Transparency

Dear Customer, as of October 9, 2025, the new provisions of European Regulation (EU) 2024/886 on payments in euros within the SEPA (Single Euro Payments Area) will take effect.

The regulation applies to all Payment Service Providers (PSPs) operating in EU countries where the euro is the national currency.

Instant Transfer

All banks in the SEPA area must offer instant transfers in euros through the same channels available for standard transfers.

Banca Sistema has already activated the instant transfer service:

• for incoming transfers, since October 2024
• for outgoing transfers, starting in August 2025 (for those who have requested it)

Starting October 9, instant transfers will be automatically enabled for all customers.

Beneficiary Verification

Every financial institution processing a payment is required to provide the beneficiary verification service (VOP), which involves verifying that the beneficiary’s account IBAN matches the beneficiary’s details as provided by the customer.

This change applies to both SEPA Instant Transfers and standard SEPA transfers.

Operational Limits

Starting October 9, each customer will be able to set and modify—for each current account of which they are the account holder or joint account holder, and entirely on their own—a maximum amount limit for outgoing instant transfers, either “per transaction” or “daily” (as an alternative).

In order to limit losses in the event of fraud or unauthorized use of a payment instrument, Banca Sistema will maintain the currently set security limits (initial limits), as stipulated in the contract, while allowing them to be adjusted.

Similarly, with regard to standard wire transfers, the Bank will maintain the currently set security limits and allow them to be adjusted.

Fees

No new fees are being introduced. The current fees, where applicable and broken down by transaction type, are also confirmed for instant transfers.

Next

We would like to highlight some important details that we ask you to read carefully.

• The SEPA Instant Transfer
• Payment Security
• VOP (Verification of Payee)
• Operational Limits

If you have any questions or need assistance, please contact our Customer Service at 800 691 629, available Monday through Friday from 8:30 a.m. to 6:00 p.m.

Your financial security is our top priority.

SEPA stands for “Single Euro Payments Area,” which covers payments in euros among European Union countries plus Iceland, Norway, Liechtenstein, Switzerland, the Principality of Monaco, the Republic of San Marino, the United Kingdom, the British Crown Dependencies, the Principality of Andorra, and Vatican City.

What It Is and How It Works

Instant bank transfer is a payment method that allows you to transfer money in real time, 24 hours a day, 7 days a week, with immediate crediting to the recipient’s account.

The requirement to offer instant transfers will take effect upon the entry into force of the Regulation and will apply at different times depending on the country and the type of payment service provider (PSP):

• For payment institutions in the euro area, it will become mandatory as of October 9, 2025
• For institutions in Member States that are not part of the euro area, the requirement will take effect on July 9, 2027

Key Features

• Instant: The transaction is completed in a matter of seconds
• Available 24/7: Instant transfers can be made at any time, including on holidays and weekends, with funds credited within 10 seconds
• Eligible transaction types: Tax refunds, salaries, recurring transfers
• Future Date: You can schedule instant transfers to be executed at a future date
• Supported Channels: Mobile App; Internet Banking (PIB2); Corporate Banking
• Beneficiary verification: Starting October 9, 2025, it is mandatory to verify that the IBAN matches the recipient’s name before the transfer is executed
• IMPORTANT: This transfer is irrevocable and, once initiated, cannot be canceled

Fees and Free Transactions

Free for customers using Internet Banking or the App, in accordance with EU Regulation 2024/886, which requires fees identical to those for standard SEPA transfers.

Types of Transfers Allowed

In addition to regular payments, it is now possible to initiate instant transfers for:

• Tax benefits
• Paychecks

Finally, it is possible to initiate instant transfers:

• “Recurring” (via the online banking feature): processed instantly on the specified recurring date
• “With a future payment date”: processed instantly on the date specified when entering the future “debit value date”

Confirmation of Credit and Possible Duplicate Transactions

Within a few seconds of payment authorization, the bank receives and immediately notifies the Customer that the funds have been credited to the recipient. The application will display a message to the Customer stating “transaction completed successfully.”

