Act ethically - responsibly

Every person in NLB Group is committed to uphold the highest standards of moral integrity, professional and ethical conduct, which is beneficial not only for the NLB Group but also for its customers, internal and external, colleagues, business partners, shareholders, the financial system and the community at large. The only guarantee for the consolidation of the confidence in the NLB Group and the key to its reputation and long-term successful performance is ethical, diligent and responsible operations compliant with the Code. Trust is the foundation of the banking activity.

The NLB Group is responsible towards its customers, colleagues, stakeholders, owners, business partners and social and natural environment. Understanding customers and taking care of their positive user experience is our fundamental responsibility. This includes the understanding of their needs and the related risks for themselves and for the NLB Group. We carefully and responsibly build partnerships with all those we enter into business relationships with. As employees we have a duty to each other and to all stakeholders to act professionally and with commitment and mutual respect in our work. Regardless of the opportunity, all employees in the NLB Group must act with complete fairness, honesty and integrity in everything we do, and face challenges in a responsible manner. With due responsibility, we take care of the reputation of the banking and broader financial activity and also meet our responsibility towards the broader social and natural environment.

Every person in the NLB Group:

• at all times complies with the principles of ethics, fairness and expertise;
• acts in a responsible, positive and constructive manner, in line with the strategy, goals and values;
• prevents and eliminates the risks of harmful conduct;
• works according to the law, regulations and good practices.

As employees of the NLB Group, we are responsible for getting familiar with this Code and fully complying with it in our conduct.

A violation of the standards and rules of conduct defined by this Code can lead to a serious violation of work obligations of each employee and result in potentially imposed measures for the elimination of the consequences of misconduct. Serious violations can result in other appropriate sanctions and other measures (including labour law measures), that can lead to termination of any further cooperation between the employee in the NLB Group and a member of the NLB Group. Therefore the Code also forms the basis for all other rules and instructions of operations, including organisational rules and procedures, the existing powers of attorney as well as decisions, agreements and contracts made by the NLB Group.

We are aware that the public identifies their work, proceedings and attitude towards the customers with the conduct of the NLB Group as a whole, with all consequences arising from such conduct.

Therefore, we must strive to always base a successful relationship with the customers on mutual trust, earned by a fair and open dialogue, understanding and freedom of choice.

We shall perform our duties by acting in accordance with the adopted principles and rules and in a way ensuring that our work and behaviour inside and outside the working environment does not damage reputation of the NLB Group or any of its members, and the banking and financial activity as such.

We are therefore responsible to:

• act in a responsible, positive and professional manner, in line with the strategy, goals and commitments, laws, rules and good practices;
• prevent and eliminate all possibilities of corruptive practices in any member of the NLB Group, as well as all violations of the applicable rules or fundamental ethical norms;
• prevent any conduct, decisions or actions that would be contrary to the laws, internal rules, the strategy of the NLB Group and the commitments, legally permitted goals, ethical principles or values of the NLB Group, particularly if these could result in damage to an individual or any member of the NLB Group.

The management staff of the NLB Group sets an example and should therefore promote open, fair and earnest relations among the employees, without vindictiveness, and act swiftly in the case of perceived ethical issues in the working environment. It is your task to promote ethical culture and not to demand any conduct from your employees which would be contrary to the legislation or other prescribed rules or this Code.