Corporate culture and Code of Corporate Ethics Sberbank. Code of Corporate Ethics PJSC "Baltic Bank. Internal control in the bank is carried out
To maintain higher standards of professional ethics, corporate ethics codes are created in Sberbank. The Codex Corporate Ethics formulates the basic principles and rules of the behavior that we are guided in our work, as well as in communication with customers, suppliers, shareholders and employees. Code of Corporate Ethics applies to all managers and employees of Sberbank. Code of corporate ethics should be guided by employees and heads of Sberbank in all their actions on behalf of the Bank and ensure that it is compliance in order to fully follow the interests of banks. In all decisions that we accept, and in all actions that we carry out on behalf of the Bank, we strive to meet the highest principles of professional ethics, comply with existing laws, as well as norms and rules established in the bank.
The bank appreciates and respects its employees. Employees are the main domain of the bank. He builds his relations with employees on the principles of long-term cooperation, mutual respect and unconditional fulfillment of mutual commitments.
Sberbank employees must comply with the ethics of business relations:
Keep a commercial secrecy of the bank;
Compliance with current regulatory documents of the CBD and regulatory documents of Sberbank of Russia;
Improve the quality of work, improve your business qualifications and professional level;
Behave politely and correctly, carefully refers to colleagues and bank customers;
Remember the basic principles of success:
1. Home Figure Client;
2. Customer service only at a high level;
3. Each employee must be interested in income banks
4. There is no word "impossible" in the bank. Everything's possible.
The bank adopted a business style of clothing. Clothing of bank employees must be neat and restrained. The Bank maintains development in the team of atmosphere of confidence in which any ethical problems may be discussed.
Following the high ethical principles and maintaining the bank's reputation is one of the main tasks of each employee.
With personal communication with the client follows:
Say hello, showing goodwill - carefully and not interrupting, listening to the client, showing interest in the
To inform the Client with reliable information and in an accessible language for all of interest on issues. When communicating with the client, do not provoke conflicts. If you see that your colleague is currently in the workplace, and the client came to him:
Show interest; Submit to the Client, offer your help; If you are not able to solve the client's problem, let me know how urgently find a colleague. Tell a colleague about the arrival of the client. If for any reason you could not find an employee, inform the direct supervisor about the arrival of the client.
Telephone negotiations are part of your work.
Imagine (standard greeting - "Good afternoon, Sberbank") .-
Find out who calls and what is the point of call.
Answer the question or repeat the customer's question .-
If the solution is not in your competence, then you need to forward the call to the competent person. Be sure to call the client if they promised to do it.
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Transcript.
2 Mission and Values \u200b\u200bWe give people confidence and reliability, we make their lives better, helping to implement aspirations and dreams. Our values: Landmarks that help us make faithful solutions in any situations: I leader we accept responsibility for yourself and for what is happening around us. We do the best, on what we are capable. We are constantly developing and improving ourselves, the bank and our environment. We are honest with each other and with our customers. We team we will readily help each other, working on the overall result. We are open and trust our colleagues. We attribute to each other with respect. We help grow and develop our colleagues. Everything for the client all our activities are built around and for the interests of customers. We want to amaze and delight customers with the quality of their services and our relationship. We are superior to the expectations of our customers.
3 Appeal by the Chairman of the Supervisory Board of PJSC Sberbank 4 Appeal of the President, Chairman of the Board of PJSC Sberbank 5 1. On the Code of Ethics for whom the Codex is intended? Observe the Code - do the proper additional charges of managers ("tone above") ethical conflicts and informing about violations of violations that need to be reported immediately compliance with the ethical principles on the work of customer relations Bank as an employer working atmosphere Health, safety and labor protection of the external type ( "Dress Code") which followed by the Bank's employees Protection of bank assets and thrift conflict of interest Joint work of close relatives Labor activities outside the bank, participation in the authorized capital and third-party management bodies Exchange gifts and representative expenses Use of bank and counterparties Risk culture Ethical Risk Culture Business practices Honest competition Counteracting corruption Countering legalization (laundering) of income obtained by criminal means, and financing terrorism Completing operations using insider information and market manipulation disclosed IE information Transparency of business is the accuracy of reporting Public communications Privacy protection Communication in social networks Responsible leadership Shareholders participation in public and political activities. Charity and sponsorship Interaction with government agencies Promoting economic progress and social well-being Respect for human rights. Environmental protection Final provisions Liability for violation of the Code Amendments to Codex 61 Designations: What does this mean for me? IMPORTANT QUESTIONS AND ANSWERS Optional 2 3
4 Appeal by Chairman of the Supervisory Board PJSC Sberbank President's appeal, Chairman of the Board of PJSC Sberbank Dear Colleagues! Bankers and financiers at all times attached particular importance not only to business, but also the moral qualities of representatives of their profession. Accuracy and accuracy, responsibility and loyalty to this word, knowledge and compliance with laws play a fundamental role in the financial world. All these requirements are reflected in the Corporate Ethics Code of Sberbank, which takes into account both international experience and the specifics of Sberbank of the largest bank of Russia. The Code establishes the requirements for professional activities, interaction in the team, relationships with partners, clients and society. Sberbank distinguishes not only the scale it uses a high level of customer confidence. This is the trust of invaluable capital, which is emerging from the actions of employees and managers. Therefore, each of us must follow the values \u200b\u200bof the bank, the principles of morality and the standards of corporate ethics in their daily work. The Supervisory Board supports the Code and considers it important on a personal example to show the commitment to high standards of corporate ethics of Sberbank. Sincerely, S. M. Ignatiev Dear colleagues! Before you Codex Corporate Ethics of the Sberbank Group. This is a set of major rules of behavior and principles of doing business adopted in our team. The code is intended for anyone who works in Sberbank and represents his interests in Russia and abroad. It is based on our mission and values, high professionalism, respect for customers and colleagues, strict adherence to the requirements of legislation and domestic policies of the Bank, the unacceptability of corruption and any other illegal actions. For me, as well as for each member of the Sberbank team, following the Codex, this is an integral part of work, which depends on the confidence of customers, the reputation of the bank, and therefore its successful long-term development. At the same time, my debt and debt of all bank leaders to file an example of impeccable behavior and maintain an open communication atmosphere in the team, in which the commitment of ethics principles is a priority in any situation. If you have a question about the ethics of one or another solution, be sure to refer to your head or special informing lines. Never neglect the Rules of the Code and remember that the success of the Bank depends on each of us members of the Sberbank team, which has more than three hundred thousand employees in 22 countries. Only together with joint efforts, we can achieve a high goal, which was set to make a bank of one of the best financial companies in the world. Sincerely, G. O. Gref 4 5 appeal
5 1. On the Code of Ethics 1.1. Who is the code for whom? Code of Corporate Ethics Sberbank (hereinafter referred to as the Ethics Code, the Code reflects the Standards of Conduct, based on our mission and values, guaranteeing honest and fair attitudes towards members of our team, customers, partners, as well as compliance with laws and domestic policies. The Code will help you on time to recognize situations that do not meet the ethical principles of Sberbank. From the code you will learn how to do if you have questions about the ethical behavior. Remember that the daily work of each of you, your actions and decisions are reflected on the attitude towards the bank, its reputation. By the text of the Code, you will see questions for self-test in the sections "What does this mean for me?", As well as examples of how the Code can be used in practice in the "Question and Answers" sections. The Code of Ethics is designed for each member of the Sberbank team: all bank employees are regardless of the post office, as well as members of the Supervisory Board. We welcome and encourage partners, counterparties and customers of Sberbank to the bank with ethical standards. If you attract third parties to work with Sberbank, make sure that the partner has due reputation and shares ethical standards reflected in the Code. The code establishes uniform principles of business ethics and business behavior for all companies of the Sberbank group, regardless of their location. Sberbank Groups can develop their own ethics codes based on the provisions of the Code and the applicable law. Q: What do the bank's statements mean that he is doing business in an honest and open manner and complies with the requirements of business ethics? A: This means that we strive to honestly and openly work with customers, counterparties, partners and colleagues. None of the employees should use the official position for personal purposes, as well as to receive illegal benefits for themselves or other persons. 7 About the Code of Ethics
6 1.2. Observe the Code Entroduction Does I always guide the Code in my work? Do I act "bypass" received requirements? Did I add to my head or to the informational line operating in the bank when I had doubts about the standards of business ethics? Sberbank operates in many regions of the world. The members of our team are citizens of many countries, as a result of which the Bank's activities are governed by many different laws, customs and cultures. In our work, we must comply with all applicable local laws and regulations in addition to the Code. Compliance with the provisions of the Code is mandatory for all members of the Sberbank team, this is an integral condition for each of us. In some cases, the individual provisions of the Code can conflict with local legislation. If you are faced with a contradiction, and local legislation makes more stringent requirements follow the requirements of local legislation. Each member of our team undertakes: to comply with the requirements of the legislation. If you have noticed any case of violation of legislation requirements, or you are asked to commit an act, which, in your opinion, can lead to their violation, immediately report this to your direct supervisor or the current informing lines; familiarize yourself with the provisions of the Ethics Code and be guided by them in daily work, avoid inappropriate behavior; to pass by the bank training courses on individual issues of the Code; Know and follow the provisions of internal policies applicable to your work. You will certainly do not remember the position of the provisions of all regulatory documents of the bank, but must understand the principles laid into documents and know what document should be checked if necessary; With respect to treat colleagues, support new employees; Perform job duties qualitatively and on time, strive to find the optimal decision, be responsible for the result of its work; recognize your mistakes, report them to managers and colleagues in order to minimize possible negative consequences; assist in the bank of investigations on the facts of possible violations; To seek help from your direct supervisor or on the line of informing if you have questions about the application of the Code or doubt about the observance of ethical principles. If you have turned to the direct supervisor, but the question is not solved, then in the Code you will find a detailed description of other ways to report a problem. 8 9 About the Code of Ethics
7 1.3. Additional duties of managers ("tone from above") as a leader, how do I create a confidence atmosphere in the team in which any ethical problems may be discussed? not to give employees of orders that violate the requirements of the legislation, the Code or other principles of business ethics; ensure the active interaction of subordinate employees with the authorized divisions of the Bank on Ethics, provide support to employees who conscientiously initiate a discussion of ethical issues; Immediately take measures to eliminate violations of the principles of ethics, as well as to take the necessary measures of impact; Take into account compliance with the Codec requirements and the contribution of employees to the formation of a culture of behavior in a bank during their assessment. Additional responsibility for creating and maintaining such a culture of behavior, in which employees know and understand their duties and freely inform about their doubts and problems. The leaders of any level are required: on a personal example, to show commitment to the principles of ethics; provide familiarization with the provisions of the code of subordinate employees, understanding and respecting the principles of the Code, including the understanding that commercial or financial results may not be more important than ethical behavior; Q: What does the term "Open Communication Wednesday in the Collective" mean? A: Open communication Wednesday in the team is an open and confidence atmosphere of communicating in the team, where employees without fears discuss any ethical problems, and leaders listen to their opinion. However, this term does not mean that you can freely disclose internal, service, confidential, insider information, personal data of employees and other non-public information of the bank, its clients and third parties. Create an open communication environment in the team, in which each employee feels comfortable, to discuss one or another question for discussion; About the Code of Ethics
