective
redress action: UniCredit is of the opinion that the right of action should
be granted to consumer associations that can truly be considered
representative according to criteria to be set by law (see for further details
reply to question n. 22);
6. equal and non punitive damages: the compensation to be provided by
traders/service providers against whom actions have been successfully
brought should be at least equal to the harm caused by the incriminated
conduct, but should not be excessive as to amount for instance to punitive
damages. The provision for exemplary damages should be prohibited as it
is not acceptable for a civil judgment to order the payment of a substantial
amount of money if it is not for effective compensation.
4
CONFIDENTIAL – NOT FOR PUBLICATION
7. inapplicability of collective redress to SMEs: since they cannot be
qualified as a "weaker party", they should not enjoy the protection which is
at the basis of the discipline concerned.
8. exclusion of the grading of the attorneys’ fees: UniCredit is strongly in
favour of excluding the grading of the attorneys’ fees to the entity of the
compensation obtained. The possibility to establish a remuneration graded
at the outcome of the dispute, might entail the risk that attorneys of
consumer associations are little inclined to fix the matter by common
agreement, or of their fixing conditions that are quite onerous. UniCredit
regards as important to avoid those mechanisms which have the distorting
effect of putting pressure on the companies to settle a case although
having strong defensive arguments not only to the detriment of a thorough
analysis of the merits of a collective action, but above all to the detriment of
the future conduct of the companies insofar as their strategic and
economic choices.
9. ne bis in idem: decisions taken on a collective action, either positive or
negative, should be indisputable towards each consumer part of the class
action. The outcome of the class action should be published thus
precluding the proposition of further class actions on the same subject.
10. no retroactivity: any law introducing a class action should not be
retroactive (damages cannot be claimed for facts that happened before the
entry into force of the law).
11. reasonable length of proceedings: finally, the length of proceedings
should be reasonable for the parties.
In any case, any European initiative should ensure that the companies are not
subjected to further costs and charges that could affect the development of a
firm’s activity due to abuses by a system that does not function properly.
Indeed, in case of class actions translating into truly exponential terms,
companies would be led to compromise the interests at stake to the detriment
of a truly objective evaluation of the situations.
Q 8 As cited above, a number of Member States have adopted initiatives
in the area of collective redress. Could the experience gained so far by
the Member States contribute to formulating a European set of
principles?
We agree with the Commission that a European set of principles has to be
built on the basis of practices of application of collective redress mechanisms
in each Member State. The problem is that initiatives for collective redress
adopted in some Member States have been introduced only recently and, as
pointed out by some studies carried out by the Commission, they have shown
evidence of weakness. Therefore, at the moment, a full assessment of the
effects of these instruments in national experiences is not available.
For example, in Italy, there has been only two class action lawsuits which
were however declared inadmissible by the judge. From this limited
experience, one could draw only a positive assessment of the principles of
opt-in and preventive evaluation by the judge (as described in the reply to
question n. 7).
5
CONFIDENTIAL – NOT FOR PUBLICATION
Q 9 Are there specific features of any possible EU initiative that, in your
opinion, are necessary to ensure effective access to justice while taking
due account of the EU legal tradition and the legal orders of the 27
Member States?
Please refer to answer n. 7
Q 10 Are you aware of specific good practices in the area of collective
redress in one or more Member States that could serve as inspiration
from which the EU/other Member States could learn? Please explain why
you consider these practices as particular valuable. Are there on the
other hand national practices that have posed problems and how
have/could these problems be overcome?
As said above, the initiatives for collective redress adopted in some Member
States have been introduced only recently. In any case, even if a complete
assessment of what these tools have changed in national experiences is still
not possible, the application of collective redress mechanisms in national
Member States is the basis which a European collective redress initiative has
to look at.
For example, the introduction of a class action lawsuit into the Italian legal
system is expected to drastically reduce the number of serial litigations
between firms (especially Banks and Insurances) and consumers. However, at
the moment it’s too early to see the effects of this reform and, consequently, it
is not possible to put in evidence any good practice.
Moreover, UniCredit supports the adoption of well-functioning out-of-court
settlement systems, which could ensure an easy access to justice and a fast
solution to disputes while significantly reducing costs and uncertainties for
operators.
Q 11 In your view, what would be the defining features of an efficient and
effective system of collective redress? Are there specific features that
need to be present if the collective redress mechanism would be open
for SMEs?
As said above, UniCredit firmly asserts that no collective redress mechanisms
should be applicable to SMEs: since they cannot be qualified as a "weaker
party", they should not enjoy the protection granted by these mechanisms.
Q 12 How can effective redress be obtained, while avoiding lengthy and
costly litigation?
