Conflict of Interest including Anti-Bribery and Anti-Corruption Policy

Conflict of Interest Standards

Employees, officers, and directors are expected to act in accordance with the highest standards of personal and professional integrity, particularly in matters of ethics and governance. That integrity and reputation must never be compromised even for purported benefit of the Bank, and most especially for individual, personal benefit. As a financial services provider, the Bank also has a fiduciary responsibility to its clients. The Bank must not favor one client over another and must protect its clients at all times.

This is comprehensively detailed in the Bank’s standards of Conflict-of-Interest, which mandates that at all times; employees, officers, and directors must elevate the interest of the Bank above that of their personal interests. Employees, officers, and directors are prohibited from using their position of authority or rank in the Bank to directly or indirectly derive personal gain, profit or advantage. Employees, officers, and directors of the Bank should best avoid conflict-of-interest situations, both in appearance and fact and take the necessary measures to prevent conflicts of interest.

Anti-Bribery and Anti-Corruption Policy

The Bank also puts the highest premium on sound, responsible and effective corporate governance and does not tolerate bribery, corruption or improper acts of any kind in all business dealings. Bribery or corruption does not only involve monetary consideration. Bribery or corruption may also involve favors or other material gain such as employment, etc. As such, it has enabled and equipped the Bank’s director’s officers and employees, with the requisite policies, programs and guidance through its Anti-Bribery and Anti-Corruption Policy (ABC Policy), Code of Business Conduct and Ethics for employees and Director’s Code of Conduct to combat risks in corruption and bribery.

Under the ABC Policy, we expect our directors, officers, employees, and business partners to comply with all anti-bribery and anti-corruption laws. All directors, officers, and employees shall not offer, promise, give or authorize others to give anything of value, either directly or indirectly, to any client, person or entity for the purpose of corruptly influencing the recipient, secure an advantage, avoid a disadvantage or obtain or retain business. Offering or paying such remuneration either directly or through any intermediaries such as agents, attorneys or other consultants is also considered corruption and bribery and is also strictly prohibited.

Guidance on the Bank’s anti-corruption and anti-bribery program is supplemented by its Standards on Conflict of Interest under Request or Acceptance of Fees, Commissions, Gifts and Fraudulent Activity.

An abbreviated version of the Bank’s Anti-Bribery and Anti-Corruption Policy may be viewed here.