Integrated Report 2021


The norms of behaviour and ethical standards accepted in the BNP Paribas Group are set out in the BNP Paribas Code of Conduct. The document expresses our goal to be a respected European bank with a global reach and contains guidelines for all BNP Paribas Group employees.

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Code of ethics

You can read the Code on this site.

  • Protection of Customers’ interests,
  • Counteracting money laundering and terrorist financing,
  • Counteracting corruption,
  • Avoiding and managing conflicts of interest,
  • Preventing market abuse,
  • Counteracting all forms of discrimination,
  • Environmental protection and counteracting climate change,
  • Responsible conduct in public life.

Every employee receives mandatory Code of Conduct training. Thus, employees can familiarise themselves with the document and understand its priorities. The employees’ awareness of the expected attitudes is also increased through ongoing internal communication.

The Bank is actively involved in industry initiatives for ethics in business. For more information, please refer to the Business perspective chapter.

In 2021, in accordance with the requirements stated in the Recommendation of the Polish Financial Supervision Authority, the Bank’s Supervisory Board officially approved the Code of Conduct of the BNP Paribas Group, which has been in force at the Bank since 2016 and was previously adopted by the Management Board.

Other documents regulating ethical issues at the Group and Bank levels are listed in the Due diligence policies and procedures section of the current chapter.

Mechanisms for reporting irregularities

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The Bank has adopted a zero-tolerance policy for any type of fraud or attempted fraud by employees, Customers, counterparties and third parties. The Anti-Fraud Policy provides details on the division and principles of responsibility in this sphere.

The Bank has established units that provide advice on ethical and legal issues, as well as matters relating to the integrity of the organisation to all employees. These units include, in particular, the Compliance Monitoring Division and the Legal Division.

All employees are expected to familiarise themselves with international standards and comply with relevant laws, rules and regulations in all areas, as well as with professional standards that apply to their activities.

An important aspect of implementing the policy related to complaints and requests is the Whistleblowing process. The system launched at the Bank is an expression of concern for our employees’ well-being and abidance with the law. It defines communication channels through which potential violations can be reported to members of the Management Board and other employees.

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The Bank places particular emphasis on the anonymity of reports. Therefore, it provides:

  • Absolute protection of the identity of the reporting and reported parties; their details may not be disclosed to third parties unless there is a legal obligation to do so,
  • Treatment of reports with the utmost seriousness, fairness and discretion,
  • Verification of reports by authorised personnel to resolve concerns fairly and impartially.

In addition to the standard communication channels, direct communication with the dedicated Compliance unit (Group Financial Security US) can be used for incident reports regarding sanctions and embargoes.

Initiatives for industry responsibility

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We actively promote good practices in the Polish financial industry. In addition to internal initiatives and the implementation of adequate policies, we raise issues of responsibility, which are essential to our Customers and to us, on the industry forum.

Declaration of Responsible Sales

In Customer relations, we focus on ethics, empathy and an improved understanding of our Customers’ needs. The Declaration of Responsible Sales is devoted precisely to these issues. The document changes the approach to the daily relationship between the Customer and the financial institution.

Our Bank was among the initiators of this self-regulatory project for the financial sector. It aims to raise and disseminate ethical standards in Customer relations, educate businesses and consumers, increase trust in the financial industry and counteract unfair practices.

As a signatory of the Declaration of Responsible Sales, we are obliged to improve our processes and service models constantly. We undertake new initiatives aimed at enhancing the customer experience.

Key assumptions and initiatives within the project

  • Simple and transparent products.
  • Customer education
  • Fair price
  • Partner relationship with the
  • Transparent product description.
  • Products tailored to Customers’
  • Equal treatment and support.
  • Simple complaint process.
  • The Customer’s voice is the driving force for new initiatives.

Cooperation with the Banking Ethics Committee of the Polish Bank Association

The Bank’s experts are involved in industry initiatives to raise ethical standards within the sector. They also actively participate in the Banking Ethics Committee of the Polish Bank Association.

“Ethics in finance” competition

As in previous years, in 2021, the Bank became one of the six sponsors of the Polish edition of the Ethics in Finance Competition. The competition is organised by the Banking Ethics Committee in cooperation with the Financial Observatory in Geneva and is part of the global Ethics & Trust in Finance Prize project. Its goal is to promote ethical attitudes in the world of finance and to raise awareness of the importance of ethics in the financial sector by involving youth.

“Not-irresponsible” conference

For many years, we have been supporting subsequent editions of the “Not-irresponsible” conference, devoted to responsibility within the financial industry and in the business world. The topic of the 9th conference, held in hybrid form in October 2021, was: „Impurity. Behind the veil of business. In the heart of man.” Małgorzata Kamińska, Director of the Transformation and Development of Customer Experience Department, took part in a debate on responsible selling.

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