8 1.4. Ethical conflicts and informing about violations If you have any doubts, how to do in a particular situation, ask yourself the following questions: 1. Does this decision or action (inaction) comply with the legislation, the Code of Ethics, other internal politicians of the bank? Yes 2. Is it logical and reasonable to this decision or action (inaction) in terms of the interests of the bank? Yes 3. Have you been taken into account when making a decision or implementation (inaction) the interests of all persons to which it could affect? Yes. Are you sure that this decision or action (inaction) will not have a negative effect on the reputation of the bank? Yes No No No. Contact advice. Contact advice. Contact your advice for advice. Contact your advice. Qualified consultation. You can also apply for an explanation on the informing line. If you think your head is involved in doubtful activities, contact a higher supervisor. Any employee who asks questions, refers to consultation, conscientiously reports violation, acts in accordance with the Code. The Bank guarantees that the employee will not be subjected to any punishment for a good report on violation and for reasonable requirements for compliance with ethical standards by other employees. All information received from the employee is checked in compliance with the confidentiality regime, and the identified violations are investigated in accordance with the procedures established in the Bank. The employee has the right to preserve the anonymity of his oral and written appeal. If an employee was involved in actions that contradict the Code, but voluntarily reported a violation, such actions will be taken into account by the Bank when considering responsibility. At the same time, in relation to the employee who deliberately provided distorted, obviously false information, measures may be applied in accordance with the law. We understand that it is sometimes difficult to make the right choice, so we urge everyone to discover the issues of ethics. 5. Can you explain and justify colleagues and / or regulators this decision or action (inaction), including after a certain period after it is adopted? Yes No. For advice on the Code of Ethics.
9 1.5. Violations that need to be reported immediately, the Bank maintains development in the confidence atmosphere team, in which any ethical problems may be discussed. However, there are violations that need to be immediately reported on the inform lines: the proposal or receipt of a bribe, the promise to give a bribe, other violations of the Bank's policies to combat corruption; cases of fraud; actions aimed at distorting reporting; Actions carrying significant risks of business reputation loss or legal risks for a bank, such as violation of customer rights and investors, performing operations using insider information, laundering moneyobtained by criminal and financing terrorism; Violations of ethical norms, as a result of which the employee / staff or the bank is harmful, and harm and the motives of informing are connected exclusively with the desire to prevent or stop damage. Q: I believe that the actions of my colleague violate the requirements of the Code and may damage the reputation of the bank. My recommendations follow the principles and comply with the requirements of the Codex colleague responds evasively. I'm going to report my suspicions anonymously on a line of informing. Can I do this? A: Yes, it is necessary to report any incident or the presence of suspicion of possible violations of the Code on the informing line existing in the Bank in any way: by phone or email. In the case of an anonymous message, information must be provided in a sufficient amount for the possibility of its timely verification of the Ethics Code
10 2. Compliance with the ethical principles at work we value our reputation, we comply with the ethical principles and implement the obligations assumed always in any circumstances. To colleagues, customers, partners and other persons with whom we interact, we treat with respect and benevolence. We are responsible for the results of our work and for the surrounding working atmosphere of customer relationships with customers with customers the basis of our business. We are here to provide service to our customers, guided by the principles of honesty, openness and justice. The development of our customers' business is the main condition for the development of the bank's business. We always strive to meet the highest standards of service, provide services professionally. We apply an individual approach to each, as it is important to us that the client felt reliably and confidently. Each bank employee fulfills promises, these to customers, promptly responds to requests, is responsible for the results of its work, recognizes errors, extracts lessons and takes the actions necessary for the qualitative fulfillment of their duties, provides comprehensive consultations that do not mislead customers and informs Customers O. possible risks. Feedback from our clients an integral part of our development and self-improvement. Working with appeals, we immediately take measures to quickly resolve the difficulties that have arisen and prevent similar situations in the future. We really appreciate and carefully apply to reviews about our work, as it improves the quality of our products and services and retains the devotion of our customers. Working with customer information, we care about its preservation. Access to the indicated data is due to the production necessity and limited to those personnel of the Bank, which is endowed with relevant powers. 17 Compliance with ethical principles at work
11 2.2. Bank as an employer in: In the process of discussing a transaction with a client, I became clear to me that the client is not fully aware of the risks inherent in financial product. What are my actions? A: The bank is strictly forbidden to take any actions that can have a negative impact on financial interests or client's reputation, including the use of ignorance of the client or restricting its access to information. Therefore, you need to provide the client information about the product with all features. Sberbank team Our main competitive advantage, so we strive for the bank to be the best place to work people of different generations and with different needs. The Bank strictly complies with labor legislation, stands for a reasonable balance between work and personal life Employees, respecting their obligations outside of work. Based on the principles of justice and meritocracy (when the success of employees depends, first of all, from their abilities and hard work), we guarantee the members of our team worthy of labor and equal opportunities for the development of career in accordance with the results of personal effectiveness assessment. Such an assessment takes into account not only performance, but also the compliance of employees to our key competencies: "I am leader", "we team", "all for the client". The bank adopted that leaders represent regular feedback to their subordinates on the results of the assessment. In order to increase the level social security Employees We are constantly developing a system of corporate benefits and privileges. It includes, among other things, medical support program, accident insurance and severe diseases, corporate pension program, material payments due to important life circumstances. Constant development is a necessary condition for our success, so we pay great attention to the professional and personal growth of employees. The Bank provides ample opportunities for training and developing professional, leader and managerial competences of members of their team, including on the basis of the corporate university we have created adherence to ethical principles at work.
12 2.3. Working atmosphere We encourage employees to self-improvement and achieving high results in the work. The Bank has a system of corporate awards, providing for various types of intangible promotion and recognition of employee achievements. We are customary to celebrate the best employees, both by their professional competencies, and for the exemplary manifestation of the Bank's values \u200b\u200bin their behavior. Q: My boss lowered me in the framework of Evaluation 5+. I believe that it deserves a higher rating. Can I complain about the unfair attitude of my supervisor? We strive to create and maintain such a working atmosphere that allows each member of our team to reveal its potential. Our employees openly express their point of view, are not afraid to talk about problems. We recognize the mistakes, remove the lessons and take action. We appreciate teamwork, where every voice will be heard. We respect the views of others and share knowledge and resources to achieve excellent results, ensure high quality of work and assistance to individual and collective growth. Members of our team belong to each other as the inner client we are open and trust each other. Creating an atmosphere of understanding and confidence, as well as supporting the productive work environment Our common duty. In our team are unacceptable, unprecedented, vulgar, coarse, cruel, discriminatory, aggressive or offensive expressions, gestures and forms of behavior. We appreciate a variety of our team. No forms of discrimination, including on the basis of beliefs, age, sexuality and other characteristics, have no right to exist in a bank under any circumstances. A: Discuss a situation with the head, bring arguments to your defense. If you do not agree with the result of the meeting, you can contact a higher supervisor right up to the head of the functional block. If you do not receive an answer or disagree with the decision, you can contact the Commission on Labor Disputes Compliance with Ethics Principles at Work
13 V: Most Time The working atmosphere in our department is friendly and open. However, in stressful situations, my boss / colleague allows themselves rude and aggressive statements in my address. How to act in such cases? A: Comfortable situations at work are each, and this should not be an excuse for inappropriate behavior. You should openly say to your boss / colleague that his words are offensive. In most cases, an open conversation is enough to stop unwanted behavior. If it did not help or you can't discuss with it / with it, this question personally, you can seek help in a personnel unit or on informing the health, safety and labor protection We care about the health and well-being of the members of our team, therefore Ensuring safety and comfortable working conditions, maintaining a healthy lifestyle are a priority for us. The Bank on a systematic basis is evaluated by the working conditions of employees, as well as a set of activities, which allows maintaining safety at a high level. At the same time, safety in the workplace depends not only on the measures taken by the Bank, but also from the competence of each employee. Even the most important and urgent matters we must fulfill only if the rules of safety and labor protection are observed. We believe that a healthy lifestyle is the basis for the harmonious development of our employees. Sports for us - a means of creating a command spirit and a positive attitude. Therefore, the Bank supports the efforts of employees aimed at strengthening their own health and knowledge of a healthy lifestyle, regularly organizes sports events for employees and members of their families. Be careful to issues related to security in the workplace and labor protection. Completely organized by the Bank Educational Courses in this area compliance with ethical principles at work
14 2.5. The external type standard ("Dress Code"), which is followed by the Bank's employees, the Sberbank team are self-confident employees seeking success. Our appearance matches this content. In the choice of clothing, hairstyles and accessories, we are guided by the principle "I am configured to deal with a serious thing and not going to slip anyone." We are not supporters of too tough and conservative rules, however, the traditional business style is a mandatory option of our appearance from Monday to Thursday. On Fridays, Dosimo Timo coming to work in free clothing of a neat look. The exceptions are employees who conduct meetings with customers who go to meetings outside the office or obliged to wear a uniform. For those categories of employees, whose working standards imply wearing uniforms, its wearing is obligatory at all without exception working days, the protection of bank assets and is escaped whether I care about the property of the bank? Do I use the Bank's resources for personal purposes? Do I not forget about the rules of rational use of resources? Will I turn off the water, light and office equipment, electrical appliances? We are convinced that all members of the Sberbank team are obliged to act in good faith and not to allow inappropriate use or embezzlement of the property of the bank, official information and funds allocated for travel and representative expenses. First of all, our employees are guided by the interests of the bank. We spend, if there are no other opportunities not to spend, and only for performing work. We save the funds of the bank and pay the costs as if we manage our money. In more detail, the requirements for the appearance of employees are established in the rules of the Bank's internal labor regulations. Compliance with ethical principles at work.