In UniCredit’s view the principles which ensure an effective and efficient
system of collective redress 1are:
1. the inapplicability of collective redress mechanisms to SMEs;
2. the exclusion of this remedy in areas - such as banking and finance
sectors- where ADR mechanisms are available;
3. the “opt-in” principle;
1
For a further description of some of these principles please refer to our reply to question n. 7.
6
CONFIDENTIAL – NOT FOR PUBLICATION
4. adequate standards of protection such as the actual representativeness of
the bodies entitled to act in the interests of consumers;
5. the preventive evaluation by the judge of the admissibility of the claim (e.g.
the claim is declared inadmissible when it is evidently unfounded, when
there is a conflict of interests, and when the judge does not recognize a
collective interest);
6. adequate advertising tools of the start of the collective action ;
7. no artificial incentives to litigiousness;
8. the exclusion of the grading of the attorneys’ fees;
9. deadlines for instructing the process and the promulgation of the decision,
10. no retroactivity of the laws introducing collective redress mechanisms;
11. the guarantee of an equal and non punitive compensation.
The publication of the start of a class action should preclude the proposal of
further class actions on the same grounds against the defendant
Each subsequent action proposed by the same individuals for the same
circumstances should be declared inadmissible and suspended until the initial
judgment is passed or, alternatively, that all class actions converge into a
single lawsuit through the mechanism for the grouping of proceedings
according to the object of the claim (“petitum”).
Delicate problems arose concerning the possibility to appeal against a
judgment (both a condemnation or rejection of the action). Taking into
consideration the peculiarity of the class action, only final judgments should be
enforceable. Otherwise the risk might be run of having to pay damages to
individuals as a result of a non-final judgment which recognizes damages (e.g.
at the end of the first degree), which might subsequently be revised or
repealed (at that point, it might not be easy at all for defendants to recover
what has been paid ).
The outcome of the action should thus be published precluding the proposition
of further class actions on the same subject.
Q 13 How, when and by whom should victims of EU law infringements be
informed about the possibilities to bring a collective (injunctive and/or
compensatory) claim or to join an existing lawsuit? What would be the
most efficient means to make sure that a maximum of victims are
informed, in particular when victims are domiciled in several Member
States?
UniCredit is of the opinion that it should be the promoter of the action – which
could likewise be a private organization or a public body depending on the
national law – to identify the class of the injured parties affected by the
infringement (which should subsequently be certified by the judge). It will
equally be the promoter’s task to make the action known to the public and
receive the requests of the consumers to take part in the action (the so-called
opt-in method, through which the consumer should expressly declare his/her
wish to participate in the collective action). The costs for the identification of
the consumers belonging to the class and their involvement should be borne
by who is promoting the action. The advertising of the collective redress action
as well as the possibility to join should in any case be limited in time.
In addition to the above, adequate mechanisms and trans-national advertising
(primarily internet) should be improved, in particular by extending the role of
7
CONFIDENTIAL – NOT FOR PUBLICATION
already existing network of European Consumer Centres (ECC) and FIN-NET
to cover also judicial collective redress mechanisms.
Q 14 How could the efficient representation of victims be best achieved,
in particular in cross-border situations? How could cooperation between
different representative entities be facilitated, in particular in cross-
border cases?
UniCredit regards as important that the national laws ensure the actual
representation and the effective expertise of the consumer associations which
are entitled to bring consumer collective redress, through the setting out of
specific requirements on the basis of EU general principles and subsequent
control of the compliance by them with such requirements. Cooperation at
European level should be facilitated through the networks we have mentioned
in the previous answer (please, read also the following answer).
Q 15 Apart from a judicial mechanism, which other incentives would be
necessary to promote recourse to ADR in situations of multiple claims?
UniCredit fully supports the establishment of ADR mechanisms by all Member
States.
UniCredit considers that consumers and traders should be persuaded to use
ADR for individual or multiple claims and to comply with ADR decisions by
highlighting the high expertise, technical competence, integrity and impartiality
of the deciding body as well as the advantages in terms of cost and time
savings. Another incentive could be the provision of the relevant information
about ADR by companies and industry (via brochures, websites, contractual
general terms, conditions or other documentation which is delivered to or has
to be signed by customers).
In this context, UniCredit regards the use of the network of European
Consumer Centers (ECC), specialized in consumer assistance for cross
border and out-of-court actions, and if the dispute is about financial services,
the use of the network FIN-NET as a very important incentive to promote
recourse to ADR. The cross-border networks of out of court disputes between
States, as FIN-NET, are able to provide an easy and effective interchange of
information between the European systems, and to alternative dispute
resolution systems in the various Member States. For this reason, further
promotion of FIN-NET and an encouragement to the establishment of ADR
systems in those States where they are not present should be pursued.
Q 16 Should an attempt to resolve a dispute via collective consensual
dispute resolution be a mandatory step in connection with a collective
court case for compensation?
