Article (1) Purpose
The purpose of approval and notifying the current “document” is to create a working environment in line with MEB values, to protect the bank and all its employees’ reputation and creditworthiness as well as fulfillment and honoring bank’s obligations to its customers. To that end, the values and general approach is delineated to make decisions accordingly, and through clarification and transparency of basic expected ethical conduct and acceptable behavior, make it possible to supervise.
Article (2) Scope of Application
The scope of application of “code of Ethics” includes all members of executive board, advisors, all employees of the bank and subsidiary companies/firms, in their group structures and contracting companies, hereinafter referred to as “Subject Persons”
Article (3) Values and General Principles
Honesty, good manner, probity, transparency and protecting interests of all stakeholders are amongst the core values and principles which, with regard to the bank’s strategy, are highlighted and based on interactions with the bank in its integrity, colleagues, shareholders, customers, contractors and supervising bodies includes, at least, the followings :
Awareness of, and compliance with, the relevant laws and regulations
all Subject Persons are required to be well-aware of and observe effective laws and regulations in their field of activity.
3-2. Taking care of stakeholders’ interests
all subject persons must give priority to stakeholders’ interests in all interactions and activities
3-3. Administrative and financial health and accuracy
regarding the importance of honesty, probity and transparency principles, all subject persons are required to observe and abide by these principles in all interactions and activities
the base for any professional relation and operation is to respect others, so all subject persons, in their contacts with people of different viewpoints, should treat with respect.
3-5. provision of quality service
all subject persons are required to devote their utmost effort to offer quality service and endeavor to identify and meet customers’ needs.Section 1- professional organizational conduct
Section 1- professional organizational conduct
Performing the duties of Subject Persons must be according to regulations. Procedure of work and fulfillment of tasks must be in an accurate manner and based on following professional principles. The Subject Persons are also required to remain committed to protecting bank’s information, assets and resources.
Article (4) Performance Accuracy and Health
The Subject Persons, at any level and time, are required to remain transparent and honest, fully aware of their duties and make their utmost effort to do their job in accordance with laws and regulations.
4-1. Conscientiousness and punctuality
4-1-1. Subject Persons are required to carry out their duties according to current guidelines and make the most of their time at work.
4-1-2. Subject Persons are required to remain fully aware of their duties, either regular and routine jobs or temporary work, as work projects, and in case of ambiguity, make inquiries from their superior officials in proper form.
4-1-3. Subject Persons, in addition to remaining fully aware of their jobs and projects, must be time-efficient and do the job in due time.
4-1-4. Subject Persons should not spend their time at the office for doing their personal jobs and must minimize their non-office activities, such as browsing internet or using social media or telephone, to the lowest level.
4-2. Accountability and Responsibility
4-2-1. Subject Persons must remain responsible towards the bank and use all their knowledge and skills to do their jobs properly.
4-2-2. Subject Persons, in addition to remaining fully aware of their duties, must know the general procedures and tasks of the unit and the management they’re working in, and show responsibility towards their organizational duties.
4-2-3. Subject Persons must remain accountable with regard to their activities and responsibilities and, in case of facing any problems, take full responsibility to find the cause and provide on-time reports and resolve the issue.
4-2-4. In case a certain task, beyond the job description, is assigned on a Subject Person who lacks professional knowledgeable to fulfill it, he/she should procure justification and refuse accepting the task and, if needed, take steps to learn the required professional knowledge.
4-2-5. Any person, at any level, stands accountable for his duties and if he/she has employees working under him, he may, with due regard to the job description and taking responsibility, assign the work on them and oversee proper performance.
4-3. Transparency and accuracy
4-3-1. Subject Persons are required to fully comply with transparency principles and refrain from supplying any misinformation or producing inaccurate report or making any attempt to conceal something.
4-3-2. In accordance with general policy of the bank on establishment of healthy relations with other practitioners, any action (or inaction), involving unhealthy practice, provision of inaccurate information on the bank’s achievements on service delivery or unauthorized access to information of other practitioners is forbidden.
4-3-3. All documents, instruments and guidelines produced in the bank must be according to the bank’s needs, with due attention to the principle of transparency, so no documents or guidelines of other banks may be reproduced without citation of the reference.