16 2.8. The joint work of close relatives did I reveal information about the fact that my relatives work in the bank, and I interact with them in the process of my work? Q: Can I make decisions / influence decision-making on working with organizations where my relatives or close friends work? A: These situations should be avoided. In any case, you need to reveal the information to your head. In more detail, the principles of prevention, timely disclosure and conflict management of interests established in the Bank, as well as examples of situations that can lead to conflict of interest are set forth in the Bank's policy management policy management. In most cases, the collaboration of relatives in the bank is not prohibited. However, in order to minimize the risk of conflict of interest, the Bank adheres to the principle of limiting the collaboration cases of close relatives, as well as prohibits family-based protectionism. The joint work of close relatives in the bank, in direct or functional submission, is prohibited, and in other cases the potential conflict of interest is allowed only by decision of the Compliance Committee compliance with the ethical principles at work
17 2.9. Labor activity outside the bank, participation in the authorized capital and the bodies of third-party managers, did I reveal information about my participation in the authorized capital of third parties / work in the management bodies of other organizations / on the implementation of independent commercial activities? How does my job outside the bank affect the execution of my job duties in a bank? The Bank recognizes the right of employees to engage in labor activities outside the Bank, subject to a number of conditions. In accordance with the banking legislation, the Bank's individual officials are prohibited from combining activities in other credit and a number of other non-credit organizations. Observe the rules established in the bank, the rules for the protection of non-public information entrusted to you or who have become known in the process of execution of official duties. To make sure that there is no conflict of interest, the bank expects employees to notify their immediate leader about any work outside the bank. Q: Working in the field of information technology in a bank, I plan to open a similar business in the field of IT developments that I do in the bank. Can I do it? A: In the Bank, employees are prohibited from entrepreneurial activities or other commercial activities, which has become accessible to the provision in the Bank, including using business connections and the possibilities of the Bank. If the planned activity complies with the requirements of the bank, it is possible. Detailed requirements for employees in the implementation of relations with clients and counterparties, in particular, restrictions on participation in the authorized capital or management bodies of such organizations, as well as on the implementation of independent commercial activities, are reflected in the Bank's policies to combat corruption. The following rules must be remembered: carry out such activities only during, free from the performance of official duties in the bank; Make sure that other labor activity does not affect your work duties in the bank, does not cause damage to the image and interests of the bank; Compliance with ethical principles at work
18 2.10. Exchange gifts and executive costs before accepting a gift, ask yourself: can this gift or a reason for it to affect the objectivity of my decisions regarding this company? Would I like this gift to know my immediate supervisor and my colleagues? The bank welcomes the development of partnerships with clients and counterparties and allows for the exchange of corporate gifts that meet business practice. We are aware that the exchange of business gifts and invitations to representative activities is a socially recognized component of business relations, but it is necessary to remember that such cases under no circumstances should the damage of the Bank's business reputation. Gifts must have a direct relationship with the legitimate purpose of donation and not to create impressions of unlawful actions. It must be remembered that the internal policies of customers and partners may not assume the adoption of gifts and even completely prohibit their adoption and donation. Bank employees are not allowed to receive gifts from any third parties: for making any actions (inaction) related to the work in the bank; in the form of cash or cash equivalents; In the absence of a generally accepted occasion for a gift. Q: How do I do if a gift was presented to me, which is prohibited by the Bank's internal politicians? A: You must refuse to adopt this gift, politely explaining that the internal politicians of the Bank prohibit such gifts. Requirements for business gifts are consolidated in the Corruption Corruption Policy. worth over the limit established by the Bank; Compliance with ethical principles at work
19 2.11. The use of the Bank's and counterparties risk culture to Sberbank employees and their family members are recommended to contact the Bank for financial services for private purposes, but such services should be provided under the same conditions on which they are provided to other clients or, in the presence of the Bank's corporate program, Other employees. Service staff should not damage the bank and discriminate with other customers. Similarly, bank employees should not be used by the privileges by counterparties, if such privileges are not available to other Bank employees under the same conditions within corporate programs. The use of special conditions for employee service as customers is allowed exclusively as part of special motivation development programs. Q: One of the bank suppliers with whom I constantly work, offered me a discount on my products. Can I take advantage of this discount? A: You can use this discount only if a similar discount has been proposed in relation to all employees of Sberbank. Otherwise, the supplier should thank for the offer and politely refuse. Did I go on risk management? Can I manage the risks associated with my work? Do I recognize my mistakes, do it in a timely manner? Do I expose planned solutions to critical analysis from the point of view of risks? Is I ready to cooperate for the sake of achieving the goals of the bank? Do I understand the essence of the rules applicable to my work, do not only fulfill their letter, but also the Spirit? In order for the bank to successfully develop in ever-changing conditions, we continually improve our risk management system. Therefore, each of us should be aware of risk management rules and act in accordance with the principles of risk-culture, namely: to identify the risks associated with our activities, analyze them and evaluate with the help of available tools, focusing on the allowed risk limits specified in the bank ; Obviously talk and report any risk-related situations, even if it seems insignificant, since timely detection of potential problems or recognition of errors allows you to minimize possible negative consequences; strive for cooperation and follow the general goals of the Bank, including formulated in its development strategy, and not exclusively to the goals of its division or their own; observe not only the letter, but also the spirit of the rules adopted to comply with the ethical principles at work
20 3. The commitment to ethical practices of doing business, we categorically not accept unethical practices of doing business in any manifestations and demand from all members of their team of immaculate compliance with the requirements of legislation and internal policies of the Bank. Bank policies in risk management, information on principles and risk-cultural rules in the bank you can find on the domestic portal. 36.
21 3.1. Honest competition Do I really get and use information about competitors and partners? In relations with our partners and competitors, we act in accordance with fair competition standards and best business practices. The Bank complies with competition laws in all business countries. Choosing partners to provide services, fulfill the work or supply of goods, the Bank complies with the principles of equality, justice and the absence of discrimination. We collect and use information about partners and competitors exclusively on the terms of legality and ethiquids. Anti-corruption is acceptable to a service that one of the bank's partners has suggested, or is it a hidden remuneration? The Bank in its activities adheres to the principle of non-acceptance of corruption in any forms and manifestations (the principle of "zero tolerance") and considers its duty to promote the level of anti-corruption culture in society. A member of the Sberbank team in any circumstances is prohibited, including, directly or indirectly, personally or through the mediation of third parties to offer, give, promise, ask and receive bribes or make payments to simplify administrative, bureaucratic and other procedures in any form. The bank expects customers, counterparties and partners to comply with the relevant duties to combat corruption. Our common goal is to maintain a high business reputation of the Bank, so every bank employee in its everyday work makes reasonable efforts to minimize the risk of business relationships with counterparties, which were or can be involved in corrupt activities commitment to ethical business practices.
