[GRI 102-16, GRI 103-1, GRI 103-3] The Bank Millennium Group has a system for managing ethics that consists of the following:
Code of Ethics – lays down our ethical principles. The Compliance Department is responsible for articulating the principles of the Code of Ethics, communicating and promoting ethical values and evaluating the adherence to the principles of ethics;
institution of the Ombudsman on Ethics – the manager of the Compliance Department discharges this function. The tasks of the Ombudsman on Ethics include watching over adherence to the Code of Ethics, promoting and advising on ethical standards, ordering the inspection of compliance with the rules of ethics and looking to cases of their violation;
system for training on ethics and notifying of changes to the rules of ethics;
procedures, policies and rules containing the guidelines on proper conduct;
system for reporting breaches of ethical standards, also anonymously;
system of inspection of compliance with the rules of ethics – encompasses periodical inspections and one-off inspections carried out upon the initiative of the Ombudsman on Ethics. As part of periodic inspections carried out at least once every two years, the compliance unit assesses the risks related to breaching the rules of ethics.
The Bank Millennium Group’s Code of Ethics
The Bank Millennium Group has a Code of Ethics whose policies define the values by which its employees should be guided in the performance of their duties and in their relations with other associates and the Bank as their employer. This Code also outlines guidelines regarding relationships with clients, the market and suppliers, and applies to areas such as service quality, ethical sales, fair competition and communication, rules for conducting trade relations and counteracting money laundering. The Code also contains anti-corruptions policies, including the rules for accepting and giving gifts, and participating in and organizing tenders. The Code of Ethics is also binding on franchisees and managers of franchise outlets.
The Bank also has in place a separate Code of Ethics for the employees providing services to the Prestige and Private Banking segment clients. That Code outlines in particular the rules for ethically performing the financial operations, collaboration with third parties, performance of operations on own accounts, and the transaction authorization rules. It also sets forth the employees’ duties and the rules on how to handle confidential information and professional secrets which may be accessed by them in the course of performance of their professional duties. Treasury Department staff responsible for the execution of transactions with Clients and for interbank operations are also bound by their own codes.
Every employee is obligated, by completing a mandatory e-learning course, to become familiar with the Code, confirm its knowledge and apply the rules included in the Code in their daily work. [GRI 102-17]The employees may report breaches of ethical standards by electronic or traditional mail (also anonymously). No breaches of the provisions of the Codes of Ethics were reported in 2019.
[GRI 205-2, GRI 412-2]Employees undergoing a Code of Ethics training*
*number and % of undergoing a Code of Ethics training. The training is designed for new employees and those who participated in such a training more than 3 years prior. The data does not include the former Euro Bank employees.
In addition, the employees of Millennium Dom Maklerski comply with the Code of Best Practices of Brokerage Houses adopted by the members of the Brokerage Houses Chamber.