Corporate Values and Core Principles

At the same time, a Transactions Transparency Policy, as well as a Regulation of Transactions with Persons with a Special Relationship with the Bank, have been adopted and are implemented for the protection of everyone transacting with us. Transactions of any kind of the Bank for all types of loans granted to those persons and the participations they acquire, are concluded upon a decision of the respective competent body of the Bank and are regulated by special terms and procedures. As a general principle, the terms of the relevant loans to persons with a special relationship with the Bank do not deviate from the terms applicable to similar categories of other loans.

The promotion of the products and services offered by the Bank, regardless of the means of promotion and the information used, is true, the proposed product is clearly and comprehensibly identified, does not contain inaccurate or misleading statements, does not make overstatements nor does it attempt to conceal the features of the services offered and does not exploit the ignorance, inexperience or fears of the public.

At the same time, the Bank reviews and resolves any and all complaints or reports by persons transacting with it, at the highest possible management level, having delegated this responsibility to the Complaints Committee, which operates under specific standards for procedures.

The Bank has developed, implements, complies with and promotes high ethical and professional standards, taking into account its special needs and characteristics. The Bank ensures the implementation of these standards (prohibition of disclosure of confidential information, professional secrecy, prohibition of money laundering, fiduciary obligation, obligation of diligence, cooperation, respect and responsibility), on the basis of an approved Code of Conduct, and monitors the compliance with these standards by the personnel and the members of the BoD.

The security of the personal data of data subjects that the Bank holds occupies an important place in the approved policies of the Bank. To this end, the Bank fully complies with the EU General Data Protection Regulation - (GDPR), extending the protection of data subjects and their rights, having developed and strictly implementing the Privacy and Personal Data Protection Policy for the personal data of its customers – natural persons, covering all activities of the organization.

The Management ensures the strict compliance, as well as the continuous improvement of the level of personal data protection that the Bank holds, having established the independent position of a Data Protection Officer (DPO). The risks to the protection of personal data are identified and addressed at various levels, in the context all operating procedures of the Bank.

In the context of the organizational and administrative arrangements, sufficient measures have been adopted in order to avoid potential conflicts of interest, which could adversely affect the relationships of all stakeholders. Measures have been adopted in order to limit or prevent actual and potential conflicts between the interests of the Bank and the private interests of the personnel, including the members of the BoD, which could adversely affect the performance of their duties and responsibilities.

The BoD of the Bank has adopted and maintains appropriate Internal Warning Policies and procedures for reporting potential or actual breaches of regulatory or internal requirements by the personnel or the internal governance regulations, through a dedicated, independent and autonomous channel. Staff members reporting breaches are not required to provide relevant evidence. However, they must be sufficiently certain, adequately justifying the initiation of a relevant investigation.

In addition to the foregoing, the following policies are also part of the key principles and the structural axes of the Bank’s operations:

• the adoption of the principle of direct or indirect involvement of at least two of its officials (4 eyes principle) for each activity or control function;
• the mandatory participation of the Internal Audit, Risk Management and Compliance units in the design of new products and procedures, in order to assess their compatibility with the applicable rules and any risks that may arise;
• the establishment of specific and detailed conditions and procedures for the physical and electronic access of the Bank’s personnel to assets and accounting data, in order to minimize unauthorized access and to reduce risks due to error and fraud. In this manner, confidential information is protected and the unhindered flow of information is “compartmentalized”, without hindering the smooth operation of the Bank, subject to the firm and fundamental principle that the human resources are the most important asset of the competitive advantage of the Bank.

The provision of high-quality services being the key focus, emphasis is placed on the availability of appropriate infrastructure and procedures for the management and training of the Bank’s human resources, in order for each job to be staffed with persons with the appropriate knowledge, skills and abilities.

Proper information and training of human resources and the provision of appropriate infrastructure contribute to the creation of a single culture that promotes honest communication, team spirit, flexibility and creativity.

Emphasis is placed on the determination of the remuneration of the Bank’s executives, especially those who are engaged in the distribution of products and services, with consistent consideration of the principle of avoiding the provision of incentives for excessive risk-taking or obtaining short-term benefits to the detriment of the interests of the Bank, its partners-members and its customers, in accordance with the approved Remuneration Policy.

Effective communication is the means by which the organized activity of the Bank is consolidated, vital information for the Bank is acquired and any necessary changes are promoted, strengthening its proper internal governance.

In the context of the application of the uniform - horizontal and vertical - communication in the daily management of the business activities of the Organization, a specific method is implemented for the dissemination of the necessary information, the introduction of procedures/policies and the issue of instructions to all Personnel through Circulars and/or Memos.