22 V: Partner of the Bank proposed to provide me with a service if I inform him about the parameters of new products that the bank plans to launch in the near future. What should I do? A: You should refuse this proposal and explain to the partner that Sberbank does not provide such information before its official announcement. In more detail, the principles of prevention and anti-corruption, set out in the Bank's policy to counter corruption, countering the legalization (laundering) of the income obtained by criminal, and whether the principle of "knowing my client / partner" should be finanted in its work? Sberbank strictly complies with the requirements of the legislation on countering the legalization (laundering) of the income obtained by criminal means and financing terrorism. We apply all possible preventive measures to have business relationships only with reliable customers and counterparties that are engaged in legal activities and receive income from legal sources. When conducting identification and preliminary verification of customers and partners, you must make sure that you understand the specifics of their activities, as well as understand the source of origin and appointment of funds commitment to ethical business practices
23 3.4. Completing operations using insider information and market manipulation in: The client with whom I work began to perform atypical transactions associated with the turnover of cash. What should I do? A: Notify in the compliance division about its observations. In more detail, the Rules of the Bank in this area are reflected in the Internal Control Rules in order to counter the legalization (laundering) of the income obtained by criminal means, and the financing of terrorism. Will I not disclose the information that is still unknown to the public, in a conversation with friends and relatives? In the course of its work in the bank, each team member can learn insider information about the bank and other organizations before this information becomes public. The use of such information to receive personal benefits for an employee or third parties violates the requirements of legislation. All team members need to be remembered by the following rules in relation to the use of insider information and market manipulation: do not commit personal operations with financial instruments of organizations for which you possess insider information and do not recommend other operations to others; Do not disclose insider information to anyone outside the bank, including members of your family, before its official disclosure; Ethical business practices commitment
24 Transfer insider information to other bank employees only in accordance with the regulations adopted; Do not accomplish actions aimed at manipulating market prices, do not distribute false information or rumors; Adhere to the rules adopted in the bank and restrictions on conducting personal operations with financial instruments. Q: During the conversation with one of the clients, I received information, the use of which will allow me to conduct a successful deal with securities for personal purposes before the information becomes public. How should I do? A: You should not make a deal, as a similar deal can be regarded as a deal committed using insider information. 4. Disclosure We want our customers, employees, partners, shareholders and investors have full and balanced information about our activities. We strive to be open and active in our communications. We protect confidential information about customers, other information protected by law, as well as information capable of influencing our competitive advantage. In more detail with the Rules of the Bank in the field of preventing the use of unfair trade methods, you can find in the Bank's standard for the implementation of personal operations in the Fund and Exchange Commodity Markets, as well as the order of access to the Bank's Insider Information, the rules for the protection of its confidentiality and monitoring the implementation of the Federal Law 224- FZ. 44.
25 4.1. Business transparency 4.2. Accountability Reportments We provide transparency of our activities, openly interacting with various stakeholders and publishing reliable and timely information of both financial and non-financial character. When disclosing information, we are guided by the principles of regularity, sequence, efficiency, availability, accuracy, completeness and comparability of the disclosed data. Being a public company, we fully comply with the requirements of regulators and exchange exchanges on information disclosure, as well as publish additional information that are necessary for interested parties to make investment or other decisions, drawing up a full and objective understanding of the Bank's activities. In more detail in the Bank, the standards and information disclosure rules are reflected in the Bank's domestic policies. With due liability, I treat the provision of information on the bank's profile divisions to compile reporting? In a timely manner and in sufficient amount I send the relevant information? The financial and non-financial reporting of Sberbank is drawn up in accordance with the adopted standards and fully reflects in all significant aspects the financial situation and the results of the Bank's activities. Bank employees as part of their competencies and in accordance with the regulations of workflows should be honest, carefully, in a timely manner and fully compile reporting on the indicators of their activities and activities of the Bank. The provision of inaccurate, incomplete, contradictory and late reporting is unacceptable. The bank is prohibited by falsification of documents, distortion of the true nature of any operations disclosure of information
26 4.3. Public communications in the bank defined a circle of persons representing it in public relations. Therefore, in cases where media representatives ask us to comment on this or that question, we recommend that they apply to the authorized division, most often this is the press service of the bank. Authorized persons when communicating with media representatives, investors, analysts or in other public communications are responsible for compliance with the requirements of the Bank, applicable law, as well as ensuring the reliability and integrity of the transmitted information. Q: Recently I was invited to speak at the university, which I graduated from the program, where all graduates talk about their labor life. Can I make a story about my work in a bank? A: You can perform at external events (conferences, forums, round tables) with a story about your work experience in the Bank in coordination with your direct supervisor and with a public relations division Protecting confidential information Employees as part of their job responsibilities may have access to non-public (confidential) information relating to the bank, colleagues, customers or counterparties. In this regard, employees are obliged to comply with informational barriers between units when non-public information is reliably protected. In particular, the transfer of confidential information should be carried out on protected channels. The bank expects employees moving towards another job place, will maintain the confidentiality of service / non-public information of the bank. In turn, the Bank does not oblige new employees to disclose official / non-public information organizations in which they worked earlier. Q: I discovered documents with information about customer accounts in the general access area from the printer, when I was delayed at work after the end of the working day. What should be taken? A: Remove the documents found in a safe place, report finding your leader and return the responsible person to disclose information
27 4.5. Communication in social networks 5. Responsible leadership staff should remember that communication on social networks of the Internet is usually public in nature. Employees are prohibited to disseminate or discuss without the consent of the Bank on public Internet resources information related to the Bank's activities, including using logos, trademarks and symbols of the bank, place photos and video images that do not correspond to reality and / or discontinuing the bank's business reputation. Sberbank is the largest financial organization of Russia and operates in many countries of the world. Our team has many thousands of people, and the number of customers is calculated in millions. This provision implies a special responsibility of the Bank for how its actions may affect the economic, social and environmental development of the regions of presence and local communities. Q: Can I answer my behalf on questions and customer claims to the bank coming in social networks? A: No, you can not. Remember that communicating in working / non-working time on the official pages of the bank on social networks, you are perceived as a representative of the bank and the information provided by you may be incorrectly interpreted. Answers to questions and comments on the official pages of the bank in social networks are prepared by the Bank employees with authorized on that. fifty
28 5.1. Shareholders Respect for the rights and legitimate interests of all shareholders of the Bank, ensuring equality of conditions for owners of shares of one category, regardless of the number of shares affiliates the basis of the Bank's relationship with their shareholders and one of the fundamental principles of the Sberbank corporate governance system. In relation to shareholders, we create the most favorable conditions for the realization of shareholders' rights, including such as: participation in the Bank's management, participation in profits, obtaining information on the Bank's activities; Application of the best Russian and international corporate governance practices; 5.2. Participation in public and political activities. Charity and sponsorship Good deeds An integral part of our corporate culture. Therefore, one of the traditional directions for Sberbank's participation in society is to participate in socially significant projects in the field of sports, culture and art, science and education, in charitable and volunteer programs. We consider our duty to help ensure reliable ways of accounting for rights per shares, as well as their free appeal to stock markets, including providing shareholders to the purchase and sale of shares on market price. All our actions are aimed at preserving and multiplying share capital. Applied by the Bank, the standards in the field of corporate governance are formulated in the Corporate Governance Code of the Bank Responsible Leadership
29 children's institutions and organizations of health care, public organizations of veterans of hostilities. Within the framework of sponsorship programs, Sberbank also contributes to the largest Russian and international business events. The bank does not participate in the activities of political and religious organizations and does not finance their activities. Employees participating in non-working time in political, religious or other public activities are obliged to act in these cases only as individuals, not representatives of the bank. On the territory of the bank, agitation is not allowed in favor of any political party or candidate, as well as the dissemination by employees of their religious views and beliefs. All team members are prohibited from the behalf of the Bank to present gifts, make contributions to political purposes, or organize entertainment activities for political parties or candidates for political positions. Interaction with state bodies of the Bank's relationship with state authorities and local governments, banking authorities and banking supervisors are based on Principles of compliance with legislation, transparency and cooperation. Bank employees must be polite and professional, express the official position of the bank and not to prevent investigations in case of their conduct. With information on the implementation of charitable activities in the bank you can find on the internal portal of the bank responsible leadership
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"Code of Corporate Governance of Sberbank 2015 Table of Contents 1. Preamble 2. On Bank 3. Commitment of Principles ..."
-- [ Page 1 ] --
Approved
by the decision of the Supervisory Board
OJSC "Sberbank of Russia"
Protocol number 19 dated 04.20.2015
corporate governance
Sberbank
1. Preamble
2. About Bank
3. Commitment of corporate governance principles
3.1. Mission, vision and value
3.2. Principles of the system of ku Sberbank
4. Compliance with the rights of shareholders
4.1. Capital Structure
4.2. General Meeting of Shareholders Sberbank
4.3. Protection of shareholders' rights / Fiduciary responsibility
4.4. Dividend Policy
4.5. Significant corporate actions
4.6. Approval of interested transactions
5.1. Supervisory Board - Key Element Sberbank System
5.2. Governing body
5.3. President, Chairman of the Board
5.4. Distribution of powers and interaction of the supervisory board and executive bodies of Sberbank
5.5. Corporate Secretary
5.6. Motivation and remuneration of members of the Supervisory Board and Sberbank Management .... 15
5.7. Insurance of responsibility of members of the Supervisory Board and Board
6.1. Compliance with the principles of business ethics and anti-corruption
6.2. Policy regarding potential and existing conflicts of interest
6.3. Confidential and Insider Information Policy
7. Internal control and risk management systems, external auditor
7.2. Organization of risk management process
7.3. Internal control service
7.4. Internal audit service
7.5. External auditor
7.6. Foreign and Internal Communication Policy for Risk
7.7. Approaches to the formation of corporate governance of controlled companies
8. Communication and transparency
8.1. General principles disclosure of information on Sberbank's activities
8.2. Communications with investors and shareholders
8.3. Feedback
9. Final provisions
1. Preamble Recognizing the importance of following the high standards of corporate governance in order to ensure sustainable business development, as well as understanding the importance of respect and ensuring the rights and legitimate interests of shareholders, OJSC Sberbank of Russia (hereinafter - Sberbank, Bank) formulates in this Corporate Governance Code (hereinafter - Code) Basic approaches, requirements and principles of the corporate governance system (hereinafter referred to as the QU).
