Compliance

Compliance

“The key aspects of the Pivdenny Bank Joint Stock Bank’s activities have been a firm intention to conduct business in accordance with ethical standards, conscientious and full compliance with legal requirements, and an honest and responsible approach to clients, partners, employees, the state and society since its establishment and to this day” (Code of Ethics of Pivdenny JSB PJSC).

Compliance Risk Management System

In compliance with the requirements of the Ukrainian laws and international standards (Compliance and Compliance Function in Banks (Basel, April, 2005), Corporate Governance Principles for Banks (Basel, July 2015) etc.), Pivdenny Joint Stock Bank has created and operates an effective compliance risk management system, which is mainly focused on ensuring compliance with the legal requirements, market standards, and corporate code of ethics in the following areas:

Functioning of the effective Compliance Risk Management System is possible due to:

  • an organisational structure with a clear allocation of duties, authorities, and responsibilities in terms of compliance risk management;
  • implementation of a compliance culture: “tone at the top”, regular employee trainings to guarantee that everyone understands their role in ensuring compliance with corporate values;
  • effective tools for detection, assessment, monitoring, and mitigation of compliance risks;
  • timely response to and integration of legislative changes into bank processes;
  • informing the Bank’s management about the compliance risk profile, adherence to limits and risk appetite for compliance risk.

Link to the presentation – Compliance Risk Management Policy

Code of Ethics

Code of Ethics  of PIVDENNY JOINT STOCK BANK PUBLIC JOINT STOCK COMPANY is a document which outlines the values and principles adopted by the Bank and its employees that allows the Bank to form a quality corporate culture, which customer trust, reputation, and successful long-term development of the Bank depend on.

Prevention of money laundering and terrorist financing

The Bank strives for a high level of compliance with legislation on prevention and counteraction to legalisation (laundering) of the proceeds of crime or terrorist financing and financing proliferation of weapons of mass destruction, requirements of sanctions imposed by the UN, the EU, OFAC, and the National Security and Defense Council of Ukraine. 

The Bank follows recommendations and research outcomes published by FATF, NBU and other competent public bodies and takes measures to ensure the proper functioning of the money laundering/terrorist financing risk management system, which is a part of compliance risk.

The Bank does not do business with clients who could use the Bank’s services and products for the purpose of legalisation of the proceeds of crime or terrorist financing, committing fraudulent activities, conducting illegal/unlawful activities/operations.

Link to the Prevention of Money Laundering and Terrorist Financing Policy  

Anti-Corruption Programme

The Bank does not tolerate corruption or fraud, avoids any risks associated with them, and takes all the possible lawful measures to prevent, detect and combat corruption, fraud and related activities (practices).

Link to the Anti-Corruption Programme.

Gifts Policy

In order to prevent and avoid situations where accepting/presenting gifts may lead to a bank employee committing a corruption offense, abuse of office, harm the Bank's good standing or come into conflict with the principles of corporate ethics and legal requirements, the Bank has put in place a Gifts Policy.

Management of conflict of interest

In order to ensure objectivity and impartiality of managerial decisions, which involves eliminating possible conflicts between an employee’s private interest and job duties, the Bank has put in place a Conflict of Interest Management Policy. 

Whitleblowing - Hotline

The Bank’s corporate values ​​include the importance of timely and open discussion of unacceptable behaviour or other violations in the Bank and their escalation. To this end, the Bank has introduced and operates an unacceptable behaviour whistleblowing system, which includes:

  • channels for reporting unacceptable behaviour in the Bank by clients, counterparties, employees, shareholders, and other interested parties;
  • a whistleblowing policy mechanism for reporting unacceptable behaviour in the Bank;
  • the procedure for reviewing/investigating reports of unacceptable behaviour in the Bank and taking measures based on the results of the review/investigation;
  • a protection mechanism for bank employees who report unacceptable behaviour;
  • a protection mechanism for a bank employee whose alleged unacceptable behaviour was reported;
  • a procedure for protection of data/documents during the review/investigation of reports of unacceptable behaviour in the Bank;
  • a procedure for notifying the Bank’s management about the status and results of review/investigation of reports of unacceptable behaviour in the Bank, measures taken as well as notifying the National Bank of Ukraine and law enforcement agencies about any confirmed facts of unacceptable behaviour in the Bank in accordance with the procedure and under the conditions provided for by the applicable laws of Ukraine.

Link to Hotline

The Bank expects its employees to perform their job duties in an honest, professional, and conscientious manner. The risk appetite is very low for behaviour that does not meet standards of corporate ethics. The Bank takes any violations of standards of corporate ethics seriously and takes all the reasonable measures to reprimand its employees who ignore or violate them.