Avoidance of the conflict of interest

The employees of the NLB Group understand and accept responsibility for adopting the right decisions led by our business interests. We are obliged to identify, monitor and exclude potential conflicts of interest.

A conflict of interest arises when an employee’s personal activities or their relationships from private life intertwine with the business interests of the NLB Group (its members) and thus affect the objectivity of the employee in adopting business decisions in line with the best interests for the NLB Group. A conflict of interest can also reduce the value of shares and expose the NLB Group to legal risks and/or reputation risks.

The employees of the NLB Group take great care to avoid such conflict of interest and follow our internal rules which dictate that we must recognise and appropriately and efficiently manage the conflicts of interest (business and private).

Every employee of the NLB Group must focus their attention on the detection, prevention and elimination of the conflicts of interest. In the framework of performing the tasks and adopting decisions, they must always follow the interests of the NLB Group and not their private interests.

As employees in the NLB Group we must at all times take care to ensure that our work outside the member of the NLB Group does not interfere with the interests of the NLB Group and does not affect our decision that would be contrary to its interests, values and goals.

Conflict of interest can arise in the relationship between the NLB Group (its members) and the customers, other customers or business customers, between the customers of the NLB Group (its members) and/or third parties and between different business activities within the NLB Group.

On a personal level, the conflicts of interest usually occur when our private interests could prevail over the interests of the customers, suppliers, other business partners or the NLB Group (its members). Such cases arise when our interests overlap with the interests of the NLB Group or its customers or when we have a close personal or financial relationships with other employees in the NLB Group.

The employees of the NLB Group have a duty to respect internal rules about the disclosure of such activities, functions or inclusion in the business activities and other circumstances that could represent a conflict of interest. This is the only way to appropriately manage or prevent potential negative consequences of a conflict of interest in a transparent, ethical and fair manner.

The following shall be deemed a conflict of interests: if an employee of the NLB Group has a personal, financial or business relationship with the customer or the business partner, which could influence the process of adopting a decision on a transaction or other business decisions. Any transactions related to financial instruments owned by the employee and all other transactions, including opening of bank accounts and performing of transactions, regardless of whether or not they are transactions performed on behalf of the employee or another person (as authorised person) shall also be considered a conflict of interests. Transactions for own account include transactions which the employee performs for the account of related persons.

Most common situations that can lead to a conflict of interest:

• Privately financed projects or private (business activity intertwining with the services offered by the NLB Group and development of new products (including innovations).
• Functions that could be incompatible with the interests of the NLB Group, such as memberships in the management bodies of competitive companies to the members of the NLB Group.
• Ownership or investment in a company that is directly or indirectly connected (a key client, contractual partner, etc.) with the NLB Group.