The main goal of the development of the Code is our desire to describe the current system of QU and create a mechanism for its further improvement in order to ensure the rights and interests of shareholders, increasing the efficiency of business, increasing the level of transparency and investment attractiveness of the bank, the preservation and increase in share capital.
Corporate governance is evolutionary by nature, its improvement is based on the results already achieved and the examples of the best practice. As they are developed and implementing the provisions of this Code can be periodically subjected to revision or clarification.
We are a bank team, we undertake to carry out work on the continuous improvement of the Bank's corporate governance and practice and will continue to consistently develop our system of KU, taking into account the interests of shareholders, employees and partners of the Bank, taking into account the change in Russian and international corporate governance standards.
This Code is a public document, which is a set of principles.
Specific procedures and practices of corporate governance are written in detail and regulated by the Charter and internal documents of the Bank, including:
Regulations on the general meeting of shareholders;
Position of the Supervisory Board;
Regulations on the Board.
All these documents are designed in accordance with the legislation. Russian FederationAs well as taking into account the provisions of the Corporate Governance Code approved by the Bank of Russia, you can familiarize yourself with them on our website on the Internet.
2. About Bank Sberbank is the largest bank of the Russian Federation, which is one of the system-forming companies in the country. In the domestic market, the Bank occupies a leading position in terms of assets, capital, infrastructure scale.
Sberbank is a head organization of the International Banking Group. The bank has a wide presence of both Russian and international market. banking services and products, becoming a truly universal bank operating in 22 countries around the world.
Sberbank has existed over 170 years, and the next chapter of our history was opened in 1991, when the Bank was transformed from the state institution to a joint stock company - at the same time the formation began acting system Corporate governance.
3. The commitment to the principles of corporate governance under corporate governance, we understand the system of relationships between shareholders (owners), the Supervisory Board, management and other interested parties, which establishes the rules and procedures for making corporate decisions, ensuring the management and control of the Bank's activities.
3.1. Mission, vision and value Our mission determines the meaning and content of Sberbank's activities, emphasizing its crucial role in the Russian economy. Our clients, their needs, dreams and goals are the basis of the Bank's activities as an organization. Following your mission, the bank seeks to become one of the best financial companies in the world.
High goals are achieved by a team of like-minded people who unites general system values. Our values \u200b\u200bare the basis of attitudes towards life and work, an internal compass that helps make decisions in difficult situations.
Landmarks that help us make faithful solutions:
I am the leader, o We are a team, o all for the client.
o We want these guidelines to be filled with real content and everyday significance for all Sberbank employees.
3.2. Principles of the system of ku Sberbank Existing system KUB Bank fully follows the regulatory requirements of the legislation of the Russian Federation, regulatory bodies, Moscow Exchange, London and Frankfurt Exchange sites (in accordance with the terms and criteria of the Listing), the recommendations of the Basel Committee on Banking Supervision and the Financial Stability Council financial organizationsAnd also focuses on the recommendation of the Corporate Governance Code approved by the Bank of Russia, and the best international standards and practices of corporate governance.
Our system is aimed at a sustainable increase in the cost of share capital in the long term and implies the need to take into account when making decisions both financial and macroeconomic, social and environmental aspects of the Bank's activities.
We develop the CB system based on the following principles:
Priority of the rights and interests of shareholders;
Ensuring long-term sustainable business development;
Delimitation of powers and responsibility when managing business;
Compliance of competence and qualifications of activity;
Complete accountability of the management of shareholders;
Balance and efficiency of internal control systems and risk management systems;
Information transparency.
The consistent improvement of the system of the KU and the increase in its effectiveness is part of the Bank's Development Strategy.
4. Compliance with the rights of shareholders. Respect for the legitimate interests of the owners of the bank's shares, ensuring equality of rights for all shareholders - owners of shares of the same category (type), regardless of the number of shares belonging to them and the same attitude towards them from the bank is one of the main tasks of corporate governance.
The Ku Bank system ensures equal attitude to all shareholders in the exercise of the right to participate in the Bank's management and creates the most favorable opportunities for its implementation.
The Bank provides its shareholders a fair opportunity to participate in its profits by receiving dividends and the right to obtain substantial information on the Bank's activities.
4.1. The capital structure of the Bank, being a public company, ensures the free appeal of its shares on financial markets, providing shareholders and investors the possibility of buying and selling valuable papers at a market price.
The authorized capital of Sberbank consists of two types of shares: ordinary shares (95.6%) and preferred shares (4.4%), equal nominal value. Ordinary shares in an amount not exceeding 25% of the total number of ordinary shares may apply outside the Russian Federation in the form of depositary receipts issued on them.
A feature of the structure of the authorized capital of the bank is the presence of a controlling shareholder in the person of the Bank of Russia, whose share in the authorized capital is 50% + 1 voting action.
Ordinary shares have the right to vote on all issues of the agenda of the General Meeting of Shareholders (hereinafter referred to as the Assembly, OSA). Preference shares There are no voting rights at the shareholders meeting, except in cases established by the legislation of the Russian Federation, but have the right to receive the dividend in the amount of at least 15% of the nominal value of shares.
4.2. The general meeting of shareholders of Sberbank The principle of prioritization of the rights and interests of shareholders includes the possibility of adoption by shareholders of important decisions for the Bank's activities, such as: approval of documents regulating the work of the Bank's bodies, the distribution of profits, as well as the election of members of the Supervisory Board (hereinafter also ns).
The procedure for the preparation and holding of the General Meeting of Shareholders is determined in the Regulations on the General Meeting of Shareholders, in accordance with which each shareholder has the opportunity to freely realize the right to vote with a convenient way for it. The bank will make all reasonable efforts, in order for voting shares belonging to legal entities to him, controlled (quasi-competition shares), did not participate in the voting at the meeting of shareholders of the Bank. Any shareholder or his representative who is present at the meeting has the right to express his opinion and ask his questions to the Chairman of the Assembly, present to members and candidates for the Supervisory Board and the Audit Commission, to the representative of the auditor, members of the executive bodies.
Our permanent practice is the organization of OSA broadcasts on the Bank's website on the Internet in Russian and English.
In the period between meetings, shareholders may receive answers to questions that arise from them through the Bank's corporate secretary.
4.3. Protection of shareholders' rights / Fiduciary Responsibility The degree of our liability to shareholders does not depend on the size of the shareholder to which they own. It is to ensure that the interests of shareholders who trusted us the decision-making on managing their capital is the main priority for us, but at the same time we make every efforts that the interests and other stakeholders in the issues of corporate and social responsibility of the bank were taken into account when developing its development and implementation strategy. current activities.
Our control shareholder in accordance with the legislation of the Russian Federation annually puts forward its candidates for the Supervisory Board, and the interests of minority shareholders are primarily independent (from the influence of executive bodies, individual groups of shareholders or other stakeholders, as well as non-banks, the state , the main shareholder or competitor of the bank) members of the Supervisory Board, but at the same time, each of the members of the Supervisory Board represents the interests of all shareholders of the bank, and not just those who directly nominated it.
4.4. Dividend policy to establish a transparent and understandable shareholders to make a decision on the payment of dividends, the determination of the size, order and timing of their payments to the Supervisory Board considers and approves the dividend policy of the Bank to the medium (at least 3 years) perspective. The Supervisory Board provides a general meeting of shareholders recommendations on the size of dividend paid in accordance with dividend policies. The decision to approve the size of dividends and their payment is approved by the OSA.
4.5. Significant corporate actions We consider as significant corporate actions to reorganize the bank, acquiring one shareholder 30 and more percent of voting shares, performing significant transactions (including major transactions and transactions on mergers and acquisitions), an increase or decrease in the authorized capital, the implementation of listing and delusory Shares, as well as other actions that can lead to a significant change in shareholders' rights, violating their interests.
In determining the procedure for the acquisition of bank shares controlled by him legal entities The Bank will strive to ensure equal opportunity for all of its shareholders who own shares of the relevant category (type), to sell the legal entity to the legal entity in proportion to the packages belonging to them on equal terms, except in cases of the acquisition of bank shares controlled by legal entities in the framework of trade activities in the stock market .
Action that can entrust forced delusting securities is unacceptable for the bank.
When making decisions on significant corporate actions, understanding the degree of responsibility, management bodies can:
form special working groups at the board level of the bank;
create a temporary committee under the Supervisory Board;
to make a question on the essential corporate action on the USA vote, if the decision of such a question is classified as the legislation of the Russian Federation to its competence.
All information on significant corporate events is promptly revealed by us in accordance with the legislation of the Russian Federation and the Bank's Information Policy.
4.6. Approval of transactions with interest in accordance with the requirements of the legislation and the best practices of corporate governance, we consider the transaction with the interest in the following order, in particular:
we carry out a preliminary analysis of the availability of interest among members of the National Assembly and the executive bodies participating in decision-making;
interested parties are removed from the process of discussing the transaction and making a decision on it.
All information about transactions with interest is promptly revealed by us in accordance with the legislation of the Russian Federation.
5. Structure of the Sberbank system
The main elements of the KU system are:
The general meeting of shareholders is the highest management body, through which shareholders implement their right to manage the bank.
The Supervisory Board is a collegial management body, implements strategic management, determines the basic principles and approaches to the organization at the KU system (including risk management systems and internal control), provides recommendations to the executive bodies and controls their activities.
The President, Chairman of the Board is the sole executive body, heads the Board and leads the management of the Bank's current activities.
The Board of the Bank is a collegial executive body, which leads the management of the Bank's current activities and implements strategies defined by the Supervisory Board.
