Description of the Information Policy
The information policy was developed with the aim of improving the quality of corporate governance, ensuring compliance with legislation, local legal acts of JSC Belagroprombank (hereinafter referred to as the bank), ethical standards (rules), preventing corruption, fraudulent and other illegal actions, taking appropriate measures when identifying a conflict of interest and (or) the conditions for its occurrence and establishes a general procedure for informing.
High-quality implementation of the Information Policy is aimed at organizing an appropriate internal control system, timely identification and prevention of cases of involvement of employees (including managers of all levels) of the bank, employees, managers and founders (participants, property owners) of participating organizations of the bank holding company in committing illegal and (or) unethical actions.
In accordance with the Information Policy, employees and managers of all levels of the bank, participating organizations of the bank holding company, clients or other persons are provided with the opportunity to unhindered and promptly inform (including with the mandatory possibility of anonymity) about the committing of illegal and (or) unethical actions in the bank’s and bank holding company’s activities via the following notification channels operating in the bank:
- appeals from citizens, legal entities in electronic or written form, including comments and (or) suggestions included in the books of comments and suggestions;
- personal reception of citizens, their representatives, representatives of legal entities;
- direct telephone lines conducted by the chairman of the bank's board, the first deputy chairman of the bank's board, and deputy chairmen of the bank's board;
- “Hotline” for bank employees;
- informing the official responsible for internal control in the bank (the person replacing him);
- electronic communication channels of the bank (section “Feedback” on the bank’s website, corporate email, social networks, video hosting, information portals and search networks on the global computer network Internet) ;
- direct informing of the chairman of the audit committee created by the bank's supervisory board (if the actions are related to the activities of the head of the bank, the official responsible for internal control in the bank, managers and founders (participants, property owners) of participating organizations of the bank holding company) .
Information about facts of illegal and (or) unethical actions received on notification channels and (or) to authorized persons (bodies) of the bank at any level and which became known as part of the ongoing proceedings is confidential and is not subject to disclosure, except as required by law.
Summary information on the implementation of the Information Policy is presented for consideration by the audit committee and the bank's supervisory board, while:
- the audit committee monitors the implementation of measures in the bank taken in response to reports of illegal and (or) unethical actions of employees and other violations;
- the bank's supervisory board considers issues related to the implementation of the Information Policy, including giving instructions to the bank's board to eliminate identified violations.
