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The Global Policy Prevention of Bribery and Corruption aims to:

  • clearly articulate the commitment of UniCredit Bank d.d. as a member of the UniCredit Group, prohibit bribery and corruption, as well as respect the relevant laws on the prevention of bribery;
  • define principles for identifying and preventing potential bribery and corruption in order to protect the integrity and reputation of UniCredit Group;
  • clearly communicate the principles for preventing bribery and corruption, both to internal and external participants;
  • provide a framework for the Bribery and Corruption Prevention Program at the level of the entire Group.

The primary principles of the Policy are:

  • Zero tolerance for corruption
  • Commitment to the fight against bribery and corruption
  • Commitment to global compliance

 

Global Policy Prevention of Bribery and Corruption

 

Protection of persons who report corruption

The objective of the Code of Professional Conduct is to promote a culture of compliance, providing a description of the rules, standards, professional ethics and commitment to sustainability. The Code of Professional Conduct was drawn up in accordance with the values we cherish within the UniCredit Group, which are, above all, integrity, responsibility and care.

 

The Code of Professional Conduct sets out the principles that all UniCredit Group employees and related third parties must adhere to in order to ensure a high standard of professional conduct and integrity when performing activities for or on behalf of the Bank.

 

Therefore, it should be considered a point of reference, a source of information that enables drawing the line between acceptable and unacceptable behavior in everyday work.

 

Code of Professional Conduct

Information to clients/third parties about the possibility of reporting unacceptable behavior and the protection of persons reporting the same

 

UniCredit Bank d.d. as a member of the UniCredit Group, is dedicated to fostering a corporate culture based on ethical behavior and good corporate governance, and therefore recognizes the importance of applying Rules on which reports of unacceptable conduct by employees and third parties are based.

Unacceptable behavior refers to all actions and/or omissions made during work or those that affect work, which are or could damage or endanger the Bank/Group and/or its employees, including the following forms of behavior:

  • illegal, incorrect or behavior,
  • violation unethical of laws and regulations or
  • non-compliance with internal rules.

Unacceptable behaviors include, among others:

  • bribery and corruption;
  • money laundering;
  • violation of financial sanctions;
  • unethical or unprofessional business conduct;
  • violation of the law on protection of market competition;
  • insider trading and/or market manipulation;
  • bullying;
  • inappropriate sexual behavior;
  • violent behavior;
  • fraud;
  • misuse of confidential data of customers and the Company;
  • violation of local laws and regulations;
  • non-compliance with Bank and Group policies and procedures;
  • violation of the Code of Professional Conduct and/or other codes of ethical conduct;
  • other illegal or improper practices or conduct.

 

Reporting unacceptable conduct

Any client/third party who is aware or has a reasonable suspicion that persons operating within UniCredit Bank d.d. may have committed unacceptable conduct has the right to report unacceptable behavior.

Unacceptable conduct can be reported in the following ways:

or

  • by sending the report by post office to the Head of Compliance, with the indication "report of unacceptable behavior - do not open!" to the address of UniCredit Bank d.d., Kardinala Stepinca b.b, 88 000 Mostar.

Along with the report, the whistleblower submits material evidence from which there is a suspicion that unacceptable behavior has been attempted or carried out, if he is in possession of such evidence.

 

Whistleblower protection

The Bank provides the whistleblower with protection against any kind of retaliation, discrimination or punishment due to the submission of a report in good faith. Revenge and discrimination against the whistleblower is prohibited, and if the existence of such is established, disciplinary proceedings may be initiated against the responsible person.

The Bank guarantees the confidentiality of the personal data of whistleblowers, witnesses and the person in question (natural or legal persons named in the report or announcement as the person to whom the violation of the rules is attributed or to whom it is connected).

All information that the whistleblower shares when submitting a report, including the identity of the whistleblower, will be kept confidential unless the whistleblower consents to the disclosure of the identity and if the disclosure of the identity is necessary to eliminate or reduce a threat to the health or safety of the person.

 

Information on the processing of personal data for the purpose of processing reports of unacceptable conduct

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