Bank Corporate Management System
5.1. The Supervisory Board is the key element of Sberbank's KU system, we understand that an effective professional observational council is the main condition for successful corporate governance. The Supervisory Board defines the principles of formation and approaches to the organization of the corporate governance system in the Bank.
In order to sustainable and systematic development of the Bank, members of the Supervisory Board should be reasonably and conscientious with proper care and prudence to carry out responsibilities assigned to them in the interests of the Bank and its shareholders, carrying personal responsibility for the decisions made.
The effective work of the Supervisory Board is determined by:
Understanding the needs of the business and the role of the Supervisory Board in the development of the Bank;
The ability to attract the highest level professionals in the observation council;
Balanced system of motivation and remuneration of members of the Supervisory Board;
Ensuring modern technological and organizational conditions for the work of members of the NA;
Opportunities for further professional growth for members of the Supervisory Board;
Self-control of the activities of the Supervisory Board, through the annual assessment and identification of opportunities for improvement;
The effectiveness of communications, both within the Supervisory Board and with the shareholders and the bank management, as well as other key stakeholders.
The Supervisory Board defines the rules for the functioning of the Sberbank system by adopting internal regulatory documents governing the principles and procedure for the work of individual elements of the KU system, as well as through the implementation of the effectiveness of the work of each element and the KU system in general, the NA is accountable to the General Meeting of Shareholders, and information about its work per reporting period disclosed in the annual report.
The main functions of the Supervisory Board being the central element of the KU system, the Supervisory Board is responsible for the development of three key functions:
Management;
Control;
Communications.
According to his role assigned to him:
determines the strategic goals and directions of the development of the Bank;
monitors the activities of the executive bodies, including the compliance of such activities approved by the Supervisory Board of Development Strategy;
forms, monitors the effectiveness of the KU system and ensures its development;
determines the basic principles and approaches to the organization of the risk management system and internal control;
forms the Bank's policies in the field of motivation and remuneration of members of the Supervisory Board, executive bodies and other key executives;
contributes to the development of the talent management system and the formation of a personnel reserve of executive bodies;
controls the provision of transparency of the bank and its activities by ensuring timely and full disclosure of information;
decisions related to the appointment and early termination of the powers of the Board of the Bank.
The competence of the NA is reflected in the Bank's Charter.
The election of the Supervisory Board to the Supervisory Board is elected by persons who have impeccable business and personal reputation and possessing professional knowledge, skills and experiences needed to make decisions relating to the competence of the NA, aimed at making their contribution to the achievement of the general result.
The Supervisory Board is elected annually by shareholders on the OSA. Shareholders who own 2 (two) and more percent of the voting shares, within 75 days after the end of the calendar year can nominate candidates for election in NA.
To improve the decision-making efficiency by shareholders when election of the Supervisory Board, the Committee on Persons and Remuneration prepares recommendations for the vote, which are included in the materials for the OSA.
The composition and status of members of the Supervisory Board The Supervisory Board consists of executive, non-executive and independent directors.
Under the executive directories are members of the NA members who are in labor relations with the Bank.
Under non-executive directors are members of the NA members who do not consist of labor relations with the bank, but are not independent directors.
To ensure the effectiveness of the decisions and maintaining the balance of interests of various groups of shareholders, the NA should include independent director.
An independent director recognizes a member of the Supervisory Board, which has sufficient professionalism, experience and independency for the formation of its own position and capable of making objective and conscientious judgments, independent of the influence of executive bodies, individual groups of shareholders or other stakeholders, and not related to the bank, the state, the main Shareholder or bank's competitor.
NA evaluates the status of independence of candidates, he can recognize the candidate (director) independent, despite its presence of any formal criteria indicating the absence of independence, if the presence of such criteria does not affect the ability of the Director to make independent and objective judgments. When circumstances occur, due to which the Director ceases to be independent, he immediately obliged to notify the NA and the Corporate Secretary. An independent director should refrain from performing actions, as a result of which he can lose the status of an independent director.
Independent directors should be at least 1/3 of the quantitative composition of the Supervisory Board.
By decision of the NA, the senior independent director, the main tasks of which are the provision of assistance to the Chairman of the National Assembly, the organization of the evaluation of its work, coordinating the interaction between independent directors and developing in the necessary cases of the consolidated opinion of independent directors under the issue under consideration.
Chairman of the Supervisory Board The Supervisory Board is headed by the Chairman who is elected from among the NA members at the first after the election of the General Meeting of the National Assembly. The Chairperson manages the work of the NA, organizes the development of an NA work plan, control of the implementation of NA decisions, the formation of the NA meeting agenda, the development of weighted decisions on the agenda items, a free discussion of these issues, a constructive atmosphere of meetings, as well as the right and timely preparation of the minutes of the NA meeting .
The procedure for the work of the Supervisory Board is our goal - to find the right balance between the generality of interests and a variety of opinions and create the conditions for the occupation of each member of the Supervisory Board of an active position regarding the issues considered by the NA.
The Supervisory Board holds meetings in accordance with the plan prepared at the beginning of its term, which ensures proper performance of his duties. If necessary, unscheduled meetings of the Supervisory Board can be carried out.
The NA meetings can be carried out both in full-time, and by correspondence and convened by the Chairman of the National Assembly on its own initiative, at the request of the External Auditor of the Bank, a member of the National Assembly, the Audit Commission, the Board, as well as the President, Chairman of the Board of the Bank.
The meeting of the NA is competent if not less than half the number of elected directors participate in it.
Each member of the National Assembly has one voice. In the event of equality of votes, the voice of the NA Chairman is decisive. Decisions on the NA meeting on the agenda are taken by a majority of the votes of directors participating in the voting, except in cases provided for by the legislation of the Russian Federation and the Bank's Charter, when a larger number of votes are required to take appropriate decisions.
A NA member can participate in the meeting using a video conference or telephone system.
Evaluation of activities and planning continuity in order to identify opportunities to improve the efficiency of the NA and its committees, identifying areas for improvement and development, as well as following the best international corporate governance practices, the NA has been evaluating the quality of its work and the work of the committees, chairman and members of the Supervisory Board. . Periodically (once every 3 years), the NA attracts such an assessment of an independent external consultant. The results of the evaluation of the NA work are provided to the Chairman of the National Assembly, which organizes their discussion with the participation of members of the NA. The evaluation of the work of the Chairperson is carried out by independent director, taking into account the opinions of all members of the Supervisory Board. The generalized results of the evaluation are disclosed in the annual report of the Bank.
Assessment of the Supervisory Board of the Bank allows you to determine its personnel needs, identify strengths and areas to improve its work. In addition, the Committee of the Supervisory Board on personnel and remuneration on the basis of the evaluation results is carried out to work on the formation of a list of additional competences of members of the NA, which is necessary to improve the effectiveness of its work and forms proposals for ns members.
The Supervisory Board, the personnel and remuneration committee may also attract an external company to search for candidates that meet the personnel needs of NA.
The Committee of the Supervisory Board of Personnel and Remuneration prepares recommendations for voting at the General Meeting of Shareholders of the Bank, reflecting the informed NA position in relation to candidates. At the same time, the Supervisory Board ensures maximum transparency of the procedure for assessing candidates and prepare recommendations.
Improving the qualifications of members of the Supervisory Board Members of the National Assembly must have the necessary knowledge and experience, but cannot be experts in all areas. In this regard, there is a need to expand and update the knowledge and development of the competence of members of the Supervisory Board. The Bank organizes special programs to introduce newly elected members of the National Assembly, to improve the qualifications, exchange of experience and additional knowledge, both in certain areas of the Bank's activities, such as on macroeconomics, management, strategic and finance.
The functions of the Supervisory Board committees and their cooperations of the Supervisory Board shall generate committees - advisory bodies created to preliminary consideration of the most important issues of the Bank's activities related to the competence of the Supervisory Board, and the preparation of recommendations to the Supervisory Board for decision-making on issues on issues.
Committees are the supporting bodies of the Supervisory Board and are not entitled to act on behalf of the Bank or NA, and in their activities the committees are fully accountable to NA.
With the Supervisory Board, the following permanent committees are being created:
audit;
by personnel and remuneration;
on strategic planning;
on risk management.
If necessary, the NA is entitled to decide on the creation of other committees.
The audit and personnel and remuneration committees are exclusively of independent directors, and if it is impossible for objective reasons - independent directors constitute the majority of the quantitative composition of these committees, and the remaining members may be members of the Supervisory Board that are not part of the executive bodies of the Bank.
The provision on the committees is approved by the Supervisory Board.
The main tasks of the Audit Committee are to improve the efficiency of internal control systems, corporate governance, ensuring the implementation of management and control functions of the Supervisory Board in the functioning of these systems, monitoring the accuracy of accounting (financial) reporting, as well as the activities of the external auditor and the internal audit service.
The main objectives of the personnel and remuneration committee are strengthening and planning the continuity of members of the executive bodies of the Bank and members of the Supervisory Board, the preparation of proposals for the formation of an effective system of remuneration of members of the Supervisory Board, the executive bodies of the Bank and other key executives.
The purpose of the Strategic Planning Committee is the preparation and submission of recommendations to the Supervisory Board on the Bank's Strategic Development.
The Risk Management Committee conducts a preliminary consideration of the Bank's risk management strategy and its group, and is monitored by the implementation of the Risk Management Strategy and Risk Appetite.
Chairmen of the Committees annually submit to the Supervisory Board report on the work of their committees, as well as reports on the issues considered by the Committee on behalf of the NA.
