Managing Conflict of Interest

Potential conflicts

Everyone at AmBank is expected to act in a way that reflects our commitment to integrity and responsible business behaviour.

Conflicts of interest arises when an employee places his or her personal interests before the interests of AmBank and where such personal interests unduly influence the employee’s business judgments, decisions, or actions.

You must ensure that personal and business affairs do not conflict with or appear to be conflicting with AmBank’s​ interest. Any potential conflict observed during your day-to-day interactions at the bank must be reported immediately.

Giving and accepting gifts

All employees must strictly adhere to AmBank’s No Gift Policy.

A gift is defined as anything of value including items such as money, securities, business opportunities, goods, services, entertainment, company sponsored events, food, drink or vacations.

Our customers and suppliers are vital to AmBank’s success. Hence, it is imperative that these relationships remain objective, fair, transparent and free from conflict.

As an employee of AmBank you should not:

• Accept or give cash or cash equivalents (e.g. checks, cash convertible gift certificates or cards, securities and loans, etc.)
• Accept or give anything that could be viewed as a bribe, payoff or improper influence
• Use your position in any way to obtain anything of value from prospective or existing customers, suppliers or business partners
• Provide entertainment that is lavish or too frequent for an existing or prospective customer or supplier
• Accept or give gifts from any supplier during the selection process, whether or not you are the primary relationship manager or involved directly in the negotiation
• Participate in any action that would cause the other person to violate their own company’s standards for gifts and entertainment
• Provide gifts or entertainment to an existing or prospective customer or supplier that are not recorded in the Gift Register.

Charitable contributions

AmBank is supportive to contributions towards charitable organisations. However, you should perform relevant due diligence procedures prior to dealing with them.

This is necessary to prevent contributing to charitable organisations which may be engaged in terrorism, money laundering or other criminal activity.

Any charitable contribution that could influence business decisions, should be avoided at all cost. This includes contribution requested by or made to an employee, customer, supplier, government official or business partner.

All charitable contributions made on behalf of AmBank should be approved by your respective department prior to disbursement to the charitable organisation.

Outside business activities

All employees must declare any involvement in business activities outside of AmBank in order to prevent potential conflict of interest.​

Examples of outside business activities include the following :

• Outside employment or business dealings with AmBank’s auditors or with existing or prospective customers and suppliers
• Outside service as a director, officer or general partner of the following entities:
• Any sort of business or financial relationship (including receiving charitable contributions, grants or foundation money) with AmBank
• Trade or industry organization (e.g., Financial Industry Regulatory Authority or the Chartered Financial Analyst Institute)
• Ownership of an outside business which is either as a sole proprietor or in partnership
• Political involvement in a government appointed office, of which you are directly involved in
• Fiduciary appointment as an administrator, executor, guardian or custodian for a minor, or a trust you are directly involved in
• Non-profit, family, community and charitable organisations that you serve as an officer or board member

AmBank reserves the right to request for you to discontinue your involvement in any of the above if the company observes any conflict of interest.​​

Dealing with families and close personal friends

In general, a family member and personal friend should not have any business dealings with you or with anyone who reports to you in AmBank.

Conflict may arise if a family member or a personal friend is working for a company that does business or seeks to do business with AmBank, as a customer or supplier.

You should notify AmBank of your involvement where you or your family member have personal financial connections, financial interests or decision-making influence. AmBank has the right to ask you to discontinue your involvement in such dealings if they perceive any conflict of interest.​