The Company places considerable emphasis on anti-corruption as follows:

1) Bribes and Inducements
It is prohibited to offer or receive any form of bribe or inducement, or to direct anyone else to conduct such an act on one’s behalf.

2) Gifts and Benefits
It is prohibited to offer or receive any gift or other benefit in exchange for doing or refraining from doing one’s duties or doing unethical conduct aimed at gaining personal benefit, or for entering into inappropriate business settlements. Strict compliance with the Code of Conduct is required.

3) Charitable Contributions and Financial Sponsorships
Charitable contributions and financial sponsorships must be transparent and conform to laws and moral principles.

4) Political Contributions and Activities
The Company’s funds or resources shall not be used to make contributions to any political campaign or activity of any politician or political party, except for contributions that are permitted by laws and in support of democracy overall. The Company’s specific permission is required for such contributions.

The Company has put in place risk management systems to avoid unethical conduct aimed at gaining personal benefit to ensure that this risk can be prevented or controlled. Unethical conduct shall be identified, assessed, controlled and monitored, and reported per the Company’s risk management policies and practices.

The Bank has put in place good corporate governance principles and an internal control culture where there are assessments of significant risks, effective control activities and appropriate segregation of duties. An adequate and reliable information system has been put in place as well as regular monitoring or internal control.

The Company has focused on efffective human resource management, knowledge-based communications for staff and regular training on our Anti-Corruption Policy and related operational guidelines in order to promote genuine understanding toward this Policy and compliance with it.​