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CORPORATE ETHICS CODE FOR
SBERBANK OF RUSSIA EMPLOYEES
TABLE OF CONTENTS
President’s Address
2
Introduction
3
Our Bank – Sberbank of Russia
3
Bank’s Values
4
Standards and Rules of Conduct of Bank Employees
8
Prevention of a Conflict of Interest
10
Corporate Social Responsibility
13
Code Compliance
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7 Kazanskaya St., Board of Trustees Building, St. Petersburg
The St. Petersburg Savings Bank occupied this building from 1842 to 1917.
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Dear Colleagues,
This is the Corporate Ethics Code for Sberbank of Russia Employees. It is a set
of rules describing the standards of our conduct, our commitments and
responsibility towards the bank, society, our customers and each other.
It would not be an exaggeration to say that we are working in a special and
unique bank. The role it has played throughout its history for the country’s
economy cannot be underestimated. One way or another, we owe our successes
to the many-thousand-strong team of our bank, operating in various regions of
our homeland that has always been like a big family, a community of fellow
thinkers united by common ideas, corporate values and moral principles. The
Code sets forth these underlying principles and shows how personal pursuit of
successful work and career should yield to the interests of the bank, its
customers and our country.
Today, Sberbank of Russia is an acknowledged leader of the Russian banking
system and is ranked high in the world ratings. I am sure the Corporate Ethics
Code will help us to maintain and strengthen the standing of our bank and be an
example of reliable and professional work.
CEO, Chairman of the Management Board, Sberbank of Russia
A. I. Kazmin
/Signature/
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• INTRODUCTION
The purpose of the Corporate Ethics Code for Sberbank of Russia Employee
(the “Code”) is to set out the Bank’s corporate values, ethical standards and
rules of conduct of Sberbank of Russia (the “Bank”) employees, to ensure they
are aware of their roles in implementing the Bank’s mission in respect of its
customers, shareholders and business partners.
The Code contains standards and rules of conduct for Sberbank employees,
which are based on the values adopted by the Bank and comply with the Bank’s
mission and philosophy.
The provisions of the Code apply to all employees of the Bank, regardless of
their position, professional activity or location of the Bank's division or branch.
Each employee undertakes to comply with this Code.
• OUR BANK – SBERBANK OF RUSSIA
Sberbank of Russia is a leader of the Russian banking system and the basis
of its stability and reliability. The Bank’s presence in all the sectors of the
banking market makes it an alternative to any other bank operating in Russia and
ensures the functioning of the country's banking system in any conditions.
Sberbank of Russia is a bank on a national scale. The Bank takes part in
shaping economic policy, influences the macroeconomic processes of the
country, and implements economically efficient projects and programs of
development. The Bank’s extensive branch network and the use of advanced
technologies are designed to ensure the availability of the Bank's services
anywhere in the country.
Sberbank of Russia represents the Russian banking system on the
international market. The Bank has partner relations with leading foreign
banks and credit institutions, and takes part in international banking conventions
and forums.
Sberbank of Russia is a universal commercial bank. The Bank strives to
satisfy the needs of all its customers for a wide range of services and to a high
standard. The Bank aims to deposit funds raised from private and corporate
customers in an efficient manner for the benefit of the Bank's customers and
shareholders.
Sberbank of Russia is a socially significant bank. Being the only banking
institution offering services throughout the Russian Federation, the Bank plays
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an active role in implementing social programs, provides support for the
development of national culture, science, education and healthcare.
The mission of Sberbank of Russia is to meet the need of its every customer
throughout Russia with banking services of the highest quality and reliability, to
ensure stable functioning of the Russian banking system, the saving of customer
deposits and their investment in the real sector, thus, contributing to
development of the Russian economy.
• THE BANK’S VALUES
The Bank’s Corporate Values
•
The Bank pursues the highest customer service standards and strives to
improve banking products and services.
•
The Bank meets the laws, ethical standards and rules of fair business,
unconditionally fulfills its obligations and values its reputation.
•
The Bank adheres to the principle of neutrality in respect of financial and
industrial groups, political parties and associations, and conducts its
business in the interests of its customers and shareholders.
•
The Bank does not finance environmentally harmful or socially hazardous
production, projects or programs.
•
The Bank factors in the social significance of its activities and considers the
social factor along with the economic one.
•
The Bank develops new types of operations and business areas, following
the principles of reasonable conservatism.
•
The Bank values its employees, creates conditions in which each of them
has an opportunity to realize their abilities in full, and cares for veterans.
•
The Bank honors the traditions of Russian entrepreneurship and contributes
to their revival, conservation and development.