5.2. Board Board of the Bank is a collegial executive body led by the President, the Chairman of the Board, which carries out the overall management of the Bank's current activities.
In its activities, it is accountable to NA and OSA. The Board at least once a year is a National Assembly Report on the implementation of the Bank's strategy, on the execution of decisions of the NA and the General Meeting of Shareholders, quarterly report on the results of financial and economic activities of the Bank and the level of risks adopted by the Bank.
The basic principles of the Board are professionalism, rationality, conscientiousness, prudency and timeliness.
When making decisions, members of the Board must be aware of their responsibility to shareholders, customers, employees and conscientiously perform responsibilities for the management of the Bank's activities.
Election, deadlines and termination of authority Members of the Board are appointed and exempt from the position of the Council decision. Candidates for board members must comply with the requirements of the legislation of the Russian Federation, imposed on these persons (the qualifications and requirements for business and personal reputation), as well as to enjoy the confidence of the members of the Supervisory Board. The term of office members of the Board is not limited.
Planning continuity Ensuring the continuity of members of the Board is one of the primary tasks of the KU system. The Personnel and Remuneration Committee, together with the management of the Personnel Service of the Bank, is directly responsible for the timely preparation of continuity plans, the exact definition of personnel management needs and the development of existing competencies, the search and attraction of the most appropriate candidates, first of all, at the expense of internal resources, for which the personnel reserve is formed.
In its work, the personnel and remuneration committee, when planning continuity, takes into account the results of a regular assessment of the activities of each of the members of the Board, taking into account the results of the work of the entire bank as a whole.
5.3. President, Chairman of the Board President, Chairman of the Board of the Bank Heads the Board and manages his work, carries out the Bank's operational leadership, ensures the implementation of NA and OSA decisions, organizes the work of the Board, distributes the responsibilities between members of the Board, presides on the meetings of the Board.
The President, the Chairman of the Board is responsible for organizing the training system and the accuracy of the Bank's accounting (financial) reporting, timely disclosure and provision of shareholders, bank customers and other interested parties on the Bank's activities.
5.4. Distribution of powers and interaction of the Supervisory Board and Executive Bodies of Sberbank Effective interaction between the Supervisory Board and the executive bodies, as well as a clear distinction between their powers is one of the key factors in ensuring the proper practitioner of corporate governance. Supervisory Board, Board and President, Chairman of the Board in their work are endowed with a sufficient degree of independence.
The Supervisory Board should not be able to interfere in the daily activities of the executive bodies, limiting their ability to quickly solve the issues of the Bank's activities. At the same time, the executive bodies of the Bank on a regular basis inform the Supervisory Board on all important issues and decisions that are important to implement the Bank's Development Strategy, planning and business development, the status of risk management and internal control systems. To achieve an optimal level of such interaction, the President, the Chairman of the Board is part of the Supervisory Board of the Bank.
In order to fully explore the specifics of the Bank's activities, NA members can organize working meetings with members of executive bodies and other key employees of the Bank, and any issues of future development and current activities of the Bank can be organized on their own initiative.
Members of the NA interact with the executive bodies and officials of the Bank in order to prepare the most complete and reliable information necessary for decision-making.
For proper execution of their duties, a member of the Supervisory Board has the right to:
request information about the activities of the Bank and promptly receive answers to your requests;
require additional information;
equally, to have the right to access the bank documents and the companies controlled.
5.5. Corporate secretary for the purpose of ensuring compliance with the management bodies and officials of the Bank's corporate governance procedures, the requirements of the current legislation, the Charter, this Code and the Bank's internal documents that guarantee the implementation of the rights and legitimate interests of shareholders, the Bank provides for the position of the corporate secretary.
The Corporate Secretary is appointed by the decision by the Supervisory Board, it is reported and controlled in its activities and is in the administrative submission of the President, Chairman of the Board of the Bank. The activities of the Corporate Secretary are governed by the Regulations on the Corporate Secretary, approved by the Supervisory Board of the Bank.
The main task of the Corporate Secretary is to ensure the implementation of the Bank's Policy in the field of corporate governance, as well as coordination of actions in the implementation of corporate governance processes and improving them, implying the implementation of the functions of methodology, control and monitoring the compliance of individual processes of such policies.
The Bank takes the necessary measures to ensure the independence of the Corporate Secretary, creates the conditions for the unhindered and effective implementation of the corporate secretary of its functions.
5.6. Motivation and remuneration of members of the Supervisory Board and Management of Sberbank The basic principles underlying the reward system currently operating in the Bank's bank are its transparency, openness and compliance of the sizes of individual remuneration to the results achieved, as well as the nature and scale of operations committed by the Bank, the results of its activities, level and Combination of risks.
We are improving the motivation system and create in its framework the mechanisms of long-term motivation, taking into account risks, also for key leaders of the Bank.
Remuneration of members of the Supervisory Board The remuneration of members of the Supervisory Board must comply market conditions And the OSA is established in such a way as to ensure attracting and active participation in the Bank of highly qualified specialists, to motivate them to honest and efficient activities. The Bank publicly reveals information on the remuneration of members of the NA in accordance with the Regulations on remuneration and compensation for members of the Supervisory Board.
In his approach to the issue of motivating members of the Supervisory Board, the Bank seeks to take into account the level of overall responsibility, individual load and professional qualifications of each of the members of the Supervisory Board.
Remuneration Members of the Board The presidential remuneration system, the Chairman of the Board and Members of the Board is determined by the Right Policy and Motivation of Key Employees of the Bank. Remuneration consists of fixed and variable parts.
Our basic principle is the desire to maximize the interests of the Bank's leaders and its shareholders. This is achieved due to the strict connection of the size of the variable part of the remuneration with the specific results of each member of the Board.
The personnel and remuneration committee is responsible for adequacy and continued actualization of the reward system of members of the Board, coordinates a set of personal targets and controls the success of their implementation by analyzing the personal contribution of each manager, its development potential and the degree of synergistic effect in the team.
The disclosure of information on remuneration We are responsible to the issue of disclosing information on the remuneration of top managers of the bank. Information on each collegial control agency of the Bank, indicating the size of all types of remuneration, including wages, premiums, commission, remuneration, separately paid for the participation in the work of the relevant authority, other types of remuneration, which were paid by the Bank during the reporting year, indicating the amount of expenses related to the execution of the functions of members of the Bank's management bodies compensated by the Joint-Stock Company during the reporting years are published in the annual report of the Bank.
5.7. Insurance of the responsibility of members of the Supervisory Board and Board Given that the Bank's management is a complex process associated with the risk that decisions taken by members of the Bank's management bodies may be incorrect and entrusted negative consequences for the bank, the responsibility of members of the Bank's management bodies is subject to insurance.
Insurance of the responsibility of members of the Bank's management bodies, as well as officials hosting key management decisions, are made at the expense of the Bank.
6. Corporate behavior and business ethics
6.1. Compliance with the principles of business ethics and anti-corruption, we are confident that unconditional following the ethical principles enshrined in the internal documents of the Bank, all members of the Office laid focused on ethical principles with the basis of corporate culture, helps to strengthen the business reputation of the Bank, the development of business cooperation with clients and partners Bank.
All members of the Contracts are obliged to act in accordance with the high principles of professional and business ethics, enshrined in the Bank's internal documents, be intolerable to corruption in any formas and manifestations, comply with the requirements of applicable laws in all countries of business and / or public circulation of securities of the bank , regularly undergo training on ethics and anti-corruption.
In more detail, the principles of prevention and anti-corruption, established in the bank, are also set forth in corruption policies.
6.2. Policies regarding potential and existing conflicts of interest members of the Office, acting reasonably and conscientiously in the interests of the Bank and its shareholders, must report on the availability or conflict of interest in making decisions, resolve the conflicts that have arisen in the interests of the Bank and its shareholders, including refrain from actions that will lead or potentially be able to cause conflict of interest, refrain from voting on issues, in making decisions on which they have a personal interest. Under the conflict of interest, we understand the situation in which a member of the management body has a personal interest in making a decision, actions or abstaining from actions as a member of the Bank's management authority, which can cause damage to the interests of the Bank or its shareholders. In the event of a conflict of interests, even potential, including in the presence of interest in the Bank's transaction, a member of the Supervisory Board should notify the Supervisory Board through his chairman or corporate secretary. If a member of the Supervisory Board is not obvious, whether the conflict of interest is creating a conflict of interest, he should consult a corporate secretary to take appropriate measures.
The members of the Supervisory Board are obliged to notify the Chairman and the Corporate Secretary in a timely manner as an intention to take a position as part of the authorities of other organizations and / or state and municipal bodies, the Bank of Russia and the fact of this purpose.
Combining members of executive bodies in other organizations requires the approval of the NA in accordance with the legislation of the Russian Federation.
In order to prevent possible negative consequences for the Bank, members of the executive bodies disclose information about the implementation of commercial activities that are not related to the interests of the bank.
In more detail, the principles of prevention and timely conflict management of interests established in the Bank are set out, including in politics in conflict management.
6.3. Confidential and Insider Information Policy The members of the Supervisory Board and the executive bodies are not disclosed and do not use confidential, insider and official information of the bank for personal purposes.
The disclosure of information about the bank, its volume, the content and methods of distribution should not contradict the requirements for compliance with the law of banking, commercial secrets, other confidential information, as well as the requirements of the Bank's information security.
All members of the governing bodies are obliged to act in accordance with the requirements of the Bank's internal documents in the field of countering the unlawful use of insider information and the market manipulation, comply with the restrictions on insider information and responsibilities towards the notifications of operations performed.
