MESSAGE FROM THE PRESIDENT OF THE MANAGEMENT BOARD OF Naša Banka AD BANJA LUKA
Dear Sir/Madam,
We know that our business success depends on our commitment, ethics and personal responsibility in everything we do. The way we do our job is as important as what we do. Our Bank's Code of Business Ethics is an ethical compass for making business decisions in line with our vision and our values. The Code provides guidelines for everyday operations and helps us understand what is expected of each employee of the Bank.
Although there is no code that covers all situations you may encounter in the course of your work, you should use this Code as a guide to help you make the right ethical decisions on behalf of Our Bank.
We are all responsible for respecting the Code, and you are expected to ask questions, seek advice and point out phenomena that could constitute a violation of its provisions. Each of us is committed to respecting the basic rules of conduct in our daily activities, which contributes not only to the success of Our Bank and good mutual relations, but at the same time, respecting the Code has a positive impact on the Bank's reputation and the trust of our clients, shareholders and society as a whole.
As employees of the Bank, we are all obliged to familiarize ourselves with and fully comply with the rules of this Code.
President of the Board
Dejan Vuklišević
GENERAL PART
Our bank ad Banja Luka (hereinafter referred to as: the Bank) is committed to a culture of responsibility, business operations in accordance with legal regulations and professional rules, and to carrying out business activities according to the principles of integrity, in an honest and ethical manner. Members of the Supervisory Board, members of the Management Board, managers of organizational units and all employees should be committed to high ethical standards of desirable behavior, which is reflected in a professional attitude towards work and associates, responsibility, integrity, impartiality, a spirit of community and respect for each individual. In this sense, the term employee used in the Code of Business Ethics (hereinafter referred to as: the Code) also refers to all managers in the Bank. Business operations, which are in line with this Code, are a guarantee for strengthening trust in the Bank and are the key to its reputation and long-term successful business operations.
The Code regulates the rules of conduct of employees in both internal and external relations, based on the core values and principles of the Bank.
The Code cannot provide answers to all dilemmas that may arise in the workplace. Therefore, one of the key requirements of this Code is due diligence, good judgment and correct action in all business activities. Each of us should adhere to this Code and should encourage other employees and business partners to do the same. In case of any doubts regarding the application of the Code, please contact your immediate manager or the Independent Compliance Department. We support open discussion on all issues.
1. Basic corporate values
The core corporate values that serve as our guide when making business decisions on behalf of the Bank are:
1. Leadership, which is reflected in:
- taking responsibility for our actions,
- taking responsibility towards clients, employees, shareholders, business partners, social and natural environment
- work in accordance with legal regulations and rules of the profession
- continuous progress and improvement
2. Team spirit:
- we help each other, because we are on the same task and want to achieve the same goals
- Open communication and cooperation are the basis of our work.
- we respect each other
- we share knowledge and learn from each other
- we act honestly and respect ethical standards
3. Client focus:
- our activities are directed towards clients and their needs
- we follow modern trends
- we are looking for new and better methods and approaches in providing services
- we optimize our processes
- We examine our clients' needs and strive to exceed their expectations.
2. Basic principles of ethical behavior
In order to maintain and continuously improve the Bank's reputation, the conduct of all employees in terms of business and ethical issues should be in accordance with the highest standards of ethics based on the following values and principles:
- compliance with the provisions of the Code in daily work,
- compliance with relevant legal regulations, internal policies and procedures of the Bank;
- we protect confidential information and data
- we do not abuse inside information
- impartiality, professionalism and client focus,
- innovation;
- high-quality, responsible and efficient performance of work tasks,
- dedication to the interests of the Bank,
- honesty and respect among colleagues
- respect for human rights
- protection and rational use of the Bank's assets, property and resources;
- care for the social environment,
- teamwork, cooperation, helping each other,
- reporting observed irregularities to the immediate manager or the Independent Compliance Department.
3. Scope of application
The provisions of the Code apply to all business activities and to employees, as well as to all third parties representing the Bank or performing certain activities on its behalf. All employees are required to familiarize themselves with and fully comply with the rules of this Code. Each manager is expected to take the necessary measures to implement and comply with the provisions of this Code, to provide instructions and assistance to employees in case of ambiguities, and to serve as an example to others through their behavior.
4. Obligation to comply with the law and the Code
All employees are obliged to:
- to respect applicable laws and other regulations, and to understand how they relate to the segment of work for which they are responsible,
- to understand and apply the rules of this Code, which should serve as a guide through their daily work,
- to confirm (in writing or electronically) that they have read and fully understood the Code, and to commit to its compliance.
- An independent compliance department is responsible for collecting signed statements.