4-4. Dress Code and Groominng Policy
4-4-1. Subject Persons should have a clean and neat appearance in the workplace and refrain from inappropriate and unusual clothing and observe the related regulations.
4-5. Personal Development and Training
4-5-1- Subject Persons, while working at the bank, are required to enhance their skills to improve efficiency and professional knowledge in their field of activity and inform their superior officials of their training needs.
4-5-2- Subject Persons must, actively and efficiently, attend the on-the-job training courses and use it in carrying out their professional duties and share relevant issues with others in appropriate manner.
4-6- Relations with Media
4-6-1- Any relations with the media, regarding the bank and its affairs, must be through Relations Department or by the permission of that department and no one has the permission to establish relations without the necessary permissions.
4-6-2- Publishing any book, essay, written or oral text, on behalf of the bank or in its name, without written permission, is not allowed.
Article (5) Compliance with Laws and Regulations and Optimal Risk Management
5-1. Awareness of and compliance with the most recent regulations on the field of activity
5-1-1. Subject Persons, at any level, are required to remain fully aware of upstream laws and regulations, Middle East Bank’s Articles of Association and Strategic Document, and also all approved and notified guidelines, circulations and internal instructions related to their operations.
5-1-2. Subject Persons, while at work, must build sufficient knowledge of regulatory bodies, enforcement officers and authorized supervisors related to their field of activity, while doing their work.
5-1-3. Subject Persons may put their questions and queries to Methods and Organizations Management and/or Compliance and AML Department, through official hierarchy and resolve their ambiguities.
5-1-4. Subject Persons are required to be aware of, and act with great prudence on high-risk laws and regulations, including AML, bribery and corruption whose incompliance may lead to serious dire consequences for the bank, (and therefore the bank shows zero tolerance towards non-observance of such regulations), and remain aware of consequences of incompliance.
5-1-5. Subject Persons are required to, within their job description, be informed of basic risk concepts and refrain from conducting high risk activities at all times while performing their duty.
5-2. Anti-Money Laundering and Combating the Financing of Terrorism
5-2-1. Subject Persons, for AML/CFT purposes, are required to study all regulations on this area and pursue them with great care while doing their jobs.
5-2-2. Subject Persons must report any suspicious and unusual transactions and behaviors to the Compliance and AML Department, in proper form.
5-3. Bribery, Corruption and Violation/misconduct
5-3-1.Abuse of authority, or the bank’s capabilities or facilities, to gain personal or group advantage is prohibited.
5-3-2.Intentional violation of laws and regulations, producing inaccurate/false report and providing wrong data/information is prohibited.
5-3-3. Giving or taking bribe is by no means and under no conditions permissible and not allowed.
5-3-4. Trading shares by the Subject Persons, using information acquired due to job position, from internal or confidential information (insider information) which may affect the value of tradable securities is prohibited. Enticing and encouraging others towards such activity, through using acquired information, is not permitted either.
5-4. Gifts, Hospitality and Services
5-4-1. Giving, taking, offer or acceptance of a service or something of value which may affect the decisions of parties or may lead to an action not in line with the benefits of the bank or consistent with the relevant laws and regulations is prohibited.
5-4-2. Subject Persons are not allowed to accept or offer gifts or services to/from other Subject Persons, customers or contractors which may influence decisions on carrying on the work or to facilitate or expedite doing the business.
5-4-3. If the gifts, hospitality or services are not aimed to facilitate or expedite conduct of business nor to influence professional independence of the Subject Persons, acceptance of pre-defined items up to the limit mentioned in the Avoidance of Bribery and Corruption Policy is permissible.
5-4-4. All Subject Persons are required to inform their superiors in writing of any offer or acceptance of gifts, service or hospitality. The managers must report in writing, offer of gifts above the defined limit to the Inspection Management.
5-5. Conflict of Interest Management
5-5-1. In case of conflict of interest, the duties and obligations of Subject Persons towards other persons/the bank shouldn’t do any harm to their duties and responsibilities towards the bank.
