Ethical standards and human rights
[GRI 102-16] 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 described in the Code, communicating and evaluating the adherence to the principles of ethics;
- By its actions and conduct, the Bank’s Management Board promotes high ethical and professional standards, including in particular an awareness of the importance of risk in the Bank’s business and a risk culture;
- Ethics Officer – the function of the Ethics Officer is exercised by the head of the Compliance Department. The tasks of the Ethics Officer include safeguarding the compliance with the Code of Ethics, promoting and disseminating information about ethical standards, ordering inspections of compliance with ethical principles and verifying cases of their breach;
- system for training in ethics and notifying changes in the rules of ethics;
- procedures, policies and rules containing guidelines on proper conduct;
- system for reporting breaches of ethical standards, also anonymously;
- rules of ethics compliance monitoring system – the Compliance Department at least annually assesses the risks associated with ethics violations. A report from the assessment is drafted, which is presented to the Bank’s Management Board. The Bank’s Management Board periodically verifies and assesses compliance with the rules of ethics in order to adjust them to the changing internal situation in the bank and the bank’s environment, and at least once a year informs the Supervisory Board about the results of the assessment.
The Code of Ethics contains principles and values that should guide employees in the performance of their duties and in their relations with their colleagues and with the Bank as an employer. The Code also sets out guidelines for relations with clients, the market and suppliers, referring to such areas as: respect for human rights, quality of service, ethical sales, fair competition and communication, focus on ensuring long-term continuity and sustainable development, principles for conducting business relations, anti-money laundering, anti-corruption, including rules on accepting and giving benefits, and participation in and organisation of tenders. The Code of Ethics also applies to franchisees and employees at franchise locations.
The Bank also has in place a separate Code of Ethics for the employees providing services to the Prestige and Private Banking segment clients. The Code outlines, in particular, the rules for ethically performing the financial operations, collaboration with third parties, performance of operations on own accounts, and 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 employees responsible for executing client transactions and interbank operations also adhere to their own codes of conduct.
Every employee is obligated to become familiar with the Code by completing a mandatory e-learning course, confirm their knowledge and apply the rules included in the Code in their daily work. [GRI 102-17] Employees have the possibility to report violations of ethical standards via email or postal mail (also anonymously). In 2021 there were no reported violations of the Bank’s rules of ethics.
Notwithstanding the above, employees receive mandatory training in the area of managing conflicts of interest and information considered confidential. These materials are intended to sensitize employees on how to identify and handle situations, which in any way may cause a conflict between the interests of Bank Millennium and the client, as well as how to handle information, which is or may be price-sensitive and its disclosure could affect the price of financial instruments.
As part of such training, employees also learn what responsibilities (including legal orders and prohibitions) are associated with conflict situations and with coming into possession of price-sensitive information. The role of employees as those who must actively identify their own behaviour as well as that of other employees and clients is highlighted in the examples.
All the above-mentioned training makes up a mandatory package of regulatory training that every Bank employee is required to undergo.
|
[GRI 205-2], [GRI 412-2] Trained on the Code of Ethics* |
Bank 2021 | Group 2021 | Bank 2020 | Group 2020 | Bank 2019 | Group 2019 |
|---|---|---|---|---|---|---|
| Managerial staff trained in the year | 22 | 25 | 20 | 25 | 22 | 27 |
| 2.29% | 2.43% | 2.80% | 3.30% | 2% | 3% | |
| Other employees trained in the year | 1,064 | 1,108 | 751 | 781 | 1,217 | 1,265 |
| 18.38% | 18.25% | 10.50% | 10.20% | 24% | 23% | |
| Total percentage of trained managers | 94.09% | 93.99% | 93.49% | 93.46% | 92.59% | 92.17% |
| Total percentage of trained other employees | 93.10% | 92.97% | 92.92% | 92.76% | 91.48% | 91.44% |
In addition, the employees of Millennium Dom Maklerski comply with the “Code of Best Practices of Brokerage Houses” adopted by members of the Brokerage Houses Chamber.
To ensure safety of the funds entrusted by clients, full information on the principles of operation of products and their advertising and sales Millennium Towarzystwo Funduszy Inwestycyjnych, apart from applying the Bank Millennium Group’s Code of Ethics, also complies with the law binding on investment fund companies.
[GRI 103-1], [GRI 103-2], [GRI 103-3] The issues concerning respecting human rights are described in the Bank Millennium Group’s Code of Ethics, the diversity policy as well as in anti-discrimination and anti-mobbing procedures.
In 2021, Bank Millennium conducted a self-assessment process of its human rights policies. The assessment covered, among other things, employment policies and labour and safety standards. Impact on local communities or relationships with suppliers/business partners were also analyzed. The results of the review are subject to detailed internal analysis.
[GRI 103-1], [GRI 103-2], [GRI 103-3] The Bank Millennium Group acts with respect for human dignity, opposes discriminatory practices and observes the right to equal treatment irrespective of gender, age, disability, race and ethnic origin, skin colour, ancestry and territory of origin, religion, nationality, political beliefs, trade union membership, creed, sexual orientation, employment for a definite or indefinite period of time, full-time or part-time employment, and other premises, which expose an employee to discriminatory behaviours. Such information does not constitute a criterion for selecting employees, terminating their employment, setting terms and conditions of employment, promotion, or access to benefits or training to improve professional qualifications.
In the Bank Millennium Group, employees enjoy, among others, the right to information and consultation, collective bargaining agreements and collective action, social and housing assistance as well as good working conditions and access to health care. The Group’s policies and the results of their application are described in the “Employees” section.
Every supplier taking part in a tender procedure must undertake to observe the rules included in the Bank Millennium Group’s Code of Ethics, including the respect of human rights and compliance with anti-corruption policies, by signing a representation to that effect. A clause requiring compliance with the Code of Ethics is also included in contracts with suppliers.
In addition, Bank Millennium has provisions in its lending rules and regulations for Corporate Banking clients on all clients having to meet the requirements of environmental protection and respecting employment rules. In addition, the rules and regulations contain certain restrictions regarding the financing of socially harmful activity featured on the EBRD Environmental and Social Exclusion List. The limitations commit all borrowers, among others, not to use the funding received from a loan for projects associated with forced labour and all forms of discrimination in employment.