However, due to technical issues, the beneficiary’s bank may receive and credit the payment but be unable to provide accurate information. The application will display “transaction unsuccessful” to the customer. In this case, the bank is required to immediately restore the funds to the originating customer’s account.

This does not automatically mean that the transfer has been rejected. The bank will subsequently receive a summary of confirmed transfers and, if necessary, proceed with a new and final debit.

If the transfer is marked as “unsuccessful” because it was not received, we recommend that you DO NOT make a replacement payment before verifying the status of the first one, to avoid duplicate payments.

Additional Information

This service is governed by the General Terms and Conditions and the Information Sheets available at the bank.

Please note: Do not confuse the “instant” transfer with the “urgent” transfer: the latter, which has been available for some time, is a transfer settled on the instruction date in the TARGET (Trans-European Automated Real-Time Gross Settlement Express Transfer) system and is subject to specific terms and operating procedures.

Please always remain vigilant against potential scams or fraud.

In today’s digital world, which leverages technology to make our daily transactions and interactions faster, more convenient, and safer, we must never lose sight of online security risks. Maintaining online security is important for each of us and for Banca Sistema; we therefore provide some guidelines to keep you informed about risks to your digital security and help prevent potential breaches.

To protect your sensitive information, please note that Banca Sistema will never ask for your bank or security codes via email, phone, text message, or social media. If you receive calls or messages that appear to come from the Bank or law enforcement agencies asking you to:

• Providing personal codes, login information, passwords, or security codes
• Make urgent bank transfers to secure your account or cards
• Go to a branch to make such payments

Be especially careful, even if the requests appear to come from trustworthy sources, and carefully check every detail (the sender may sometimes appear legitimate).

If you are unsure of the source of the communication, never provide any details. We urge you to be wary of any requests to provide account holder codes, PINs, security codes, or other personal information, and never share such codes with anyone.

Finally, be careful not to fall for suspicious links received via email, text message, WhatsApp, or social media. Avoid clicking on links in suspicious communications. Phishing often uses the tactic of inviting or enticing you to click a link. Always verify links before clicking them to contact Banca Sistema, and remember that you can always manually enter web addresses instead of clicking on potentially harmful links.

If you have any questions, contact the bank’s call center or law enforcement directly. The mandatory beneficiary verification reduces the risk of errors and fraud, but does not eliminate it.

Be mindful of security when making bank transfers!

• Never provide personal codes, PINs, or passwords to anyone, even if the request appears to come from the bank or law enforcement.
• Always be wary of urgent requests for bank transfers or money transfers, especially if received by phone, email, text message, or social media.
• Do not click on suspicious links received via email, text message, WhatsApp, or social media; always enter the bank’s web address manually.
• Always verify the recipient before confirming a bank transfer, especially if the IBAN was provided over the phone or via email.
• If in doubt, contact Customer Service or law enforcement directly.

Starting October 9, 2025, the Beneficiary Verification (VoP) service will be active.

When a customer initiates a SEPA transfer (standard or instant) via a payment account—either online or in person—they will receive a notification verifying that the beneficiary’s details entered in the order match those on file with the receiving bank before confirming the transfer.

Specifically, before the online transaction is completed, the bank will send a real-time request to the beneficiary’s Payment Service Provider (responding PSP) to verify whether the International Bank Account Number (IBAN) is actually associated with the identifying information provided in the order.

The data compared will be the beneficiary’s name (first and last name—or business name) or other unique identifiers if specified in the payment order (e.g., VAT number, LEI code for a legal entity); with the following possible outcomes:

Match

Perfect match between the beneficiary’s details entered by the payer and the actual account holder listed in the counterparty bank’s records: the transfer can be authorized immediately (without any special notifications).

Close match

Partial match with minor differences (a few characters)—the recipient’s name is displayed, and a button is activated that allows the payer to align the entered beneficiary; the customer can also confirm the payment and proceed with authorization by checking a specific box; another button allows the customer to return to the form to make manual changes or cancel the payment.

