Description of the policy on exclusion of conflict of interests and conditions of its occurrence
In order to improve corporate governance and ensure the financial reliability and ability of a bank holding company to exist long-term as a profitable financial organization, JSC Belagroprombank (hereinafter referred to as the bank) has implemented a systematic approach to managing conflicts of interest and developed a Conflict of Interest Management Policy (hereinafter referred to as the Policy).
A conflict of interest is understood as a contradiction between the property and other interests of the bank and its shareholders (beneficial owners and other owners), management bodies and their members, organizations of a banking group, a banking holding company, the parent organization of which is the bank, divisions, employees, clients (counterparties), which may entail negative consequences for the bank and (or) its clients (counterparties).
One of the main tasks of corporate governance is to organize the management of conflicts of interest in the bank’s activities, including a set of measures to identify and eliminate conflicts of interest, as well as the conditions for its occurrence.
Conflict of interest management objectives:
- improvement of corporate governance;
- counteraction to corruption;
- complete and timely identification of existing and potential areas and (or) conditions for the conflicts of interest occurrence.
- Conflicts of interest are managed in the bank by taking the following measures:
- ensuring transparency of corporate governance of the bank;
- creation of an effective internal control system, risk management system, internal audit system and remuneration and compensation system;
- ensuring the bank treats its clients and counterparties fairly in the framework of their consultation, provision of services or transactions with them or on their behalf (excluding preference for the interests of one client (counterparty) over the interests of another client (counterparty), preference for the interests of an employee over the interests of a client (counterparty) , including with the personal interest of the employee);
- establishing the priority of collective decision-making over individual decision-making, including the introduction of the practice of dual control (compliance with the “four eyes” principle);
- minimizing the facts of decision-making on individual conditions provided for banking operations and other activities;
- ensuring the exclusion of conflict of interest and the conditions for its occurrence when appointing persons accountable to the bank’s supervisory board to positions;
- excluding the possibility of bank officials, members of its management bodies, and employees receiving material and (or) personal benefits when performing their official duties personally or through third parties;
- avoiding inaction, refraining from actions (decision making) that may lead to a conflict of interest;
- timely response to cases of negative or unreliable information in the media and other sources, carrying out investigations of these cases.
Measures aimed at identifying and eliminating conflicts of interest are not exhaustive. In each specific case, other measures may be used to resolve conflicts of interest.
The bank's audit committee analyzes and evaluates the implementation of the Policy in the bank, develops proposals and recommendations for resolving the identified conflict of interest, the conditions for its occurrence based on information provided by the official responsible for internal control in the bank, as part of management reporting.
The bank's Supervisory Board reviews information on the results of analysis and assessment of the implementation of the Policy.
