Ethics and conduct
Our Code of Ethics reflects our broader vision of our social and environmental responsibilities. It explains those values in which we believe, and which we have made a commitment to uphold.
As a company that operates in compliance with strict ethical norms, we have put in place a number of mechanisms that reveal risks that have previously, due to their nature, remained hidden; these include ethical risks. The purpose of the procedural rules is for victims in ethics cases, who until now have been unable to ask for help, to be able to consult and request advice, before taking action, if needs be, and to do so in an anonymous manner. In every member country the Intesa Sanpaolo Group has established a local ethics ombudsman system which, with a few exceptions, investigates ethics-related reports in the member country concerned, and the decisions are also made locally. To enable us to take local conventions into account, in addition to the ethics ombudsman the CIB Group has also established an Ethics Committee, the chairperson of which, as ethics ombudsman, is the Bank's head of CSR. We send a notification of every report to our head office in Italy without delay. The Ethics Committee does not impose sanctions, its task is to judge whether the claims made in the report are well grounded, and to take steps to share the lessons learned. If the report is well grounded, the Committee passes the case on to the appropriate professional department for investigation and a decision, and also to the HR area for a possible labour-law investigation.
In 2018 a total of six ethics complaints were received.
|Unauthorised disclosure of information to a third party||Conflict of interest||Employee's conduct||Employee's conduct||No ethics reports were received||Customer complaints|
|Verbal insulting of an employee||Sexual harassment||Manager's conduct||Customer complaint||Employee's conduct|
|Investigation, on the basis of ethical principles of the use of internal post for personal purposes||Manager's conduct||Manager's conduct|
|Investigation at the request of a coworker into the dishonest settlement of overtime||Employee's conduct|
|Clarification of the Code of Conduct||Obtaining information on overtime|
|Conduct of direct supervisor, overtime settlement||Question that arose with regard to car purchases from CIB's contracted partners|
|Statutory compliance in respect of internal regulations||Unfair conduct, apparent favouritism due to suspected personal relationship between an employee and a manager|
The interactive learning material prepared in 2012 provides the basis for the training that every employee must complete via the online platform. The learning material that was produced took the form of a comic strip-type story, which provides the most important information and uses interactive exercises and case studies to guide employees through the maze of the Code of Ethics, the rules of conduct and the Code of Ethical Procedure. The purpose of the training program is to make key information on our ethical values and ethical procedures accessible and engaging, both in the way they are presented and in terms of the related tasks, by making them easy to understand through exercises that illustrate the rules of conduct through examples. All new hires must study and be familiar with the ethics-related training material, and employees must pass a new test on the subject every four years.
The Code of Conduct is a means of articulating, in the form of regulations, the values enshrined in the Code of Ethics. It goes into detail regarding the rules of personal conduct and the finer points of banking operations, sets rules pertaining to the expected model of conduct, and deals separately with the prevention of corruption and the criteria for gift-giving. The breach of the Code of Conduct may have consequences under labour law.
Equal treatment and diversity
The Bank's Organisational and Operational Regulations (OOR) also clearly define the key principles related to responsible practices. Through this, the Bank rejects all forms of discrimination and corruption in both its internal and external communication, prohibits any form of discrimination and guarantees the general requirements of equal treatment in accordance with the relevant EU guidelines. Besides the above, the regulations governing compliance and risk management activities also proclaim similar principles aimed at supporting responsible operation.
The CIB Group ensures equal treatment for its existing and future employees in accordance with the Fundamental Law of Hungary, the effective statutory provisions and the CIB Group's Code of Ethics. This is achieved through the transparency of decision-making processes within the company and the ethical training provided to both managers and employees. The examination of ethical issues associated with this topic and the subsequent preventive changes ensure legal and ethical compliance in this area.
We ensure equal treatment for all existing and prospective employees, but at the same time we also give special consideration to ensuing work opportunities for people with disabilities and disadvantaged workers, and to creating a level playing field for these individuals. Where necessary, we adapt the hiring process to accommodate the special needs of applicants with altered abilities. Through these measures, we ensure the diversity of our staff.
Functions supporting responsible operation
In terms of responsible banking operation, clearly defining responsibilities, and in certain cases - depending on the relative importance of the given function - creating a separate organisational unit, is of key importance.
