2019 Financial
and Social Report

Preventing conflicts of interests

[GRI 102-25] The Bank implemented a „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 governing the execution of personal transactions, protection of the flow of confidential information and limitations concerning the execution of personal transactions during closed periods, 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), transactions with members of the Bank’s Group as well as additional and competitive business undertaken by employees.

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’s Group, e.g. Millennium Dom Maklerski has in place the “Policy for the prevention of conflicts of interest at Millennium Dom Maklerski S.A.” and Millennium Towarzystwo Funduszy Inwestycyjnych adheres to the “Regulations for managing conflicts of interest at Millennium TFI S.A.”.

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