No Match

No match—a generic no-match alert is displayed; the customer, at their own risk, may still confirm the payment and proceed with authorization by checking the appropriate box (provided the beneficiary’s bank does not expressly prevent this); a button allows the customer to return to the form to edit or cancel the payment.

Comparison Failed (NOAP)

Due to technical issues with the connection or the beneficiary’s bank, the comparison could not be performed—a specific warning is displayed;

Please note: The customer may still confirm the payment at their own risk (by checking the appropriate box) and proceed with the authorization, or abandon it and try again later if necessary.

Please note that the customer must pay close attention to all cases of mismatch (other than “match”) and especially to cases where the data cannot be verified (NOAP).

This check is also performed for recurring transfers at the time of online entry or modification; it is not performed for all instructions submitted by mail.

The service is free of charge for the Customer.

Banks participating in the VOP

The effective implementation of the payer verification scheme will follow the effective dates set by the Regulation:

• It will be mandatory starting October 9, 2025, for payment institutions in the euro area
• It will take effect on July 9, 2027, for institutions in Member States that are not part of the euro area

Note for businesses (CBI service active)

In the Webcontoc application, the service is implemented for online transfer functions (SEPA transfers, tax-benefit transfers, payroll transfers) and for the CBI functions for entering transfers and payroll entries. In this case, the verification result is displayed on the screen where the customer must sign using Strong Customer Authentication.

Alternatively, when importing a list of transfers, the system automatically verifies each transfer on the list upon completion of the “upload” function.

As required by regulation, in order to speed up transfer operations, the customer has the option to waive the verification by clicking a dedicated button.

If verification is enabled, the imported lists will be placed in the authorization queue only if all transactions contained therein pass the verification check.

The “List of Batch Files to Be Sent” menu will display the verification result for each transaction. For any transaction that fails verification, the Customer may decide to cancel the payment, modify it, or proceed anyway (at their sole discretion).

With the entry into force of the Internet Payment Regulation (IPR), the Customer has the right to freely set and modify operational limits—which define the maximum amounts that can be authorized for payment transactions—based on their own security needs.

What’s Changing (for Bank Transfers)

• You will be able to change these limits independently via Internet Banking, the Mobile App, and Webcontoc (for corporate customers with an active CBI)
• Limits will be introduced on a per-account basis, and channel-specific limits will be discontinued: it will no longer be possible to set separate limits for the app, Internet Banking, or in-branch transactions; limits will be set for each current account and will apply regardless of the method used to initiate the payment
• Two distinct limits will be activated: one for instant transfers and one for standard transfers
• Two types of limits will be implemented: per transaction or daily aggregate. The customer may choose which type to activate

What WILL NOT change

Transaction limits for other transactions (such as cell phone top-ups) will remain adjustable only by the Bank and will follow the traditional logic (by channel rather than by current account).

How to change the limits (via the Mobile App)

You must be the account holder or a joint account holder of the selected account.

Go to the “Transaction Limits” section of the Mobile App, where you’ll find two buttons:

• Standard Transfer
• Instant Transfer

Steps to make changes:

1. Select the current account you want to modify using the “Change Account” button
2. View your current limits by clicking on the rows in the table at the bottom of the screen:
   • Daily Payments
   • Single transaction
3. Tap the “Edit” button to:
   • Set a new maximum amount
   • Choose whether to apply the limit per transaction or per day

The change takes effect immediately.

Change via Internet Banking

You can also access the “Transaction Limits” section via Internet Banking, where you’ll find the following buttons:

• Bank Transfers
• Other transactions

After selecting your account, you can:

• View the active limits for standard and instant transfers
• Change the limits using the “Change Limits” button, choosing between a limit per transaction or a daily limit (alternatives).

Edit via CBI (corporate customers)

For customers with an active CBI, this feature is available only for accounts held with Banca Sistema.

After selecting the account, you can access the limit editing feature by clicking the “Edit Limits” button.

The transaction requires strong customer authentication (SCA) by an authorized user.

Disputing a transaction is a procedure through which the customer may request a refund or correction of a transaction that they believe they never authorized or that was executed incorrectly by the Bank compared to the instructions provided by the customer.

