Prevention of Conflicts of Interest

The bank applies measures to identify and to eliminate conflicts of interest that, during the provision of services, can occur between the bank and the Customer, as well as among the bank’s Customers. The bank has an approved policy for the prevention of conflicts of interest, which provides for:

  • activities to prevent or control information exchange between the bank’s employees whose activities are related to a conflict of interest risk if such information exchange might harm the interests of one or more Customers;
  • internal control system to ensure compliance with laws with respect to personal financial transactions of the bank’s employees, and their restrictions, and to guarantee that the bank’s employees do not execute personal transactions on the basis of internal information that is accessible to them while performing their duties at the bank, as well as that they do not recommend third parties to execute such transactions and do not reveal internal information to third parties;
  • measures that prevent or limit inappropriate influence of third parties in the process of investment service or investment auxiliary services provision.

The bank has developed and approved procedures that:

  • provide for additional supervision of the bank’s employees whose main duties are activities performed on behalf of Customers or the provision of services to Customers, or who otherwise represent other, including the bank’s, interests and whose interests may be involved in a conflict with Customers interests;
  • prevent direct link between the activities of the bank’s employees related to the provision of various investment services and the remuneration of such employees, or their income to be made in situations when a conflict of interest may arise with respect to the activities carried out in the framework of investment services provision;
  • prevent or controls concurrent or consecutive involvement of the bank’s employees in the provision of various investment services or investment auxiliary services, if such an involvement might weaken the adequate supervision of conflicts of interest;
  • provide for other additional procedures and measures necessary to prevent conflicts of interest with respect to the activities of the bank’s employees.

Upon the Customer’s request, the bank provides them with the possibility to become acquainted with the policy for the prevention of conflicts of interest and other procedures.