5-5-2. Subject Persons, at any level, are required to carry out their jobs properly and avoid any misuse in favor of their own or their relatives private interests.
5-5-3. Subject Persons, in their relations with customers, colleagues and third persons, must maintain their professional independence and refrain from influencing the other party in favor of their own interests.
5-5-4. Subject Persons are not allowed to work for any other entity except teaching at universities and educational institutions with prior consent of the bank.
5-5-5. Subject Persons are not allowed to make entries (themselves) in, nor do transaction from, their own or their relatives accounts, or the accounts where they have personal interest, nor to get involved in the facilities extended to their relatives.
5-5-6. Opening or closing of the account or making transfers between the accounts without permission and approval of the person in charge, or transfer of funds without approval, is not allowed.
5-6. Optimal Risk Management
5-6-1. Subject Persons must be familiar with the broad concept of risk and be aware of general strategies and policies related to which.
5-6-2. Subject Persons are required to be informed of the risks associate with their field of activity and assume responsibility for timely risk identification and reporting.
5-6-3. Subject Persons, when performing their jobs and offering service, should endeavor to identify existing risks and directly report to the Risk Management or enter the case in the Operational Risk System.
5-6-4. Subject Persons, in addition to compliance with all rules and regulations, are required to be risk-centered when performing their duties and, even if regulations are satisfied, remain highly prudent when face a high-risk item.
5-7. Disclosure and Reporting of infringements
5-7-1. Subject Persons must remain sensitive to any financial offence or violation and report, through System for Confidential Disclosure of Violation, any conduct of transactions by unauthorized persons or any misconduct or incompliance with notified regulations and bank’s internal guidelines, immediately and without any worry.
Article (6) Protecting the bank’s property, information and reputation
Subject Persons must endeavor to use and protect the bank’s assets, equipment and information, however accessible to them, in a proper manner.
6-1. Information Confidentiality and Security
6-1-1. Subject Persons must endeavor to protect the three main pillars of information security, namely confidentiality, data accuracy and accessibility.
6-1-2. Subject Persons must prevent any unwanted changes to the existing data and information, whether intentional or unintentional.
6-1-3. Subject Persons are committed to maintain secrecy and be aware of basic concepts of information security and cybercrime and the bank’s policy on such issues and do their best to mitigate the risk of disclosure of confidential information and unauthorized access to the bank’s information and resources.
6-1-4. Subject Persons are required to be informed of the information classification and confidentiality policy/standards and level of access and refrain from disclosing confidential information of the bank, current or former colleagues or the existing or former customers, which they receive in the line of duty, while working for the bank or after termination of work.
6-1-5. Disclosure of information is permitted only in certain circumstances and merely based on enforceable laws and regulations to be submitted to the competent legal authorities.
6-1-6. Subject Persons are required to report to the Information Security Department any security issues such as unintentional disclosure of information, unauthorized access to equipment and sources, unauthorized destruction or change of information and suspension of provision of critical services.
6-1-7. Protecting information asset, at various levels, is of importance and Subject Persons must endeavor to keep information asset secure and observe security issues when using e-mail, internet and sharing files.
6-2. protecting resources, assets and equipment
6-2-1. Subject Persons must take adequate care of all (re)sources, equipment and IT services, made available to them in the course of their duty, and avoid any carelessness or misusing the bank’s assets and property.
6-2-2. Subject Persons should minimize using bank’s equipment, resources and means of communication such as telephone, e-mail or internet, for personal purposes.
6-2-3. Subject Persons are not allowed to use other colleagues (such as cleaners) for their personal errands.
6-2-4. Subject Persons should minimize the costs imposed on the bank. The costs of Subject Persons, incurred when on mission or business trips, should be reasonable and proportionate to necessary services and goods.
6-2-5. Subject Persons should follow security factors and procedure of work when using bank’s equipment, and inform any malfunction or breakdown of equipment or properties to the IT Management or Logistics Department.
6-2-6. Subject Persons are not consented to use, or customize, in any form or manner, the items which are intellectual property of the bank and they’ve cooperated in preparation or development of which.
6-3- Protecting the good reputation and stature of bank
6-3-1. Subject Persons should refrain from stating opinions about the bank which negatively impacts the customers, Subject Persons and other parties.
