Financial Crime World

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Bank’s Anti-Bribery and Corruption Policy

The [Bank] is committed to upholding the highest standards of integrity and ethics in all its business dealings. As part of this commitment, we have established an anti-bribery and corruption policy that outlines our stance on bribery and corruption, as well as procedures for reporting suspected incidents.

Reporting Suspicions

If you suspect fraud or bribery, please report it to your manager or directly to Internal Audit or Compliance. Alternatively, if you wish to remain anonymous, you can report through the Whistleblowing Line available to all staff members.

Immediate Reporting of Bribery Incidents

If anyone is aware that a colleague, customer, or supplier is involved in bribery, this must be reported immediately. It does not matter whether the person involved is an internal employee or external party.

Non-Compliance Issues

Any non-compliance issues will be assessed accordingly and relevant measures put in place to consider regulatory and reputational impact, as well as impact on capital adequacy and liquidity of the Group.

Monitoring and Review

The Bank monitors and reviews procedures designed to prevent bribery and corruption, making improvements where necessary.

Governance

The following roles have been identified with major responsibilities for implementing this policy:

  • Board of Directors: Bears ultimate responsibility for effective implementation and setting the right tone from the top.
  • Audit Committee: Approves policy, ensures sufficient internal procedures are in place, and monitors implementation via Control Functions.
  • ExCo: Reviews policy prior to submission to AC and ensures effective embedding throughout Group operations.
  • Compliance Division: Drafts, enforces, and updates relevant procedures/ circulars as required.
  • Risk Management Division: Reviews compliance risks addressed in the policy.
  • Internal Audit Division: Independently assesses and evaluates internal controls, policies, and procedures.

Line Directors and Local Managers

Line Directors have responsibility and accountability for adherence to this policy within their divisions (as first line of defence). Local Managers or Regional Managers are responsible for informing LCOs about gifts relating to their area.

Legal provides general advice on relevant legislation and support, guidance, and advice in relation to legal issues.

Organization Department

Communicates policy to all employees and ensures key principles are fully incorporated in relevant procedures.

Procurement Department

Develops and maintains sourcing, procurement, and vendor management policies and procedures ensuring proper management of anti-bribery and corruption risks.

Human Resources

Incorporates anti-bribery and corruption provisions into Code of Conduct and Code of Ethics. Performs due diligence checks before appointing new employees and designs disciplinary procedures.

Personnel Responsibilities

All personnel are responsible for complying with this policy and its related procedures. If an employee becomes aware or suspects bribery or corrupt activity, they must report it immediately to their direct supervisor/line manager or via the Whistleblowing Line.

Supporting Documentation

Relevant written communication, acknowledgements, declarations, and other material confirming compliance are properly maintained and archived.

Exception Approval Process

Exceptions to this policy can be allowed with approval of Chief Compliance Officer and CEO or Deputy CEO. Audit Committee must be notified accordingly.

Implementation Procedures (Key Processes)

  • Gifts over €50 are approved by higher authority.
  • Gifts over €100 are approved by two-level higher authorities.
  • All gifts, whether approved or rejected, are recorded in the gift registry.
  • Gifts to Directors (N-1) level are approved only by CEO.