Members of the Bank's Management Board and all managers have an additional responsibility for creating and maintaining a corporate culture and environment in which employees know and understand their duties ("tone from the top"), and encourage employees to report observed irregularities and any other problems they encounter to their immediate manager or the Independent Compliance Department.
Managers are required to:
- They promote ethical principles through their example,
- Explain the provisions of the Code to other employees,
- They encourage open cooperation and communication in which every employee will feel free to present their opinion or idea for consideration,
- They take corrective measures in case of violations of ethical principles.
- The pursuit of profit does not justify breaking the law or the Code.
- New employees are required to familiarize themselves with this Code and to sign the above-mentioned statement immediately after signing the employment contract.
5. Competences
The Bank's Management Board is responsible for ensuring the conditions for the uniform application of the Code throughout the Bank. An independent compliance department has operational responsibility for the introduction and control of the application of the Code in all organizational units, and for providing assistance and necessary training to employees in this area. Managers of organizational units are responsible for compliance with the Code in their areas of responsibility.
6. Obligation to report violations of the Code
If employees become aware of a violation of the Code, they are required to take appropriate corrective action, or report such conduct to their immediate manager or the Independent Compliance Department. The report may be submitted in person or by email to the Independent Compliance Department, or anonymously in writing.
INTERNAL RELATIONS
1. Honesty and respect among employees
At the Bank, we strive for relationships based on cooperation, mutual respect, kindness and assistance. Each employee is obliged to respect the dignity and personal integrity of employees, help them acquire new skills and knowledge, and support them in their personal development and advancement.
We do not tolerate any kind of discrimination, unequal and unfair treatment of employees, as well as any kind of violence, harassment or bullying/harassment on any grounds. Every employee can do their job without fear of such practices. We respect the human rights of every individual and promote a positive work environment that contributes to our success.
Ethical business practices contribute to the Bank's reputation, support corporate culture and contribute to the establishment of a safe, stimulating and healthy working environment. When performing their duties, Bank employees must be aware of their authority, jurisdiction and responsibilities, and not take any action that would exceed them.
Employees may not under any circumstances exert undue pressure on others, make harmful remarks, spread inaccurate or biased information, or in any way undermine the integrity of other employees.
2. Education and professional development
Employee motivation is largely defined by the degree to which their needs and demands are met. Taking these needs and demands into account, the Bank offers employees the opportunity for professional development, so that they can achieve their desires to a reasonable extent and perform their work tasks more efficiently.
Concern for personnel development leads to proper and successful operation and development of the Bank.
3. Team spirit
Our goal is to create and maintain a work environment that allows each employee to reach their full potential. Each employee is allowed to express their opinions without being afraid to openly discuss any dilemmas.
The quality and level of communication and mutual cooperation among employees is of key importance for achieving the Bank's goals. All employees are expected to adopt a friendly and open attitude towards each other, to promote team spirit. By conscientiously and professionally performing our work, we contribute to the efficient performance of our employees' work obligations and thus the efficiency of the Bank as a whole.
4. Professionalism
We have a professional relationship with our clients, which we demonstrate through personal tidiness, tidiness of the work space and presentation of the highest ethical and professional standards in everyday business and communication with clients in the sale and offering of our products and services. Employees are expected to demonstrate creativity and individual initiative, and to take responsibility for the results of their work. We acknowledge our mistakes, learn from them and take all necessary measures to perform our duties and tasks in a quality manner, i.e. so that our mistakes are not repeated.
We treat our clients fairly. Employees immediately report all client complaints to the authorities, resolving them quickly, efficiently, to the benefit of all parties involved. By acting professionally at all times, we contribute to the good reputation of the Bank as a financial institution.
5. Protection of Bank assets
Employees are required to use property, information and intellectual property that legally belongs to the Bank with special care, and to safeguard the property they use and for which they are responsible.
6. Avoiding conflicts of interest
All employees of the Bank must adhere to the highest standards of ethical conduct in order to avoid even the appearance of a conflict of interest or a situation that could cause harm to themselves, their associates, the Bank or its shareholders. The personal or private interests of employees must not conflict with the interests of the Bank or the interests of the users of the Bank's services. Employees are obliged to identify, monitor and eliminate potential conflicts of interest.
A conflict of interest arises when an employee's personal activities or relationships in their private lives interfere with the Bank's business interests and therefore affect the employee's objectivity in making business decisions. A conflict of interest may expose the Bank to legal and/or reputational risks.
Within the scope of his duty and decision-making, the employee must always follow the interests of the Bank, and not his private interests.
Employees may not misuse the name of the Bank or shareholders, or their position within the Bank, for their personal interests or the interests of third parties.
It is impossible to describe all potential conflicts of interest. If you are aware of a conflict of interest, or if you are unsure, seek advice from your supervisor or consult with the Independent Compliance Department, which will, after careful analysis, decide whether a conflict of interest exists and what steps should be taken.