Bank Customers
Among its customers, the Bank sees all citizens of the country, organizations,
companies of any form of incorporation, credit institutions, other financial
institutions, executive governmental authorities, and sole traders.
The Bank aims to establish long-term partner relations with every customer.
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The Bank excludes any political, religious, national, age or gender
discrimination of its customers.
The Bank offers a wide range of bank products and services and conscientiously
fulfills its obligations.
The Bank seeks to ensure a high quality of customer services in accordance with
international standards.
The Bank guarantees confidentiality of information related to its customers.
Such information may be used only for the purposes stipulated by the applicable
laws and the Bank’s internal documents.
Bank Shareholders
The Bank’s corporate conduct practice is intended to ensure that its shareholders
are treated equally.
The shareholders define the main principles of the Bank's business development.
The Bank is responsible to its shareholders for ensuring the growth of the
Bank’s assets, its profitability and implementing the standards and traditions of
Russian corporate business conduct, compliant with internationally accepted
standards in the Bank's daily practice.
The shareholders have the right to regular, full and timely receipt of reliable
information about the Bank and its performance.
The Bank is interested to have its strategic partners and customers, who consider
shareholding as part of a long-term cooperation program, among its shareholders.
The Bank welcomes the desire of its employees to hold the Bank’s shares and
thus to participate both in its management and profit distribution.
Bank Employees
The Bank values and respects its employees. The employees are the Bank’s
main asset.
The Bank builds its relations with employees based on principles of long-term
cooperation, mutual respect and unconditional performance of mutual
obligations.
The Bank strives to ensure that each employee shows respect for the Bank’s
traditions and history and is genuinely proud that he or she works for Sberbank
of Russia.
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In its employees, the Bank values honesty, integrity, professionalism, orderliness,
inner culture, self-discipline, and being result-oriented.
The Bank adheres to the principle of tolerance of any ideological, personal or
physiological differences of its employees. Any individual peculiarities of a
person not having a negative impact on the quality of his or her work may not be
grounds for any restrictions in respect of such employee.
The Bank maintains a balance between personal interests of its employees and
the Bank’s interests: encourages professional and personal development and
cares for the health and welfare of its employees and their family members.
The Bank creates conditions enabling each employee to realize their creativity,
be able to improve their professional knowledge, and have good prospects of
career advancement.
The Bank views increasing the level of independence and responsibility of its
employees as a material factor of personnel quality improvement.
The Bank welcomes the development by its employees of the following qualities:
•
Goal orientation
•
Customer orientation
•
Compliance with corporate rules
•
Innovation
•
Professionalism
•
Teamwork skills.
Single Team
The Bank is a multi-national team united by the idea of high-quality customer
services, improvement of the Bank's image, and strengthening of its business
reputation and status.
The Bank’s goals are attained by combining the efforts of all the Bank
employees and creating a cohesive and highly professional team of fellow
thinkers, able to respond adequately to the changing market requirements and
challenges.
The Bank is focused on maintaining the stability of its teams and the succession
of personnel professional experience.
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The Bank arranges interaction between all employees based on common values,
and ensures the functional integration of all Bank divisions.
Each employee of the Bank contributes to the work of his or her team and is
responsible for its result. Each employee should be aware that the work
performed by the employees of different divisions all serves the common
objective.
High Reputation and Reliability
The Bank values and strengthens its reputation ensuring compliance with all
obligations in its relations with customers, employees and shareholders.
The Bank declares its commitment to the principles of fair competition and the
counteraction of the legalization (laundering) of the proceeds of crime.
The Bank is responsible for the correctness and validity of its marketing and
advertising campaigns.
The Bank builds relations with its competitors based on principles of integrity
and mutual respect.
The Bank’s business reputation is characterized by reliability, stability and
success.
Reliability is the basis of the reputation of the most popular Bank that attracts
and retains customers.
The Bank’s stability, profitability and management efficiency are benchmarks
for our customers, partners and shareholders.
• STANDARDS AND RULES OF CONDUCT OF
BANK EMPLOYEES
Ethical Conduct Standards
The Bank treats all its employees and business partners with respect and good
will. This is a fundamental issue.
The conduct of each employee gives the Bank’s business partners and customers
a general idea of the Bank and has an immediate effect on their desire to
cooperate with it.
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Each employee strives to perform their duties to the fullest extent and with
maximum responsibility, contributing to the attainment of the Bank's single
goals. When performing their job duties, employees of the bank should aim to
find the best solution, combining low cost and high efficiency.