7. Internal control and risk management systems, an external auditor internal control system - a set of a system of body and internal control directions, ensuring compliance with the procedure for implementing and achieving the objectives established by the legislation of the Russian Federation, constituent and internal documents of the Bank.
The Supervisory Board is responsible for the definition of principles and approaches to the organization of internal control systems and risk management in the bank.
Executive bodies provide the creation and maintenance of effective internal control systems and risk management systems, and are also responsible for the implementation of the decision-making of the Supervisory Board in these areas.
Building internal control and risk management systems in a bank is carried out using the "Three Protection Lines" model, at which:
The first line is the divisions that are responsible for the daily effective implementation of internal control, take current risk management measures related to their activities. These measures are part of the daily activities of the divisions, therefore, the permanent process of identifying, evaluating and controlling risks is ensured;
The second line is the responsible divisions of the Bank, which are responsible for developing and enforcing the rules and procedures of internal control, determine the risk management standards, principles, limits and restrictions, monitor the level of risks, form reporting, check the risk compliance with the risk of appetite to risk, consult , simulate and aggregate a common risk profile;
The third line is an internal audit whose tasks is an independent assessment of the effectiveness of internal control systems and risk management systems.
7.1. Internal Control System Structure
Internal control in the bank is carried out:
Bank management bodies;
Audit committee;
Chief Accountant (his deputies) of the Bank;
Leaders (their deputies) and chief accountants (their deputies) branches of the bank;
Internal audit service;
Internal control service;
Structural unit (responsible employee) on countering the legalization (laundering) of income obtained by criminal means and financing terrorism;
Controller of the professional participant in the securities market;
Other divisions and employees carrying out internal controls in accordance with the powers defined by the Bank's internal documents.
7.2. The organization of the risk management process used by the Bank The risk management system is based on standards and tools recommended by the Basel Committee on Banking Supervision, and meets the requirements of the best global practices. The main tasks of the integrated risk management system, as an integral part of the Bank Management Process, is the introduction of risk management standards, principles, limits and restrictions, monitoring risk levels and risk reporting, ensuring compliance of the risk-based risks established by risk, modeling and formation of the general Risk profile. In order to ensure effective planning and control of accepted risks, risk management functions are distributed among the Supervisory Board, the Chairman of the Board, the Bank's President, the Board, the Curator of the Risky block (the head of the Bank's Risk Management Service), specialized committees of the Board, Risky Block and Other Bank divisions and participating organizations. The distribution of powers in the risk management system complies with the requirements and recommendations of the Bank of Russia and international financial organizations.
7.3. Internal control service for the implementation of internal control, promoting the Bank's management bodies in ensuring compliance with the Bank's activities to legislation, regulation and best practices, as well as the creation and application of effective methods and mechanisms for managing the risk of occurrence of damages due to non-compliance with the legislation of the Russian Federation, internal documents Bank, standards of self-regulatory organizations and / or application of sanctions and / or other measures of impact on the part of the supervisory authorities, an internal control service has been created in the Bank, which includes a combination of structural divisions and employees of the Bank engaged in accordance with the Regulations on the internal control service.
The internal control service is valid in accordance with the principles of independence, the constancy of activities, objectivity, impartiality and professional competence.
When implementing internal control and performance of its functions, the internal control service interacts with all divisions, collegial and executive bodies of the Bank on issues in their competence.
7.4. The internal audit service of the Internal Audit Service promotes the Bank's Office to achieve the goals, ensuring the effectiveness and effectiveness of the Bank's activities and operates in compliance with the principles of the constancy of activities, independence, impartiality, honesty, objectivity and professional competence. The internal audit service is an independent structural unit that carries out inspection measures throughout the system of functioning of internal control, accountable to the Supervisory Board of the Bank and administratively subordinated to the President, Chairman of the Board of the Bank.
The Bank takes the necessary measures to ensure independence and impartiality of the internal audit service, creates conditions for the unimpeded and effective implementation by the internal audit service of its functions.
The internal audit service conducts inspections in all areas of the Bank's activities (an object of inspections may be any division and employee of the Bank or the organization of the Member of the Group), monitors the effectiveness of the units adopted and authorities on the results of verification tests that reduce the level of revealed risks.
In its work, the internal audit service applies the best practices in the field of internal audit, including the international bases of the professional practice of internal audit.
7.5. External auditor for the purpose of checking and confirming the accuracy of financial (accounting) reporting prepared as Russian and international standards, we attract an independent audit organization with world recognition.
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Code of Corporate Ethics
PJSC "Baltic Bank"
St. Petersburg
Article 1.
Objectives and objectives of corporate ethics code
1.1. The purpose of the Corporate Ethics Code (hereinafter - the "Code") is to determine the standards of the Baltic Bank PJSC (hereinafter - "Bank") and the behavior of its employees aimed at maintaining ethical standards, quality of service and convenience for customers, improving the efficiency of activities, financial The stability of the bank and contributing to the increase in demand for employees of the Bank and employees of the bank to themselves.
1.2. The tasks of this Code are:
· Consolidation of the mission and corporate values \u200b\u200bof the bank;
· Providing awareness by the Bank's employees, members of the Board, members of the Board of Directors of the Bank of Personal Responsibility to Clients, Business Partners, Bank shareholders and colleagues to fulfill their official duties, their role in the implementation of the Bank's Mission;
12.8. Bank employee, member of the Board, member of the Board of Directors of the Bank excludes any activity that may cause damage to business reputation, other intangible and material interests of the bank, client, business partners.
12.9. An employee of the Bank may inform the direct supervisor to the relevant structural unit, a member of the Board - the Chairman of the Board of the Bank on the planned, current or implemented actions both inside and outside the bank from other employees of the Bank, members of the Board, Board of Directors, Customers, Business Partners, Violating Generally accepted principles and norms of international law, the provisions of the legislation of the Russian Federation, this Code (in cases provided for by the provisions of this Code) or other internal documents of the Bank.
For the purposes of this Code under the bank employee means any individualThe employment contract or other civil contract with the Bank, which provides for a personal implementation of a specific function (work on a particular specialty, qualifications or position).
The emergence of a conflict situation within a labor collective, factors such as ignorance or intentional ignoring the norms of current labor legislation may be promoted, attempts to get rid of disagreeable employees, insufficient motivation, an unjust labor assessment, lack of professional competence of managers, the psychological incompatibility of employees, unjustified protectionism and preferences in relation to individual employees (including due to related links), etc.
The formation of a single team is impossible without a sense of emotional involvement. Sberbank makes the maximum efforts to form a corporate culture that would correspond to the values \u200b\u200bof the bank, on the one hand, would be comfortable for the development of professional skills and the implementation of employees' ambitions, on the other. The most important task is to form a single communications space. Employees of all divisions of the bank should feel their unity and involvement in the general case.
The generally accepted values \u200b\u200band norms of Sberbank are reflected in the Corporate Ethics Code, which regulates the rules of conduct, mandatory for all employees of the bank. To familiarize themselves with these rules, each employee, when admission to work, signs the "Declaration on agreement with the ethical norms of Sberbank of Russia". To adapt new employees a set of activities designed to facilitate the process of entering the position and adaptation to new corporate culture. Created a "newcomer book", which is an interactive media, which contains all the basic information necessary for new employees. Some territorial banks host special training programs for beginners. In addition, there is a practice of consolidation during the period of passing the test period of personal mentors from among colleagues with long experience in the bank.
The main tool internal communications is an intranet portal that contains a special heading on the PSS, sections of structural divisions and territorial banks, internal regulatory and information documents. The internal portal is the most important feedback channel from employees to the bank management. We plan to further develop the portal, including in the direction of creating virtual work offices.
On the local network, employees receive a special newsletter "Good morning, Sberbank" special newsletter, and once a week - Bulletin "Sberbank. Day after day, "which includes a brief overview of the key events of the bank over the past week. Among other internal communications tools are the monthly newspaper "My Sberbank" and information boards. The bank has an open telephone line for employee appeals.
Monthly Bank staff receives the appeal of the president to which you can answer counter comments and suggestions. According to the results of feedback, reports are preparing reports that are sent to the Bank's management to familiarize themselves. There is also the opportunity to write a letter addressed to the president, and in 2010 G.O. Gref spent in video conference mode the first "hotline" with employees.
Not all employees have regular access to the intranet portal and email, this problem is especially serious for territories distant from major cities, as well as small internal structural divisions of the bank. In this regard, Sberbank is focused on using a wide range of communicative tools. So, in the plans of the bank, restoring the internal corporate newspaper as a printed publication and the release of an updated corporate journal.
In 2010, the Bank conducted a study of personnel satisfaction with the number and quality of corporate communications channels. Its results will allow us to choose the communications channels correctly depending on the topic of messages and the target audience.
Sberbank regularly organized a variety of corporate holidays. Such events make it possible to support corporate spirit and traditions, create an atmosphere of confidence and mutual understanding within the bank, strengthen informal communications in the team, to increase the loyalty of employees, to create a sense of involvement in a common goal. Traditionally, the celebration of March 8, the New Year, the Day of the Sberbank employee, the Victory Day. Children's holidays, children's health recreation are also organized annually, children's drawing contests are being organized.
The corporate culture of Sberbank is strong enough. The main values \u200b\u200bof the organization are intensively supported, clearly defined and widely distributed. It has the ultimate clarity of priorities, management informs workers about the tasks of the enterprise, they actively involve them in solving these tasks. The organizational culture of the bank is focused on a personal approach and, at the same time, unites employees into a single whole.