How can the Customer become aware of this

• after receiving a notification on their smartphone via the app
• after checking their account activity via the app or online banking
• via SMS service, if activated by the Customer
• upon receipt of a bank statement

A payment transaction is considered “unauthorized” when it is carried out without the Customer’s consent.

A transaction is considered “non-compliant” when it is executed in a manner that differs from the order or instructions provided by the Customer.

IMPORTANT

When the Customer uses a payment instrument, they are strictly required to:

• use it in accordance with the guidelines set forth in the contract and the information sheet

• notify the Bank as soon as possible of any loss, theft, misappropriation, or unauthorized use of the payment instrument, in accordance with the procedures set forth in the contract

The Customer must safeguard payment cards, identification codes, passwords, PINs, and any access codes for ancillary services with the utmost care.

Under no circumstances should the Customer leave them unattended, disclose them to third parties, write them on the payment cards, or keep them with the cards.

The Bank will never ask the Customer to share codes for authorizing payments.

If the Customer notices that a payment was processed incorrectly or believes they did not authorize one or more payment transactions, they must contact the Bank (or the payment card issuer) promptly and without delay, in accordance with the procedures outlined in the “What to Do” section.

If the Customer contacts the Bank regarding transactions made with cards not issued by the Bank, the representative will provide the necessary instructions for contacting the Issuer.

The Customer must also request that the payment instrument be blocked immediately and initiate the dispute process.

Unauthorized or Non-Compliant Payment Transactions

If the Customer becomes aware of an unauthorized payment transaction (due to a notification in the app, via text message, or by noticing it on the transaction list or account statement) or realizes that a properly authorized transaction was not executed in accordance with the order or instructions given, and wishes to obtain a refund, they must immediately contact the Bank (see the BANK CONTACT INFORMATION section).

To request a refund for disputed transactions, the Customer must send the Bank the “Form for Disputing Unauthorized or Incorrectly Executed Transactions,” fully completed, as soon as possible (see the FILLABLE FORM section).

Subsequently, the Customer must submit to the Bank a police report filed with the Public Safety Authority.

If you are unable to download the form, the Bank will provide it to you or send it via email for you to complete.

Disputed transactions made with a debit card

In addition to the procedure for unauthorized payment transactions:

If a payment card issued by Banca Sistema is involved, the Customer must immediately request that the card be blocked:

• to the Bank (temporary or permanent) (see the BANK CONTACTS section)
• to Bancomat Spa: at the toll-free number 800.822.056 or the number for calls from abroad: +39 02 6084 3768 (permanent block)

Unrecognized Transactions Made with Nexi Cards

If a payment card issued by Nexi Spa is involved, the dispute report and refund request must be directed directly to the issuing company, Nexi, by calling Customer Service or the dedicated card-blocking number (see the NEXI CONTACTS section).

To obtain a refund, the Customer must submit a dispute request. Nexi will review the request and communicate the outcome of the assessment directly to the Customer.

We recommend that you also immediately request that the card be blocked—either temporarily or permanently—through the Personal Area on nexi.it, the Nexi Pay app, or by calling Nexi.

The refund will be issued directly by Nexi (Credit cards) or by the bank upon Nexi’s instruction (debit or prepaid cards).

BANK CONTACT INFORMATION

The Customer may contact the Bank:

• at a branch, during business hours
• by calling the toll-free number 800.691.629 during Customer Service hours
• by sending an email to one of the following addresses:
  • siconto@bancasistema.it
  • info@bancasistema.it
• by sending a message to the certified email address operations.bancasistema@legalmail.it

NEXI CONTACT INFORMATION

For transactions made with credit cards (credit, debit, prepaid), the Customer may contact Nexi Customer Service directly at the following numbers:

• +39 800 151616 from Italy
• +39 02 34980020 from abroad
• +1 800 4736896 from the U.S.

The service is available 24 hours a day, 365 days a year.

Refunds for Unauthorized Transactions

The Bank and/or Nexi are required to refund the transaction amount to the Customer by the end of the business day following the day on which they acknowledge the transaction through written notification from the Customer, which consists of the delivery or submission of the duly completed dispute form.

