Financial and
ESG report 2020

Preventing conflicts of interests

[GRI 102-25]
The Bank has implemented the “Policy for the prevention of conflicts of interest in Bank Millennium S.A.”.

In line with the Policy, the Bank has established the following principles governing this area:  

acceptance and provision of financial and non-financial benefits (the so-called “performance incentives”)

product review and approval

appropriate organizational structure (including clear reporting lines) and information barriers

compensation policy

personal transactions

additional or competing activities

transactions with entities of the Bank Millennium Group

The Bank’s Management Board is responsible for the proper management of conflicts of interests and supervising them. On the basis of recorded cases of actual conflicts of interests, the Compliance Department carries out analyses of occurrence of conflicts of interest and provides the Bank’s Management Board with the conclusions with a view to eliminating them in the future. These analyses are prepared periodically, at least on an annual basis.  

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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