UniCredit – Alignment with IOSCO Principles for Financial Benchmarks

UniCredit Bank GmbH (“UniCredit”) is committed to maintaining the highest standards of integrity, transparency and governance in the administration and use of financial benchmarks. In this context, UniCredit aligns its practices, policies and control framework with the IOSCO (meaning “International Organization of Securities Commission”) Principles for Financial Benchmarks (the “IOSCO Principles”), ensuring consistency with applicable regulatory requirements and industry best practices; the aim of this alignment is to promote the reliability of Benchmark determinations, and address Benchmark governance, quality and accountability mechanisms.

UniCredit maintains a comprehensive governance framework covering all aspects of benchmark determination, including development, calculation, oversight and dissemination. This framework is designed to ensure that benchmark methodologies are robust, transparent and reflective of the underlying economic reality they are intended to measure. Benchmark methodologies, as well as relevant governance and procedural documentation, are made available where appropriate to ensure transparency to stakeholders.

Benchmark determinations are subject to clearly defined controls and are performed by suitably qualified personnel with the requisite expertise. UniCredit operates segregation of duties and implements effective arrangements to identify, manage and mitigate actual or potential conflicts of interest. Independent oversight is exercised through designated governance bodies responsible for reviewing benchmark methodologies, approving material changes and ensuring ongoing compliance with internal policies and applicable regulatory standards.

UniCredit applies a risk-based control framework to the input data used in benchmark calculations. This includes procedures to detect anomalies, validate data integrity and ensure that inputs are representative, reliable, and derived from appropriate sources, such as observable market data where available. Where models or expert judgement are applied, these are subject to appropriate validation and oversight.

To support accountability, responsibility, and transparency, UniCredit maintains clear audit trails and retains records of benchmark determinations in accordance with applicable regulatory requirements. In addition, UniCredit has established mechanisms for internal escalation and whistleblowing, enabling concerns regarding benchmark integrity or potential misconduct to be raised and addressed appropriately.

UniCredit conducts periodic reviews of its benchmark methodologies and governance arrangements to ensure continued alignment with market developments, regulatory expectations, and the IOSCO Principles. Where necessary, changes are implemented in a controlled and transparent manner, with appropriate governance approval.

While UniCredit seeks to ensure full alignment with the IOSCO Principles, the application of such principles is undertaken in a manner proportionate to the nature, scale and complexity of the relevant benchmarks and associated activities.