If the request is received on a non-business day or on a business day after the branch’s closing time, the request is considered to have been received by the Bank on the next business day.

The Bank and/or Nexi may suspend the refund process to the Customer, providing timely notice, if there is reasonable suspicion of fraud on the part of the cardholder/account holder.

If the transaction resulted in a debit to the Customer’s account with the Bank, the Bank will restore the account to the state it would have been in had the transaction not taken place and ensure that the value date of the credit is no later than that of the debit.

It should be noted that the amount is credited within the aforementioned time limit, but subject to “clearance.”

The “subject to collection” condition implies that the availability of the credited funds is not final, as it is contingent upon the successful completion of the investigation, which must be finalized no later than 90 days from receipt of the Customer’s notice of dispute regarding the transaction.

After the amount has been credited “subject to successful clearance,” the Bank may request additional documentation from the Customer to conduct further investigations necessary for the evaluation of the case. In particular, within 7 days of receiving the notification of an unauthorized transaction, the Bank may request from the Customer additional documentation (including, but not limited to, a report filed with law enforcement authorities, fraudulent text messages, or emails) in addition to that already submitted or included in the dispute form, granting the Customer a period of no less than 15 days from the request to provide the additional information. If the Bank does not receive the requested documentation within 15 days, it reserves the right to cancel the request by sending a specific written notice to the Customer.

Following the refund and within 90 days of the submission of the Form, if the Bank or Nexi determines that the transaction was properly authorized by the Customer or properly executed, in accordance with applicable Payment services regulations, they have the right to independently debit the amount of the funds previously credited “subject to clearance” ( ), after first notifying the Customer of the reasons for rejecting the dispute. After this period, the Bank may not charge the amount back, although it retains the right to recover the amount that was not due.

The Bank and/or Nexi will send the Customer notifications at every stage of the request’s Management, from the opening of the dispute file until its closure.

The rejection of a dispute or the failure to respond within 15 business days is sufficient grounds for the Customer to file an appeal with the Banking and Financial Arbitrator (ABF). The Customer may file an appeal with the ABF by completing the appropriate forms available on the ABF website or at the Bank.

ATTENTION

The Customer is responsible for the safekeeping, use, and confidentiality of their personalized electronic credentials and payment cards.

The Customer will not be liable for any losses if:

• the payment transactions were authorized after the Bank was notified of the loss, theft, or misappropriation of the payment instruments, or of their unauthorized use, and a simultaneous request was made to block the Payment services

• the Customer could not have been aware of the loss, theft, or misappropriation of the card prior to a payment transaction

If the Customer has acted fraudulently or has failed to fulfill one or more obligations related to the use of payment instruments and the Management of credentials with intent or gross negligence, the Customer shall bear all losses resulting from unauthorized payment transactions.

The Customer must submit the notification no later than 13 months from the date the transaction was debited or credited, as indicated in the informational documentation provided by the Bank. For Customers who have signed the “Si conto! Corrente” current account agreement reserved for Sole Proprietors, Professionals, Companies, and Entities, and the “Si conto! Corrente Premium Corporate” current account agreement, the deadline for filing a dispute is 60 days from the date the transaction was debited or credited; if the Customer is a Micro-Enterprise, the deadline is extended to 13 months.

Potential Fraud Detected by the Bank

If the Bank detects potential fraud or possible misuse of electronic payment instruments or payment cards (issued by the Bank), it may temporarily block the customer’s account or card in order to limit any potential fraud.

A Bank representative may contact the Customer to confirm whether the transactions are legitimate.

The Customer will never be asked for other information (e.g., card codes or digital service codes), nor will they be asked to take any actions to secure the services themselves.

IMPORTANT

A Bank representative will never ask you for your card number, codes, or login credentials, nor will they ask you to make bank transfers, top up your card, go to an ATM, or authorize payment notifications to secure your payment method.

If you receive such requests, it is a fraud attempt!

Under no circumstances should you comply with unusual requests. If you receive such requests, contact the Bank through the official channels listed on the website to report the incident.