As said in UniCredit’s reply to the European Commission’s Consultation on the
use of Alternative Dispute Resolution as a means to resolve disputes related
to commercial transactions and practices in the European Union, if an attempt
to resolve a dispute via individual or collective ADR was a mandatory first step
before going to court, it would surely be a big step in discharging the Courts
from disputes. However, consumers should be allowed to go to Court without
8
CONFIDENTIAL – NOT FOR PUBLICATION
a previous attempt to resolve a dispute via ADR. ADR system should be fully
alternative to the public judicial system and a mandatory first step in ADR
schemes before going to the Court would turn out to be a sort of limitation for
consumers.
The Italian legislation has introduced in March 2011 the obligation to resort to
mediation before bringing legal action regarding certain matters (e.g. disputes
concerning banking, financial and insurance contracts). Since the recent entry
into force, we are not able to assess, in practice, its effects.
Q 17 How can the fairness of the outcome of a collective consensual
dispute resolution best be guaranteed? Should the courts exercise such
fairness control?
In UniCredit’s view, the fairness of the outcome of a collective consensual
dispute resolution should never be questioned, since the fairness is rooted in
the agreement of the parties who have decided to solve their dispute through
an alternative dispute resolution scheme provided it is based on the above
mentioned principles. A consumer can decide to resort before a court when
he/she believes that his/her own rights have been infringed. However, since in
this case the court would initiate a new proceeding, it would not have the right
to examine the fairness of the outcome of the collective consensual dispute
resolution procedure. In conclusion, collective consensual dispute resolution
should remain distinct from and independent of ordinary judicial remedies.
Q 18 Should it be possible to make the outcome of a collective
consensual dispute resolution binding on the participating parties also
in cases which are currently not covered by Directive 2008/52/EC on
certain aspects of mediation in civil and commercial matters?
Unicredit regards as not clear the scope and ratio of this question. If the aim of
the Commission is to extend the scope of Directive 2008/52/EC to consumer
protection, UniCredit does not consider it necessary since consumers are
already protected by this Directive. If this is not the intent of the Commission,
UniCredit regards as necessary to clarify the question.
Q 19 Are there any other issues with regard to collective consensual
dispute resolution that need to be ensured for effective access to
justice?
In order to ensure an effective access to justice, ADR should respect the
following minimum conditions:
1. submission of the case to ordinary Courts shall always be possible;
2. criteria for the appointment and the composition of the mediation/judging
body should be fixed by law (as well as requirements on expertise and
integrity that ensure technical competence and impartiality);
3. access to ADR should be inhibited when disputes have already been
submitted to a Court or to another ADR procedure;
4. confidentiality should be ensured during the ADR procedure (e.g. by
denying the use of information and documentation acquired in the course
9
CONFIDENTIAL – NOT FOR PUBLICATION
of the ADR proceedings in any other judicial proceedings regarding or
connected to the case concerned).
Q 20 How could the legitimate interests of all parties adequately be
safeguarded in (injunctive and/or compensatory) collective redress
actions? Which safeguards existing in Member States or in third
countries do you consider as particularly successful in limiting abusive
litigation?
1. In UniCredit’s view an adequate protection of the legitimate interests of all
parties in class actions would be ensured only by collective redress
mechanisms complying with the principles stated in the answers 7, 11 and
12.
Q 21 Should the "loser pays" principle apply to (injunctive and/or
compensatory) collective actions in the EU? Are there circumstances
which in your view would justify exceptions to this principle? If so,
should those exceptions rigorously be circumscribed by law or should
they be left to case-by-case assessment by the courts, possibly within
the framework of a general legal provision?
UniCredit supports the need to introduce the “loser pays” principle as an
effective safeguard to avoid abusive claims, according to the existing national
judicial redress systems.
Q. 22 Who should be allowed to bring a collective redress action?
Should the right to bring a collective redress action be reserved for
certain entities? If so, what are the criteria to be fulfilled by such
entities? Please mention if your reply varies depending on the kind of
collective redress mechanism and on the kind of victims (e.g.
consumers or SMEs).
UniCredit deems that the collective action should be pursued only when there
are legal and factual issues common to several parties, there exists the
possibility of objectively identifying the group of the consumers concerned and
there are circumstances that render the collective action the most suitable
instrument for ensuring an efficient, fair treatment of the suit, having taken the
number of parties and intricacy of the procedure into account.
Moreover, UniCredit suggests to introduce a mechanism providing for the
possibility of proceeding jointly with a series of claims only upon the granting
of a provision by the judge aimed at verifying the existence of the above
specified given prerequisites.
The right of initiating a class action should be foreseen only for consumers
and not for professionals and/or companies, including SMEs.
UniCredit is of the opinion that the right of action should be granted only to
those consumer associations that can truly be considered representative. The
criteria for the true representativeness of associations legitimized to start the
action shall be set by law. In any case, legal certainty would not be
guaranteed if the associations entitled to initiate a class action were defined
too broadly.
