Guiding Principles

The following principles apply under this Policy:

1. Compliance is the responsibility of all the Bank’s employees.
2. The Bank must hold itself to a high standard of integrity and ethical conduct in its business dealings and operations and observe both the spirit and letter of the law and regulations, at all times.
3. The Board and Senior Management shall oversee and ensure the effective management of bribery and corrupt practices risk, including the establishment of anti-bribery and corrupt practices compliance function within Group Compliance.
4. The Board and Senior Management assume primary roles in fostering a strong compliance and ethical culture within the Bank by ensuring that all employees understand their roles and responsibilities in respect of compliance and are able to raise their concerns on any compliance matter without fear.