We regard legal compliance - especially with respect to the prevention of money laundering and the financing of terrorism - and the appropriate management of the risks arising from our operation as being of particular importance.
The functions supporting compliance with EU guidelines and legislative requirements ensure responsible operation, a key tenet of which is the effort towards corruption-free operation. Our corporate governance regulations, process requirements and internal training courses ensure that our employees do not fall victim to or become involved in corruption. Employees receive special training in this regard, and compliance systems ensure compliance with the regulations in the course of audits.
A separate team of specialists coordinates activities to prevent money laundering and the financing of terrorism. They have the task of checking transactions that are relevant or risky from the perspective of money laundering and sanctions, authorising the opening of accounts for new customers and reviewing existing customer relationships, as well as providing training for employees in the prevention of money laundering, forwarding reports to the competent investigating authorities, and ensuring the necessary flow of information. Digitalisation is exerting an impact in this area as well, and new schemes aimed at money laundering and by-passing sanctions surface continuously. The Bank must be prepared to recognize these and respond to them promptly and effectively.
Our employees have taken part in distance learning courses and examinations on the prevention of money laundering, anti-corruption and security awareness through the e-learning platform accessible via the intranet, as well as attending personal training courses. In 2018 a total of 330 employees took part in personal training on the prevention of money laundering, while a further 1,610 employees enrolled in such trainings on the e-learning platform.
The obligatory Code of Conduct, which was approved in 2008 and last reviewed in 2018, includes a set of rules on the prohibition of corruption. As a part of its efforts to combat corruption - in keeping with the relevant guiding principles of the Parent Company Intesa Sanpaolo - the CIB Group does not, in any way, support politicians or political parties, or institutions or persons that are associated with them.
Internal Audit is an independent and objective, corroborative and advisory function, the purpose of which is to improve the operations and effectiveness of the given organisation. In order to assist in achieving the organisation's stated objectives, the Internal Audit function methodically and systematically assesses and improves the effectiveness of the audited organisation's governance and control procedures.
Our internal policies set out stricter rules on conflicts of interest than the provisions of Act CXXXVII of 2013 (Credit Institutions Act), Act CXXXVIII of 2007 (Investment Firms Act) and Act I of 2012 (Labour Code).
The controlling of conflicts of interest is performed by the independent Compliance unit.
The Compliance unit also performs the subsequent control of gifts accepted by employees and is in charge of approving participation at professional events. The acceptance of gifts can, in certain cases, be classified as corruption.
As a consequence of the economic crisis, the demand for consumer protection in Hungary has strengthened on the part of both society as a whole and the legislators. In response to these expectations, the CIB Group has developed procedures that reinforce the protection of consumers. A dedicated specialist has been assigned to oversee this task, ensuring that consumers' interests are taken into consideration in the course of day-to-day operations, and that this attitude becomes an integral part of our corporate culture.
Our parent company, Intesa Sanpaolo - adopting an enlightened European approach - likewise places considerable emphasis on consumer protection and on providing a high standard of service to customers. Our parent company has issued a set of group-wide consumer and investor protection regulations, in order to harmonise and unify the consumer and investor protection provisions required and represented by Intesa Sanpaolo across all of its subsidiaries.
The purpose of the risk management function is to identify the risks of the given organisational unit, to measure the identified risks and manage them to ensure that they do not jeopardise prudent operation or the fulfilment of business objectives. At the CIB Bank Group, it is the Risk Management department that is responsible for these activities.
In 2011 the CIB Group elaborated its Risk Management Strategy, which is reviewed annually in line with the CIB Group's business strategy. The Strategy describes the internal capital adequacy assessment process and concept, which encompasses the CIB Group's risk assumption policy, its appetite for risk and the structure of risk control operations. The greatest risk that we face in the course of our business operations is credit risk, the mitigation of which is achieved partly through compliance with the statutory requirements and internal limits, and partly through prudent lending and loss-provisioning practices.