10
CONFIDENTIAL – NOT FOR PUBLICATION
The acceptability of a class action should be extended even against alleged
illegal conduct of a public administration.
Q 23 What role should be given to the judge in collective redress
proceedings? Where representative entities are entitled to bring a claim,
should these entities be recognized as representative entities by a
competent government body or should this issue be left to a case-by-
case assessment by the courts?
UniCredit regards as essential a preliminary examination by the judge of the
admissibility of the collective action, extended to include a first valuation of the
merits of the case (fumus boni juris). With regard to the admissibility, the judge
should verify the existence of legal and factual issues common to several
parties, as well as the possibility of objectively identifying the group of the
consumers concerned, and the existence of circumstances that make the
collective action the most suitable instrument for ensuring an efficient, fair
treatment of the suit, having taken the number of parties and intricacy of the
procedure into account.
The identification of the members of the class by a judge - with the possibility
given to interested individuals to opt in the class action within a certain time
period - would allow companies to be aware of the size and identity of the
claim. As said in answer n. 22 the consumer association entitled to bring a
collective redress action should be recognized as representative by the
competent public body on the basis of criteria set by law.
Q 24 Which other safeguards should be incorporated in any possible
European initiative on collective redress?
According to UniCredit, it would be useful to introduce sanctions to be charged
to the entities promoting unmeritorious class actions or proposing again a
class action already rejected.
Furthermore UniCredit suggests to oblige the claimants to pay a security
deposit for legal costs before the process starts. In addition, systems which
compensate for abusive actions should also be envisaged in order to prevent
that collective actions are used in an irresponsible way.
Q 25 How could funding for collective redress actions (injunctive and/or
compensatory) be arranged in an appropriate manner, in particular in
view of the need to avoid abusive litigation?
According to UniCredit’s point of view, no public funding for collective redress
actions has to be provided in order to avoid abusive litigation.
Q 26 Are non-public solutions of financing (such as third party funding
or legal costs insurance) conceivable which would ensure the right
balance between guaranteeing access to justice and avoiding any abuse
of procedure?
11
CONFIDENTIAL – NOT FOR PUBLICATION
In UniCredit’s opinion there is no need to promote public funding for collective
redress purposes at the European level given that consumer associations are
normally able to get funds for their activities,
Q 27 Should representative entities bringing collective redress actions
be able to recover the costs of proceedings, including their
administrative costs, from the losing party? Alternatively, are there other
means to cover the costs of representative entities?
UniCredit regards as fair and sufficient the application of the “loser pays”
principle.
Q 28 Are there any further issues regarding funding of collective redress
that should be considered to ensure effective access to justice?
No further issues for UniCredit.
Q 29 Are there to your knowledge examples of specific cross-border
problems in the practical application of the jurisdiction, recognition or
enforcement of judgements? What consequences did these problems
have and what counter-strategies were ultimately found?
The existing EU law seems to address sufficiently the problems related to the
practical application of the jurisdiction, recognition or enforcement of foreign
judgments.
Q 30 Are special rules on jurisdiction, recognition, enforcement of
judgments and /or applicable law required with regard to collective
redress to ensure effective enforcement of EU law across the EU?
No.
12
CONFIDENTIAL – NOT FOR PUBLICATION
Contact people
Marco Tagliaferri, Head of Global CIB Legal, UniCredit:
Marco.Tagliaferri@unicredit.eu
Costanza Bufalini, Head of Institutional Relations with the European Union,
UniCredit: Costanza.Bufalini@unicredit.eu
Mario Di Ciommo, Institutional Relations with the European Union, UniCredit:
Mario.DiCiommo@unicredit.eu
Main contributors
Francesco Palazzolo, Head of Italy Litigation, UniCredit
Cinzia Caracciolo, Head of Legal Italy Staff, UniCredit
Stefania Camelo, Legal Italy Staff, UniCredit
Johann Becher, Legal, Corporate Affairs & Documentation, HypoVereinsbank,
UniCredit Bank AG
Matjaž Hafner, Legal & Compliance and Executions, UniCredit Banka
Slovenija
Peter Biesenbender, Rechtsabteilung, Bank Austria
Dora Tajthy, Legal and Compliance Department, UniCredit Bank Hungary Zrt.
Ivana Burešová , Director of the Legal Department, UniCredit Bank Czech
Republic
Roman Melis, Legal and Compliance Division, UniCredit Bank Slovakia
Tomasz Nowacki, Dyrector Zarzadzajacy, Department Prawny, Bank Pekao
SA, acting on behalf of Executive Director Elzbieta Krakowiak
Anousheh Alamir, Institutional Relations with the European Union, UniCredit
13
Nessun commento:
Posta un commento