It is important for the Bank to develop an atmosphere of cooperation among the
Bank’s personnel. The Bank does not promote competitive relations between its
subdivisions or branches, but welcomes a competitive spirit among its
employees as an impetus to personal growth and professional development of
each employee and enhancement of the Bank’s overall performance.
Personal communication of the Bank’s employees during business hours shall be
in accordance with generally accepted standards of business ethics.
The Bank encourages a healthy lifestyle of its employees.
The Bank employees are prohibited from:
•
Using any material or intellectual resources of the Bank for their own needs
•
Saying or doing something detrimental to the Bank
•
Using narcotics
•
Drinking alcohol at their work place and/or within the Bank territory.
Drinking alcohol is only allowed on holidays and other special events and
is restricted by the standards of business ethics
•
Visiting gaming establishments that practice gambling and/or accept bets
(casinos, sweepstakes, bookmaker’s offices, slot machine halls and other
gambling houses or venues)
•
Smoking within the Bank’s territory except for specially designated areas.
The Bank has a business dress code. The Bank employees shall wear neat and
modest clothes.
The Bank promotes the development an atmosphere of trust among its teams in
which any ethical problems can be discussed.
Each employee shall resist any deviations from the standards of corporate
conduct of the Bank employees.
Following high ethical standards and upholding the Bank's reputation are one of
the main objectives of each employee.
Relations with the Bank’s Customers
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The relations of employees with the Bank’s customers are based on amiability
and a desire to provide customers with maximum services and high professional
service competence.
The employees may service customers only within the scope of orders given by
customers and contractual obligations.
The employees shall not create such service conditions for a customer that will
impair the Bank’s interests or prejudice the rights of other customers.
The Bank employees are not allowed to receive money or costly presents from
customers, provide or receive services with the purpose of influencing decisions.
• PREVENTION OF A CONFLICT OF INTEREST
The Bank and its employees try to avoid situations giving rise to a conflict of
interest.
Restrictions on the participation of the Bank’s employees in operations
(transactions) with an organization in respect of which such employees may be
recognized as interested parties are established under the laws of the Russian
Federation.
An employee shall abstain from any activity if such activity contradicts the
Bank's interests or may cause doubts as to the reputation and reliability of the
Bank.
In the event of a potential conflict of interest, the employee shall bring such
details to the notice of his or her immediate supervisor, the internal control
service, and, where necessary, the security service of the Bank that will advise
the employee on his or her actions under the circumstances.
If a conflict of interest cannot be eliminated for objective reasons, the interests
of the Bank's customers shall prevail, unless it is in conflict with the laws and
the Bank’s internal regulatory documents. In the event of a conflict of interest
between an employee and the Bank, the Bank’s interests shall prevail.
Employment outside the Bank
Recognizing the right of its employees to engage in other professional activities
outside the Bank, the Bank does not approve the part-time employment and
employment under civil agreements with other commercial organizations (save
for teaching and research activities).
In case of employment outside the Bank, the Bank employees shall:
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•
Notify their immediate supervisor and the head of the Bank’s (branch’s)
HR department of such other employment
•
Engage in other labor activity only out of working hours, subject to the
requirements of this Code, except to the extent provided for by applicable
laws
•
Make sure that such other employment does not affect the performance of
their primary duties or impair the Bank's image or interests
•
Comply with confidentiality restrictions in respect of insider information as
set forth by the Bank’s regulatory documents.
The Bank employees shall not hold full-time management positions with
organizations, save where a resolution on holding a concurrent full-time
management position with an organization is passed by the executive authorities
of the Bank’s (branch’s) management board to implement a program for
financial rehabilitation of the organization, for the period of the liquidation
commission, bankruptcy of the organization or the taking of other measures.
The employees may not engage in any activities, whether directly or indirectly,
that may, as a competitive action, cause damage to the Bank.
Participation of the Bank employees in other organizations is subject to written
obligations assumed towards the Bank.
Participation of employees in political, religious and public organizations
The Bank does not restrict the participation of its employees in any political,
religious or public organizations beyond working hours.
Religious and political preferences are a matter of personal opinion of
employees and shall not prevent them from performing their job duties or
communicating with colleagues.
The Bank’s employees taking part in political, religious and public activities
shall in this case act as private individuals only and not as the Bank’s
representatives.
No agitation of employees for the benefit of any political party or candidate or
distribution by employees of their religious beliefs or views is permitted within
the territory of the Bank.
Employees shall not perform political, religious or public activities using the
Bank's resources, image or reputation to that end.