In 2013 the CIB Group introduced a new system of limits defining its risk appetite, in harmony with our parent bank's guidelines issued in this respect, which determines the framework based on which we control, depending on the extent of the risk, when, how and at what terms we provide services. We review the risk appetite and related system of limits annually, together with the parent company, thereby ensuring that the risk appetite, which imposes a limit on the various types of risk resulting from business activity, always reflects the effective statutory limits and the tolerable levels of the risks resulting from the CIB Group's activity.
We have established the Focused Customer Management Department, which has the primary objective of reducing credit risks through a reduction in problematic exposures, by means of an individual, customer-tailored business strategy for the customers concerned on the corporate side, and the development and the introduction of standard restructuring products in the retail segment.
In the course of its business operations the CIB Group is exposed to a variety of market risks. The CIB Group has identified interest risk, liquidity risk and price/exchange rate risk as measurable market risks. Each year, the Board of Directors, under the supervision of the Supervisory Committee, determines the appetite for market risk in line with the parent bank's tolerance for risk, and then sets out the corresponding limits and limit system. Risk Management is responsible for the operation of the limit system, the related processes, back-testing and reports.
The appropriate risk management committees, including the Board of Directors and the Supervisory Board, regularly receive risk reports broken down by risk type and in aggregate, applying the system of limits serving to define the risk appetite, which was introduced in 2013. The CIB Group, in addition to the retrospective analyses, also plans possible future risk regularly and on an ad-hoc basis.
In addition to normal risk management activity, for the management of financial crisis situations, in 2013 the CIB Group drew up and reviews at least annually, together with the parent company, its recovery plan in compliance with the applicable Hungarian and European Union laws. The purpose of the recovery plan is to enable the CIB Group, in the event of a financial crisis, to recover its financial stability without the need to be bailed out by the government with taxpayers' money.
It is important for us to advance ethical behaviour within our industry by exhibiting fair market and competitive conduct, leading by example, and through participation. We adhere to the self-regulating approach adopted by the industry and apply this to our own operations, while acting ethically towards our competitors. Fair competitive market conduct serves as the basis for our pricing policy.
In 2018, the MNB initiated an ex-oficio audit procedure, primarily to determine whether CIB Bank Zrt.'s compliances related to investment services and auxiliary investment services and its internal audit activity are in compliance with the requirements stipulated by Act CXXXVIII of 2017 on Investment Firms and Commodity Dealers and on the Regulations Governing their Activities (Bszt.), Directive 2003/6/EC of the European Parliament and of the Council of 28 January 2003 on insider dealing and market manipulation (market abuse), Regulation (EU) 596/2014 of the European Parliament and of the Council of 16 April 2014 on market abuse (MAR) and repealing Directive 2003/6/EC of the European Parliament and of the Council and Commission Directives 2003/124/EC, 2003/125/EC and 2004/72/EC. In its resolution, the MNB imposed a fine of HUF 1,200,000, which our Company paid in due time. At the request of the MNB, an appropriately regulated system and procedure for preventing, detecting and screening market abuse is under development. Ensuring compliance with data reporting and measure-related obligations is also in progress.
In the last quarter of 2018, the MNB sent its audit report on the targeted consumer protection audit launched to check CIB Bank Zrt.'s complaint management activity. In addition to correcting administrative errors, the report focused on complaints related to non-CIB operated ATMs and the mailing process.
In the last quarter of 2018, a themed consumer protection audit was launched focusing on CIB Bank Zrt.'s unilateral modification of loan agreements with a mortgage collateral and the related information provision.
In its resolution sent at the beginning of October, the MNB compelled CIB Bank Zrt. to display the annual percentage rate (APR) prominently in the commercial communication - published on its website- on personal loans provided to consumers, as well as to comply with statutory regulations related to determining the value of the APR to be displayed in the representative example and the data to be presented in the representative example. In addition to the requested changes, the MNB ordered CIB Bank Zrt. to pay a fine of HUF 500,000 for violating the above regulations.
In the context of the MNB's continuous consumer protection surveillance, the MNB has issued a consumer protection warning adressed to CIB Bank Zrt., due to the fact that the document entitled "Information on the Risks Stemming from Excessive Indebtedness" has not been updated. Our Bank updated the document without delay and notified the MNB about this. The MNB accepted CIB Bank Zrt.'s notification on the response to the consumer protection warning.