Scope of application of the Code and persons bound by it

The guarantee for the consolidation of the confidence in the NLB Group and the key to its reputation and long-term successful performance is operations compliant with the Code. All employees of the NLB Group must understand and comply with the values, principles and rules contained in this Code of conduct, taking them into account when pursuing the Bank’s current values.

As employees of the NLB Group, we are responsible for the reputation of each member of the NLB Group and must be familiar with this Code and comply with it in our daily conduct. The Code is structured so as to be of practical help in our everyday work.

The conduct in accordance with the rules of the Code of Conduct of the NLB Group can contribute to a more successful development of the entire NLB Group and all us, employees. Every employee is obliged to comply with the Code and encourage their colleagues and business partners to do the same.

This Code fully applies to members of the bodies of the NLB Group. In this sense the term employee of the NLB Group is also interpreted.

Managers at various levels in the NLB Group, including members of the management bodies (management board members, supervisory boards, executive directors, board members) have specific responsibilities:

• Discuss this Code with the members of your teams and make sure that all have understood it, thus promoting the ethical culture in the NLB Group;
• Make sure that the fundamental principles and rules of conduct are implemented and complied with;
• Make sure that the values of the Bank are achieved in the light of set principles and rules of conduct;
• Encourage open, fair and honest relationships among the employees, without fear and vindictiveness;
• Encourage open discussions about all questions handled by this Code;
• Your conduct and behaviour should set an example embodying the values and meeting the basic principles of the NLB Group;
• You are responsible for reacting swiftly if you perceive any ethical problems in your environments;
• Do not demand any conduct from your employees which would be contrary to the legislation or other prescribed rules or this Code.

The NLB Group abides by the basic principles and rules of desired conduct in its operations with business partners and other stakeholders. Therefore, the NLB Group expects that all business partners and other stakeholders apply the standards at least equal to those written in this Code, including their attitude towards the employees. The NLB Group is committed to respecting all relevant interests of the parties involved in a transparent manner and in accordance with the agreements.