6-3-2. Subject Persons should be highly prudent when using social media and refrain from behaviors, activities and deals which may do harm to the reputation and standing of the bank.
6-3-3. Subject Persons should refrain from social or political activities contradictory to the country’s laws and regulation and/or professional conduct.Section Two- Personal Professional Conduct
Subject Persons should, in the course of their work, remain committed to professional conduct and give priority to honesty, respect, appropriate relationship and team spirit in the workplace.
Article (7) On Customers
Provision of favorable services along with respect, precision and speed in carrying out duty are amongst professional principles of the bank. The expected services should be offered in the shortest of time, error-free and at the highest quality and lowest cost.
7-1. Respect and Honesty
7-1-1. Subject Persons should always observe the principles of respect, honesty, transparency, secrecy and accountability in their relations with customers.
7-1-2. Subject Persons in their interactions with the customers, while showing respect and talking with proper language, should avoid building relationships which trespasses acceptable behavior.
7-1-3. Subject Persons should show restraint and respect in dealing with any behavior or questions of customers and get along with misbehaving customers, as far as no violation of regulations happens.
7-1-4. Subject Persons, when offering services and products, are required to obtain adequate information from the customers and avoid asking for information beyond the regulations.
7-1-5. Subject Persons are required to keep customers’ information confidential.
7-2. Offering Quality Consultancy and Services
7-2-1. Subject Persons should understand the needs and requests of customers and provide them with suitable services and products, according to their current request and need, and inform them about new services and products, if necessary.
7-2-2. Subject Persons should guide the customers in the best way possible and provide them with accurate and useful information with due regard to confidentiality guidelines. When providing requested information is not allowed by regulations, the customer should get informed with utmost respect.
7-2-3. Subject Persons should offer their consultancy and comprehensive information to the customers, according to their field of business activity and expected banking services, and act in line with enhancing satisfaction, protecting interest and creating value for customers.
7-3. Fair treatment and non-discrimination
7-3-1. Subject Persons should refrain from any discrimination and must treat the customers well, regardless of issues such as sex, race, nationality, religion, social class, physical incapability and appearance.
7-3-2. Subject Persons should do their best to treat individual and legal customers fairly and without prejudice. Various services may be granted to customers but the difference in level and type of services shouldn’t be to the detriment, or loss of profit, of other customers.
7-4. Taking care of Customers’ interests
7-4-1. Subject Persons should pay reasonable attention, and show rational commitment, to customers’ interests.
7-4-2. In case of customer dissatisfaction and complaint about the type, quality and manner of banking service provision, the Subject Persons are required to examine the case according to the rules and regulations and inform the customer of the results in proper manner.
Article (8) On Shareholders
8-1. Subject Persons should always pay due attention to provision of favorable services to customers.
8-2. Subject Persons are required to assist board of directors and the board’s specialized committees with the establishment of optimal corporate governance, aiming at enhancing transparency, releasing accurate information and protecting shareholders’ interests.
8-3. All clauses mentioned in Article (7)- On Customers, with the exception of sub-clause (7-2.), shall be exercised for shareholders as well.
Article (9) on Third Persons
Subject Persons should treat third persons with respect and give them assistance but refrain from providing them with non-necessary information.
Article (10) on Relations with other Colleagues
The bank’s organizational culture is based on honest and respectful behavior and the bank shall not be indifferent on cases of disrespect, non-transparency or discrimination.
10-1. Respectful and non-discriminatory treatment
10-1-1. Subject Persons should avoid any rude or disrespectful behavior, using contemptuous language, offensive terms, insulting words or ethnic or sex issues contempt.
10-1-2. Subject Persons should treat each other politely with respect and avoid any relations or interactions, beyond accepted customs and norms.
10-1-3. Subject Persons must deny unusual requests and, in necessary, inform the HR management.
10-2. Team Work and Collaboration with others
10-2-1. Subject Persons should cooperate with, and respond to, others and abide by the principles of team work and proper behavior with other team members.
10-2-2. Subject Persons should observe the code of conduct in the meetings and while taking note of the time schedule and agenda of the meeting, state their opinion.