Information Transparency and Confidentiality Compliance
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The Bank establishes the procedure, forms and ways of providing official
information subject to the applicable laws, the nature of information provided
and the needs of interested parties.
The Bank keeps official information on its employees, including personal
information and information on personal income, confidential. The Bank ensures
the confidentiality of such information, except to the extent provided for by the
applicable laws.
Employees may not use illegally restricted official information, including when
making transactions beyond their job duties and/or upon a conflict of interest.
To protect customers’ interests, employees shall observe information barriers
between divisions when carrying out financial activities in accordance with the
Bank's internal regulations.
The Bank restricts the number of persons entitled to communicate with mass
media on behalf of the Bank. Only authorized persons may make comments on
the Bank’s activities for mass media and other sources.
An employee shall not question the Bank's activities or actions of his or her
colleagues using mass media.
Employees shall be held personally liable for the content of information they
publish about the Bank in public Internet resources.
The employees who change their employment shall keep the Bank's restricted
official information in confidence in accordance with their previous written
obligations.
The Bank does not require that its employees disclose confidential information
accessed by them when working for other companies (organizations).
In the event of intentional or negligent disclosure by a Bank employee of any
information treated as a commercial secret, that was made available to him/her
for the performance of his/her job duties, the Bank reserves the right to impose
measures provided for by applicable laws.
• CORPORATE SOCIAL RESPONSIBILITY
The Bank’s social responsibility to society involves:
•
Providing quality services to each customer
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•
Creating work places, paying legal salaries and investing in the
development of human capital
•
Strict legal compliance
•
Taking into account public expectations and generally accepted ethical
standards in its business practice
•
Efficient conduct of business, including subject to the interests of the least
socially protected social groups
•
Contributing to the formation of a civil society through partner programs
and local community development projects.
The Bank’s social mission is implemented by pursuing an interest-rate policy on
private deposits, factoring in the interests of the least protected social groups, by
maintaining private customer service outlets unprofitable for the Bank where
they are the only bank institutions, and in certain cases by performing bank
operations free of charge.
For the Bank, socially significant business involves not only charitable and
sponsorship campaigns, but also the creation of a sustainable business
environment and active interaction with society, which contributes to the
stabilization of the economy and improvement of quality of life.
The Bank plays a significant role in providing financial services to the public
and demonstrates ways of solving social problems to the rest of the business
community.
The general approach to forming and implementing internal corporate social
programs is focused on enhancing the consolidation of the Bank’s teams united
by a single production process and preserving the basic values inherent in the
Bank.
The Bank views the level of social security of its employees as an important
element of its image distinguishing the Bank among its competitors by
economic efficiency, internal stability and the status of its employees.
• CODE COMPLIANCE
The Bank employees shall comply with this Code.
If an employee has any questions as to the correctness of his or her conduct in
any situations covered by this Code, and if he or she has reasonable suspicions
that any of his/her actions or omissions may lead to a violation of the Bank's
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ethical standards or give rise to a conflict of interest, such employee shall apply
to one of the following instances:
•
The employee's immediate supervisor
•
HR Department (Unit)
•
Internal Control, Inspection and Audit Department (Unit)
•
Legal Department (Unit)
•
Security Department (Unit)
•
Line manager.
Employees shall display a spirit of cooperation in any investigations concerning
bank ethics violations. No employee may be persecuted for pursuing the Bank's
ethical standards or his/her reasonable demands that these standards be observed
by other employees.
The Bank is confident that unconditional compliance by all employees with this
Code improves the Bank's performance, maintains and strengthens its image and
reputation and contributes to the development of strong business relations with
its customers, partners and shareholders.
Each employee shall be personally responsible for ensuring that their relations
with customers, colleagues, shareholders and the public contribute to the Bank’s
leadership, dynamic growth and higher quality of the services provided.
The Code is compliant with the Bank's current internal regulatory documents
(Sberbank of Russia Development Concept, Sberbank of Russia Corporate
Management Code, Regulations on Participation of Sberbank of Russia in Other
Organizations, Regulation on Commercial Secret of Sberbank of Russia, and
others).
Each employee shall have a personal copy of this Code.
The text of this Code and all subsequent amendments hereto will be published
on the corporate website of Sberbank of Russia.
Each employee shall read the Code and sign the Declaration of Consent with the
Ethical Standards of Sberbank of Russia. The signed copy of the Declaration
shall be stored in the employee’s personal file.
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Employee’s ignorance of the provisions of this Code or refusal to sign the
Declaration shall not relieve such employee from his/her obligation to comply
with the corporate standards and rules of conduct approved by the Bank.
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