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Anti-Bribery and Anti-Corruption Policy

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This policy outlines Commercial Bank of Ceylon PLC’s stance on bribery and corruption, defines key terms, and sets out responsibilities for various stakeholders.

Key Points

• The bank has a zero-tolerance policy towards bribery and corruption.
• All employees are responsible for preventing, detecting, and reporting bribery and corruption.
• The bank adopts the three Lines of Defense (LOD) approach to manage bribery and corruption risk:
  • Business Units: Primary accountability for identifying, owning, managing, and controlling bribery and corruption related risks
  • Compliance Department: Responsible for ensuring compliance with anti-bribery and corruption legislation and regulatory guidance
  • Management/Audit: Provides independent objective assurance on the effectiveness of internal controls to deal with bribery and corruption risk
• The bank will provide training on bribery and corruption awareness to all employees.
• The policy will be reviewed annually or more frequently if required.

Responsibilities

Business Units

• Identify, own, manage, and control bribery and corruption related risks
• Undertake enhanced due diligence
• Notify the Compliance team of suspected or actual bribery and corruption
• Implement and follow procedures for reporting bribery and corruption

Compliance Department

• Ensure compliance with anti-bribery and corruption legislation and regulatory guidance
• Advise on compliance obligations
• Provide oversight of activities in respect of bribery and corruption risks
• Monitor the effectiveness of controls designed to address bribery and corruption risks

Management/Audit

• Provide independent objective assurance on the overall effectiveness of internal controls to deal with bribery and corruption risk