10-3. Observing office hierarchy
10-3-1. Subject Persons are required to follow office hierarchy at all levels and observe the same when passing on information, making communication or producing reports.
10-3-2. Subject Persons are required to execute rational orders of their superior and, in case of having any ambiguity or different view, state their opinion, in a respectful manner.
10-4. responsibility towards employees under management
10-4-1. Subject Persons should encourage and raise spirit of the employees working under them and avoid any discrimination or contemptuous behavior against them.
10-4-2. Subject Persons must procure, and communicate, appropriate information, necessary training, transparency of tasks and career ladder for the employees working under them.
10-4-3. Subject Persons should settle any argument or dispute between the employees working under them and, if needed, ask HR for help.
10-5. Safety and Health of Employees
10-5-1. Subject Persons must refrain from any insulting behavior which may make the work environment toxic or distract concentration of colleagues.
10-5-2. Subject Persons, when at work, should pay due attention to work place safety, health of others and prevention of disease spread.Section Three- Roles and Responsibilities
In compliance with this Code of Ethics, each employee and the main organs of the bank are tasked with the following duties
Article (11) Employees
11-1. Shall be made informed of the content of current Code of Ethics, on the employment start date, and are committed to comply with it.
11-2. Are made informed of any changes to Code of Ethics, and evaluate themselves based on how they observe the content of which.
11-3. Feel responsible towards observance of the Code of Ethics by the staff working under them and colleagues in their department.
11-4. Remove any ambiguity in the content of the Code of Ethics through relevant manager, HR management or Compliance and AML Department.
11-5. If any breach of Code of Ethics or deviation from its content is spotted, report the case to their direct superior, HR management or Compliance and AML Department or register it in the System for Confidential Disclosure of Violation.
Article (12) Compliance and AML (Anti-Money Laundering) Department
12-1. In collaboration with HR management, provides necessary training courses and removes employees’ ambiguities.
12-2. Evaluates the risk of non-compliance with the Code of Ethics and checks the statues/condition system of implemented controls.
12-3. Sets out procedures, in cooperation with HR department, to ensure observance of the Code of Ethics and makes sure that any deviation from Code of Ethics can be identified.
12-4. Introduces instruments and implements controls to mitigate the risk of non-compliance with the Code of Ethics.
12-5. Revises the Code of Ethics once a year at least.
12-6. Prepares and submits the report on violation and infringement of the document to the Compliance Committee, semiannually.
Article (13) Human resource Department
13-1. Makes arrangements for teaching the full content of this current Code of Ethics, in collaboration with Compliance and AML Department.
13-2. Makes sure that the content of Code of Ethics is thoroughly transferred to all Subject Persons and they’re made fully aware of any changes.
13-3. Assists Compliance and AML Department with implementation of the procedures on identifying deviation from Code of Ethics and putting into place controls to mitigate the risk of non-compliance with Code of Ethics.
Article (14) Other Main Organs of the Bank
14-1. Board of Directors is the main body in charge of accurate and proper execution of Code of Ethics and responsible for supervising its proper execution.
14-2. Board of Directors helps Compliance and AML Department with implementation of procedures to mitigate the risk of non-compliance with Code of Ethics.
14-3. The Inspection Management investigates breach of Code of Ethics, if necessary.
Article (15) Performance Guarantee
Any deviation from this Code of Ethics is construed as professional/official misconduct and shall be dealt with according to disciplinary regulations. The bank’s action may vary from giving notice to termination of work or, as the case may be, reporting to judicial system.
Article (16). Body in Charge of Supervision on Good Performance
Supervision on good performance of current Code of Ethics, and its associated plans for execution, is carried out by Board of Directors through Compliance and AML Department.
Article (17). Revision
Compliance and AML Department is responsible for preparation, updating and revision of the current document. Modifications, when needed, after confirmation of Corporate Governance Committee, shall be approved by the Board of Directors.
This Code of Ethics and Professional Conduct, in 17 articles, confirmed and signed by the members of Corporate Governance Committee members in the session held on January 25, 2021 and approved by Board of Directors in the session dated March 14,2021.