In 2018 the Bank implemented a new „Policy for the prevention of conflicts of interest in Bank Millennium S.A.”. According to its wording, the Bank has implemented effective procedures and means to prevent the emergence of conflicts of interests such as principles regulating the execution of transactions for the own account of involved persons who are directly or indirectly affiliated with the Bank through a relationship of control; the flow of confidential information and limitations concerning the execution of personal transactions by Bank employees; compensation policy (ensuring that the compensation of Group employees does not constitute an incentive to place their own interests above the interests of a client).
The Bank’s Management Board is responsible for the proper management of conflicts of interests and supervising them. The Compliance Department conveys a report on managing conflicts of interest in intervals that are at least annual, including information concerning all the identified conflicts of interests.
Some Companies adhere to specific regulations on top of the regulations that span the Bank Group, e.g. Millennium Dom Maklerski has the “Rules and regulations for managing conflicts of interest in Millennium Dom Maklerski S.A.” and the “Policy for countering conflicts of interests in Millennium Dom Maklerski S.A.” [GRI 102-25]