Compliance and corporate ethics

The main business interests and statutory obligations of BANK INVESTMENTS AND SAVINGS JSC are to ensure that the personal interests of the members of its management bodies, as well as the interests of its employees, do not harm the business interests and obligations of the bank and its clients.

The following principles have been established in the bank to prevent and resolve conflicts of interest:

• Timely identification of existing conflicts of interest.
• Prompt adoption of necessary and comprehensive measures to resolve conflicts of interest.
• Constant monitoring and control of potential/existing conflicts of interest.
• Постійний моніторинг та контроль за потенційними/існуючими конфліктами інтересів.
• Confidentiality of conflict of interest disclosure and resolution process.
• Compliance with the balance of interests of the Bank and the employee in the settlement of the conflict of interests.

Persons who are not employees of the bank have the opportunity to report the facts of conflict of interest by sending a letter to compliance@bisbank.com.ua or in another available way.

A set of rules, standards and procedures for detecting, countering and preventing corruption in the bank’s activities has been established at JSC “BANK INVESTITSIY TA ZAOSCHADJEN”, including:

• The mechanism for monitoring the requirements of the legislation on preventing and combating corruption in the performance of their functional duties among managers and other employees of the bank;
• The mechanism for preventing abuse during interaction with state authorities, supervisory bodies and their officials, officials of clients and counterparties among managers and other employees of the bank;
• Procedures for monitoring the implementation of representative expenses and the giving/receiving of gifts by managers and other employees of the bank during the performance of their official duties.

Anti-corruption clause.

When fulfilling their contractual obligations, the bank, its clients and counterparties (hereinafter collectively referred to as the Parties), their close and affiliated persons, employees or intermediaries accept the following anti-corruption precautions:

• Refusal from any material incentives for employees of the other Party, which puts them in a certain dependence and is directed to the employee making decisions in favor of the other Party or aimed at obtaining undue advantages for one of the Parties;
• Do not carry out actions qualified by the legislation, such as offering, promising or providing an illegal benefit, bribery, provocation of bribery or actions that violate the requirements of the legislation of Ukraine in the field of prevention and countermeasures against legalization (laundering) of proceeds obtained through crime, financing of terrorism and financing proliferation of weapons of mass destruction or anti-corruption legislation;
• Certify and guarantee to the other Party that at the time of signing the agreements by the Parties, they are not subject to international and Ukrainian sanctions or other restrictive measures, as well as that they do not cooperate and do not enter into control relations with persons subject to sanctions or any other restrictive measures;
• Undertake to fulfill contractual obligations and conduct related activities in accordance with business ethics standards, which excludes the possibility of corrupt actions or fraud, as well as legalization (laundering) of proceeds obtained through crime, financing of terrorism and financing of the proliferation of weapons of mass destruction;
• Undertake to ensure the absence of a conflict of interest (real or potential) when concluding and during the validity of contractual obligations, and to notify each other of the presence or potential of a conflict of interest immediately, as soon as the Party becomes aware of them;
• Undertake not to take actions that may lead to the imposition of restrictive measures (sanctions), financial losses, reputational losses, conflict of interest situations on the bank, and also undertake to comply with market standards, including standards of fair competition. If a Party suspects that a violation of anti-corruption provisions has occurred or may occur, the relevant Party undertakes to notify the other Party in writing.

IMPORTANT!

Agreements may be terminated in the case of non-compliance by the Parties with the anti-corruption provisions of the agreements or in the case that restrictive measures (sanctions) are imposed on any of the Parties to the agreement or related individuals by Ukraine, foreign countries and/or international bodies or institutions that recognized by Ukraine.

PAY ATTENTION!

The Parties guarantee complete confidentiality in the implementation of the anti-corruption provisions of the agreements, as well as the absence of negative consequences both for the Party that applied, as a whole, and for the employees of the Party who reported the fact of violations of the anti-corruption provisions of the agreement.

Employees and non-employees of the bank have the opportunity to report violations of anti-corruption requirements by sending a letter to the e-mail address: compliance@bisbank.com.ua or by any other available way.

If you are aware of the facts of improper behavior of our employees, which may harm the interests of the bank and its reputation, you can confidentially inform us about it by sending an appropriate message.

Every message will be verified. Please note that an anonymous message is provided, however, if you leave your contact details, we will notify you of the results of the verification.

With your help, we will be able to improve the quality of services and create conditions under which the separate interests of the Bank’s officials, their business and other connections will not be able to compromise the decision-making procedure and harm the Bank’s reputation.

You can report the facts of unacceptable behavior / violations in the Bank’s activities by sending a letter to compliance@bisbank.com.ua or by any other available method.

PLEASE CONSIDER THE FOLLOWING RECOMMENDATIONS WHEN SUBMITTING MESSAGES

• The message must necessarily contain the name of the branch, department, management or other structural subdivision of the bank, as well as a surname, a name and a patronymic and the position of the person whose actions, in your opinion, are inappropriate; the date of the incident must also be noted.
• It is necessary to indicate the subject of the message and justify the inappropriateness of the bank employee’s performance of his duties, as well as, if possible, provide evidence.
• It should be noted whether you are an employee of the Bank or connected by other business relations (clients, counterparties, partners of the Bank).
• Messages written for the purpose of resolving personal conflicts with Bank employees will not be considered.

To protect the interests of employees, shareholders, customers and other partners, the bank manages compliance risks.

The goal of compliance risk management is to minimize its impact on the financial result, create conditions that prevent the bank from engaging in illegal activities, ensure the inadmissibility of conflicts of interest, and preserve and uphold the bank’s business reputation.

Compliance risk management is an integral part of the bank’s corporate culture, risk management system and internal control system, is carried out on three lines of protection and ensures the minimization of the probability of events that may negatively affect the bank’s results and is aimed at preventing the involvement of bank employees in illegal activities .

Compliance risk management in the bank complies with the following principles:

• Completeness of compliance risk management measures.
• Ensuring timely (at an early stage) detection, measurement, monitoring, control, reporting and mitigation of compliance – risk at all organizational levels.
• Structuredness is a clear division of functions, duties and powers of compliance-risk management between all structural divisions and employees of the bank, and their responsibilities according to such division.
• Segregation of duties (separation of the control function from the implementation of bank operations) is an avoidance of a situation in which the same person performs bank operations and performs control functions.
• Comprehensiveness and comprehensiveness is a  coverage of all types of bank activity at all organizational levels and in all its structural subdivisions, assessment of the mutual impact of risks.
• Independence is a freedom from circumstances that pose a threat to the unbiased performance of the chief compliance manager and the Compliance Office – control of their functions.

Proper management of compliance risks allows the bank to achieve its goals, to ensure compliance of the bank’s activities with established requirements, to minimize the likelihood of applying legal sanctions, financial losses or loss of reputation due to non-compliance with the requirements of current legislation, as well as standards and internal documents.