Anti-corruption

We have zero tolerance for all forms of corruption, including accepting, offering, requesting, giving or agreeing to additional benefits, items or advantages.

The Bank’s anti-corruption system is based on:

• internal regulations specifying the method of operation and reporting corruption incidents to the appropriate organizational units of the Bank,

• training employees to increase their awareness and show paths of action in specific situations,

• operational control as part of the implemented internal control system.

The Bank continuously evaluates the management and control system (procedures, reporting, controls, training) implemented in order to counteract corruption. Appropriate internal regulations in this respect are implemented and updated on an ongoing basis, risk mapping and analysis of information on corruption from reporting are centrally supervised. The Managing Director of the Compliance Division appoints a person acting as Corruption Prevention Correspondent, whose tasks include coordinating anti-corruption activities.

Within the anti-corruption activities, the Bank monitors, among others: indicators concerning reported cases of fraud, identified conflicts of interest, accepted/transmitted gifts and invitations, due diligence in establishing relations with Clients/contractors/intermediaries, level of employee awareness.

We expect our business partners (suppliers, contractors, subcontractors working with the Bank and its Clients on behalf of the Bank) to act in accordance with the principles set out in the Anti-Corruption Policy. An anti-corruption clause is an integral part of each agreement concluded by the Bank with its business partners.

The Anti-Corruption Policy, similarly to all other policies and procedures in force at the Bank, is available in the Intralex internal system. Every employee of our Bank has the opportunity to read the document.

Other binding policies on anti-corruption:

• Rules of accepting and giving presents by employees of Bank BNP Paribas S.A. – describe in detail the process of accepting and giving gifts. According to them, employees may under no circumstances make the scope of services provided by the Bank or the products offered dependent on potential personal benefits obtained from Customers. In particular, it is forbidden to solicit a gift from the Customer. It is unacceptable to accept or give presents that may affect the impartiality and independence of decisions. The rules describe the process of giving presents to persons performing public functions.

• Policy on notification of a non-compliance incident at BNP Paribas Bank Polska S.A. – gives employees the opportunity to submit a notification of the occurrence or possibility of a non-compliance incident, including an act of corruption, in a manner independent of all other methods described in other banking regulations.
• Code of good practice for employees of BNP Paribas Bank Polska S.A. – in commercial relations with contractors. According to the document, employees commit to guarantee fair competition.
• Regulations on conflict of interest management at BNP Paribas Bank Polska S.A.

In addition, the Corruption Prevention Correspondent prepared anti-corruption workshops for selected units of the Bank. IT solutions are also being prepared to enable more effective monitoring of key corruption indicators.