2013 Annual Report
146 2013 Annual Report Attachment
MARKETING
COMMUNICATIONS
Materiality
The sale of prohibited or challenged products is important for the Bank because
this is a reputation issue, including legal risk and the degree of influence the Bank
holds with our stakeholders.
In order to ensure that prohibited products and services are not offered to
stakeholders, the Bank has in place a governance level in charge of the approval,
marketing and monitoring of products and services.
The goal is to avoid that any products are marketed before their general
characteristics, risks, controls, legal feasibility and operating, accounting,
and technological procedures, to name a few, are both identified and
assessed by all relevant technical areas. This assessment has two issues
in view: impacts for the bank and impacts for the clients.
As applicable, the Corporate Marketing Committee (based in Spain) is involved
in the assessment and approval process for products. According to the corporate
policy, upon approval, the marketing of products remains under surveillance.
Our advertising communication is based on transparency,
simplicity and clarity. When developing campaigns that
involve the launch of products or depict a product category,
the Bank strives to present product characteristics in a clear
manner thereby avoiding ad jargons or productions that
confuse the audiences; in addition to guiding consumers as
to the best use of products and their adequateness; clearly
state the product or service's purpose; and state the channels
available to the consumer for additional information.
The Bank's philosophy is that adequate, clear information
about products and services is integral part of both product
communications and design. Thus, when designing a product
or service, the Bank conducts a pre-test of its characteristics
and how it should be presented to consumers. This practice
provides a true perception of how consumers will understand
the ad while allowing for any corrections both in the product
and in communications.
Indicators Consolidation
The sale of banned or disputed products G4-PR6
The Bank uses Article 31 of the Consumer Defense Code
as a benchmark in this area. Prior to being made available
for sale, the Bank's products and services are subjected to
the approval process according to internal policies in force.
In 2013, the product with the highest number of complaints
was credit cards. The non-delivery of the card or its invoice;
charging annual fees; non-acknowledged payments; and
non-recognized charges are the main reasons for complaints.
Most complaints are placed via Customer Service, with
authority to solve problems such as reversals and canceling.
In cases that are beyond this authority level, the complaint is
routed to a supporting group in charge of resolving the issue.
Compliance with regulations in connection with
marketing communications G4-PR7
Policies and Commitments
The Bank also follows internal and external guidelines to ensure that prohibited
products and services are not marketed. Internally, the drivers are our Code of
Ethics, the Product and Service Marketing Policy and the monitoring of product
sale, under the approved business standards. Externally, the Banking Sector
Self-Regulating Code (issued by FEBRABAN), the codes issued by the Associação
Brasileira das Entidades dos Mercados Financeiro e de Capitais (Anbima) and the
standards in place by regulatory bodies: the Central Bank, the Brazilian SEC
(the "CVM"), and the Private Insurance Agency (the SUSEP).
In connection with the number of incidents and sanctions
for noncompliance with voluntary regulations and codes in
communications and marketing, the Bank did not record
any complaints in 2013 involving the Brazilian Council for
Self-Regulation in Advertising (the Conar).
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