UBI Banca Group

Policy for the distribution of mortgages through brokers
This policy regulates the procedures for the use of external distribution networks for granting
mortgages to non captive customers in order to mitigate potential credit, operational and reputational
risks.
The policy defines the following:
minimum capitalisation limits for the brokerage companies and a prohibition on direct
agreements with mortgage brokers and real estate agents;
minimum contents for agreements between distribution networks and banks or companies in the
UBI Group including, for example, the specification of a minimum list of risk indicators to be
monitored for which there must be a provision in the agreement that requires the network to
remain within certain limits. Once those limits are exceeded penalties are applied (if maximum
risk limits are exceeded) or bonuses are paid (if particularly low levels of risk are achieved) to the
distribution network;
an obligation by banks entering into agreements to put a process in place to monitor changes in
the risk indicators just mentioned, with support from the Parent.
Policy on the portability, renegotiation, substitution and early repayment of the mortgages of
direct customers of the network banks
The policy on the portability, renegotiation, substitution and early repayment of mortgages of the UBI
Group furnishes guidelines for portability (in both directions), the renegotiation (including the
rescheduling of instalments as regulated by the agreement between the Ministry of the Economy and
Finance and the Italian Banking Association), the substitution and early repayment (partial or total)
of mortgages. It is designed (by setting minimum standards of service amongst other things) to
minimise processing times, conditions and related costs and also to equip the Group with appropriate
processes and instruments to manage the relative risks (credit, operational and reputation).
The policy also defines objectives for the maximum time limits for responding to customers for which
a specific monitoring process has been launched.
Policy on the portability, renegotiation, substitution and early repayment of mortgages granted
through brokers
As was defined for the mortgages of direct customers of the network banks, the policy on the
portability, renegotiation, substitution and early repayment of brokered mortgages sets, for this
specific type of business, maximum time limits for responding to customers for which the necessary
monitoring process must be put in place.
Risk-adjusted pricing policy
The risk-adjusted pricing policy defines a process to formulate and implement risk-adjusted pricing
approaches for various products which involve the assumption of credit risk.
The price setting process involves a detailed process of defining and using prices to ensure that:
380