Our business is legal and we abide by the rules

The employees of the NLB Group are obliged to respect the legislation and other rules prescribing requirements regarding our daily business. We avoid actions that could constitute an alleged or actual breach of prescribed rules. The employees of the NLB Group therefore analyse and manage risks related to compliance in internal organisation, decision-making processes, disclosure policies, internal reporting and reporting to external (supervisory) institutions.

The NLB Group has been conducting procedures to discover and prevent money laundering, know your customer procedures and procedures for identifying and preventing financial and other crime – the NLB Group has zero tolerance for these.

In the case of abuse resulting from money laundering and terrorist financing, in addition to loss of reputation, individual members or the entire NLB Group could be subject to financial and regulatory sanctions. Therefore, the employees of the NLB Group are obligated to keep up to date with internal policies, rules and procedures to discover suspected money laundering and terrorist financing. We have also developed procedures and measures to respect sanctions and embargoes that prevent persons or organisations to conduct business with certain countries, groups of persons, companies, organisations and individuals, including those connected with terrorist activities, drug smuggling, nuclear weapon development and similar. The NLB Group has zero tolerance for the above.

To successfully prevent and discover suspicious transactions, every employee in the NLB Group who is faced with such transactions in the course of their work, has to act in accordance with internal acts of the NLB Group members and report such transactions to their superiors and the competent internal organisational units.

We at the NLB Group guarantee the highest standards of diligence in the management of confidential data and other information regarding individual members of the NLB Group, the entire NLB Group, the employees, customers and business partners. This is the only way to ensure the discretion of business relationships with business partners and customers as well as relationships with employees based on long-term trust.

Employees of the banks that are members of the NLB Group are thus bound to protect the confidential banking data, strictly confidential information and business secrets; there is zero tolerance for any events that could result in leaking or forwarding of information, data and business secrets to unauthorised persons.

The NLB Group employees are obliged to comply with the internal rules and procedures to protect all information and data disclosed to them in the course of their work. This obligation applies to all communication channels, social networks, all types of media and means of communication. Every employee is responsible and takes care of the protection of any confidential information, data and business secrets of which they become familiar during their work.

Such information may only be used internally, for business purposes of the employer, and may not be disclosed to third parties, unless permitted by the regulations or internal rules.

The employees of the NLB Group may not use for their own benefit or forward to any third person any confidential data specified by law and/or business secret determined as such by the member of the NLB Group and entrusted or in any other way made available to the employees. Any data which could obviously cause material damage if submitted to unauthorised persons shall also be deemed business secret.

The NLB Group has in place a strict ban on trading in financial instruments based on inside information and other forms of abuse of the market in financial instruments. The NLB Group is obligated to protect the confidentiality of inside information on NLB d.d. or other issuers and uses such information only for the purposes for which it was disclosed.

Certain confidential information is deemed inside information within the meaning of regulations on market abuse prevention. The NLB Group employees who are disclosed such information, either in the scope of their work assignments or accidentally, shall keep this information strictly confidential and shall not trade on the basis of inside information. Through internal acts the NLB Group has established measures that prevent conflicts of interest, set up information barriers, ensure timely and transparent disclosure of inside information on NLB d.d., establish control over the implementation of personal transactions, provide regular training in abuse of markets in financial instruments and guarantee full cooperation with the competent regulators. The NLB Group employees and other liable persons whom we cooperate with or who are included in the corporate governance system are obligated to fulfil their obligations as specified in the regulations governing personal transactions in financial instruments and to comply with the ethical standards, internal acts and rules defined in the NLB Group.

The NLB Group is committed to fair dealing on the markets where it operates, which includes avoiding unfair sales and business practices, restrictive agreements unfair competition and abuse of a potential dominant market position. The NLB Group is aware of the risks related to safeguarding competition, which is why we operate in compliance with our obligations. It is our responsibility to keep up to date with and to act in line with the regulations on the prevention of the restriction of competition and to understand how the risk of unfair competition influences our work obligations.

All our actions and each decision have to be aligned with this Code, the legislation and other regulations applying to the members of the NLB Group, and with the applicable internal acts. We have to be well familiar with these documents and act in line with the instructions regulating the performance of our tasks.

It is our duty to provide accurate and comprehensive documentation about all our business activities.

Every member of the NLB Group plays a key systemic role in the discovery and prevention of money laundering. At the NLB Group we should therefore be every day aware that money laundering and terrorist financing constitute a severe criminal act prosecuted ex officio. Thus, the front office employees have to ensure that the rules and procedures for money laundering and terrorist financing are complied with every day.

We have to identify early our considerations of potential (also future or possible) non-compliance. This is the only way to prevent violations. When in doubt we refer to our superior or the internal organisational unit in charge of compliance.

Are you considering trading for own account based on the information obtained in the course of your employment? Are you planning to use your employment for personal gain? The NLB Group has in force a strict ban on insider trading and market abuse.

In the event of a (potential) breach, you should immediately report thereon to the organisational unit in charge of compliance by use of the designated reporting channels in line with internal documents.

Information is crucial for preserving our competitive advantage. Employees in the NLB Group are responsible for the protection of secrecy and integrity as well as availability of information and data owned by members of the NLB Group, our customers, suppliers and other business partners. Therefore you have to comply with all internal rules and procedures and act so that this information and data are properly protected.