7. Use of the services of the Bank and its business partners by Bank employees
Employees and their family members are encouraged to use all financial services within the Bank's scope of activities. Services will be granted under the same conditions as those granted to other Bank clients, in order to protect the Bank's interests and to ensure that no one is placed in a discriminatory position.
8. Engagement in activities outside the Bank
The Bank supports all employees to engage in sports and cultural activities, scientific research, special interest organizations, etc. in their free time, taking into account that performing such activities does not reduce their capacity to perform work tasks at the Bank, that performing such activities does not represent a conflict of interest, and that it does not in any other way harm the interests or reputation of the Bank. When performing free time activities outside the Bank, special attention should be paid to the protection of confidential information.
BRIBERY AND CORRUPTION
No form of bribery and corruption is permitted. Bribery and corruption are harmful social phenomena and should be suppressed, exposed and sanctioned, affirming the principle of “zero tolerance” towards them. Employees may not under any circumstances, directly or indirectly, promise, request or accept bribes, or pay to expedite administrative, administrative or other procedures. The Bank also expects such business conduct from its business partners. All employees should make reasonable efforts to reduce and/or avoid the risk of entering into business relationships with contracting parties involved in corrupt activities.
Gifts, for which there is an absolute prohibition on accepting or giving, are unconditionally rejected. Any other acceptance or giving of money, inappropriate gifts or services is not in accordance with the Bank's bylaws and is strictly prohibited.
RELATIONS WITH CLIENTS AND BUSINESS PARTNERS
Our clients, business partners are always in the center of our attention. In order to preserve their trust, employees are obliged to protect their interests, respecting all relevant regulations. In order to build long-term relationships with clients, our approach is professional, with openness and respect.
We develop an individual approach to each client, fulfilling our promises and responding to their requests without delay. This is how we earn their long-term trust.
We have a responsibility to understand the needs of our clients and take their interests into account. Based on our experience and expertise, we are committed to providing innovative and modern products and services that meet the needs and requirements of our clients. Our desire is to contribute to the fulfillment of their plans, and our task is to advise and inform them and raise their awareness of the nature and level of risks associated with their wishes and requirements.
Under no circumstances will services, advice or cooperation be offered that may lead to a violation of any regulations.
Our goal is to ensure that clients benefit from the products and services we offer, taking into account their interests, carefully building partnerships and maintaining trust in the Bank.
PROTECTION OF CONFIDENTIAL DATA AND BANKING SECRECY
All employees, shareholders, and members of the Bank's bodies are obliged to keep confidential any confidential data and information they obtain in the course of their daily activities, both while at the Bank and outside the Bank. There is zero tolerance for any events that may result in the disclosure or disclosure of such information to unauthorized persons. All data and information about users is also treated confidentially. Disclosure of such information is permitted only with the prior written consent of the user, or at the request of authorized supervisory and investigative bodies and in accordance with the provisions of the RS Banking Law.
The Bank takes special care to protect personal data in accordance with regulations. The protection of personal, or confidential, data is regulated by the Law on the Protection of Personal Data of BiH.
MARKET COMPETITION
In its business relations with its competitors and business partners, the Bank behaves in accordance with the standards of fair competition and best market practices, while adhering to all applicable regulations governing market competition. The Bank collects information from the market in a legal and ethical manner, respecting the principles of fairness, equality and non-discrimination.
Abuse of the position of a professional market participant undermines confidence in the capital market and has serious consequences for the Bank and every individual who participates in such activities. We do not enter into any oral agreements and act in accordance with the rules of fair competition, local and international rules governing market conduct.
SOCIAL RESPONSIBILITY
The Bank's activities may to some extent affect the economic, social and ecological development of the environment in which it operates. We strive for long-term sustainable and stable business operations, refraining from any activities that may have harmful consequences for society. We want to contribute to the improvement of environmental protection and social standards through our activities. We are committed to respecting human rights and fundamental freedoms in relations with our employees, suppliers and clients.
The Bank actively contributes to the implementation of socially important projects, cultural and sporting events, as good deeds are an integral part of our corporate culture. The Bank remains politically neutral and does not support any political organizations or activities through donations or subsidies, even if local legislation allows it. The Bank respects the obligations of employees who, as citizens, wish to participate privately in public life, while being obliged to carefully protect the reputation and credibility of the Bank.
The Bank's relations with government and regulatory authorities are based on the principles of transparency, cooperation and compliance with the law. In these relations, employees are required to act courteously and professionally, expressing the official position of the Bank, enabling the competent authorities to carry out their official duties without hindrance.
The Code of Business Ethics was adopted by the Supervisory Board of the Bank.
Version 6, December 2022.