Lawful and Ethical Behaviour

Our Bank's high reputation for legality and ethical values in the conduct of its business is vitally important in commercial and regulatory terms. It is one of the Bank's greatest assets. All employees must:

These principles must spread throughout the Bank at all levels, so that compliance with them is a state of mind and is accepted as part of every day business.

Normally the law and ethical values coincide. Sometimes, however, an activity may be technically lawful but be unethical or contrary to the Bank's standards. If that situation arises, follow the Bank's ethical values and standards. The Bank's reputation is so important that compliance with the letter of the law is not always enough.
Breaches of the law, regulations or the Bank's standards are not justified by the pursuit of profit. Nor are they made acceptable by the practices of competitors or others in the market. 'Market practice' is often euphemism for sharp practice. The bank rightly sets demanding performance targets. They are intended to be met by professional enterprise and skill and not by cutting corners with the law and regulations or by compromising the Bank's reputation and standards.

Responsibility

The Board, the Chairman and the Bank's Chief Executive Officer have ultimate responsibility for the legality and integrity of the Bank's operations. Day to day responsibility lies with line Management. But, whatever one's position in the Bank, he/she is personally responsible for ensuring that his/her act fully in accordance with the Bank's standards. The Golden Rule is never to take a chance with the law or regulations or the Bank's reputation. The Bank's lawyers, inspectors and internal auditors are available to advise anyone who is not sure how to proceed.

Relationships with Regulators and Auditors

All employees must be open and co-operative with our regulators and auditors and keep them fully and promptly informed of every matter which should reasonably be disclosed to them.
The Bank must be able to:

Actions to achieve these aims include:

Service to Customers

The Bank is committed to providing the best possible quality of service to its customers.

The Bank or a business unit should provide a service or product to a customer only if it has acquired any necessary regulatory license or authority to permit it to do so and has the expertise to do so at the highest standards. Before doing so, it should seek from its customers all the information, which might reasonably be expected to be relevant to the matter, and act in the light of the customer's financial circumstances and objectives. If delivering advice, it should ensure that the advice is clearly expressed and that any reservations to or qualifications of the advice are fairly presented.

Confidentiality

This section sets out the Bank's Core Policy. In some instances however, even stricter laws may apply. Always comply fully with these laws.

The Bank owes a strict duty of confidentiality to its customers. It cannot disclose to any third party particulars of the identity or financial, business or personal affairs of a customer, unless:

Every employee must, therefore, take the greatest care to respect the confidentiality of such information and ensure as far as he/she can that others do the same. Never share such information with anyone who does not have a clear right to it. Take care not to give away such information by accident, for example by moving around the office holding documents without concealing their contents.

The duty of confidentiality applies also to communication between Departments / Branches, except that information. may be passed where necessary for the protection of the Bank (for example, in case of fraud) or for the proper management of the Bank (for example, reporting by a Department/Branch to another Department/ Branch in the discharge of Bank's management functions) The duty of confidentiality precludes disclosure for marketing purposes except with the customer's prior written consent.

Conflict of Interest

In the course of business, a conflict of interest may arise between a business unit and its customer, or between customers or prospective customers. Business units must try to identify potential conflicts of interest and to avoid them. If a conflict of interest unavoidably occurs, the paramount consideration is to ensure fair treatment of the customers concerned. This may be done by disclosure of the conflict to the customers, internal rules of confidentiality ("Chinese Walls”) declining to act, or other measures. The Bank must not unfairly place their interest above those of their customers.

Personal Interests

Every employee must ensure that his/her personal interest do not conflict with the duties which he/she owes to the Bank and which the Bank owes to its customers. In particular, no one should become personally involved in any transaction, negotiation or contract on behalf of the Bank with an entity in which he/she or a relative has an interest ,without full written disclosure to and prior written approval from the Managing Director. Nor should one accept any employment, consultancy, directorship or partnership outside the Bank without the prior written approval of the Deputy General Manager (Human Resources Management)
Relatives for the purpose of this code are defined as an employee's spouse, grand child or child (including step and adopted), sibling ,parents ,aunts/ uncles, nieces/nephews, first cousins and same relationship by marriage.

Financial Commitments

No employee should enter into any contracts or transactions, which are in any manner considered as conflicting with the Bank's interests. They should not in any manner and at any time subordinate Bank's interest to theirs.
No employee should borrow or lend should disclose all external liabilities to the Bank. Any commitments in the capacity of a guarantor should be notified to the Bank. Therefore, all employees should confirm in writing to the Bank, in advance their financial dealings and obligations, which would be held in the respective personal files. This is to ensure that these dealings do not conflict with the duties they owe to the Bank or which the Bank owes to their customers.

The Bank also expects all employees to maintain and conduct their accounts properly, drawing of cheques without sufficient funds in the account is a serious act of misconduct, and therefore all employees are advised to operate their personal accounts in an exemplary manner.

Members of the Staff Operating Accounts as Attorneys

Members of staff operating accounts as attorneys are prohibited, except in respect of immediate family members who would be the spouses or their children. The maintenance of joint accounts other than with the spouses and children are not normally permitted, except where expressly authorized by the Management.

Gifts and Inducements

Any employee may not (whether personally or for a relative) solicit or accept from, or offer to, an existing or prospective customer, counter-party, supplier or contractor of the Bank any favour, gift, entertainment or other benefit the size or frequency of which exceeds normal business contact. Nothing may bee given or received which might distort commercial judgment or harm the Bank's reputation.
The above principles must be observed at all times. Provided one complies with them, he/she may accept (but not solicit) and may provide normal business entertainment and, on traditional festive occasions, non-monetary gifts of insignificant value.

Any business related personal benefit which an employee or his/her family give or receive must be reported in writing within three working days to the person to whom he/she normally reports. A person receiving such a report must promptly acknowledge receipt.
He/she may not accept any benefit from the estate of or a trust created by customer, or from an estate or trust of which the Bank is an executor, administrator or trustee without the prior written permission of the Managing Director. Such permission is unlikely to be granted unless the benefit derives from a family relationship or is of no monetary value.

Personal Expense Claim

All employees should always observe the Bank's rules on claiming reimbursement of personal expenses.

Insider Trading

No one should engage in insider trading in Securities.

This means that one may not deal, or advice or arrange for anyone else to deal, in any shares or other securities listed or traded on a recognized Stock Exchange, if an employee has information which he/she know or have .reason to believe is non-public price sensitive information relating to those Securities or the company concerned. This applies whether one has received information through his/her work or from any other source.
This covers:

Information is price sensitive lf, were it to be generally known in the market, it would be likely to affect the price of the securities. It is impossible to give a complete list of topics which are or may be price sensitive.
Examples are:

Executive Officers should only engage in shares transactions pertaining to companies within the group during period stipulated by the Stock Exchange as non - sensitive and a declaration to this effect should be made.

One must also observe any internal rules on personal trading in securities which the Bank and subsidiary/Associate companies put in place and which applies to employees.

Money Laundering

The Bank fully supports the international drive against serious crime, especially drug trafficking and is committed to assisting the authorities to identify money laundering transactions and, where appropriate, to confiscate the proceeds of crime. Every employee must make sure that he/she is familiar with any obligation imposed by the laws of the country. The key principles include the following:

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