Prevent unacceptable practices

The NLB Group has set up the standard of zero tolerance for illegal and unethical conduct and disrespect for values It has highlighted this standard as one of the fundamental principles that it pursues when conducting business.

The NLB Group rejects all types of bribery and corruption. These forms of actions are unfair, illegal and damage the countries in which the corruptive practices take place, and the society in general.

The NLB Group offers no bribes or inappropriate incentives for any purpose whatsoever, nor does it accept them. We expect and demand the same conduct from our clients, business partners and third persons.

Inadmissible acts are categorically rejected and actively prevented in our business.

All employees of the NLB Group are subject to limitations in giving and accepting gifts, offering hospitality and otherwise influencing the conduct of the employees of the NLB Group.

In addition to bribery and corruption, the NLB Group identifies as harmful behavior also fraud, abuse, counterfeit and all other actions that could result in regulatory sanctions, criminal liability, diminished reputation or integrity, and which have been committed to the detriment of an individual or all members of the NLB Group or their employees, customers and business partners.

We at the NLB Group believe that responsible corporate governance is more than just respecting the laws, regulations and standards. An important part of our operation is also the integrity and transparency of operations.

All employees of the NLB Group are thus expected to understand and accept responsibility for adopting the right decisions. The prevention of other harmful conduct is the responsibility of all employees.

If we notice any harmful conduct the employees of the NLB Group are obliged to immediately report our concerns and observations To this end, the NLB Group ensures independent internal procedures and processes for reporting irregularities.

Every employee is obliged to immediately report any information on anything that could present a violation or non-compliance with the regulations or internal rules, or harmful conduct. The NLB Group encourages the reporting of conduct in cases an employee is aware that something “is amiss”.

It is our duty to report inappropriate behavior without undue delay through one of the available communication channels of the designated person for reporting in the organizational unit responsible for business compliance. Employees can also anonymously submit information directly to the Executive Board or the Board of Directors. If we are not convinced that a potential action has the nature of misconduct, unlawful or unethical action, we may consult our superior or directly the organizational unit in charge of compliance.

We at NLB Group do not tolerate retaliation against whistleblowers who report misconduct and have a reasonable belief that the information is true, even if it later turns out that the reported conduct was not dishonest or unlawful.

During the processing and examination of individual reports, the data from the report are strictly protected, which ensures the protection of whistleblowers during the entire reporting procedure of disclosure and potential sanctioning of misconduct. We guarantee the protection of the identity of the person who reports improper behavior, as well as those to whom the report of improper behavior refers.

If somebody offers us a benefit to influence our conduct or action, that is a bribe. If someone wants to use their position to obtain benefit for themselves, that is corruption. An employee of the NLB cannot give or accept bribe. We may not participate or allow corruption in any form at any level. We must ensure that our actions and conduct do not give the impression that we are inclined towards bribery or corruption.

The risk of corruption can occur in any activity carried out in the NLB Group, whenever we are in contact with third parties. It has many forms: in the tenders and selection of suppliers in purchasing procedures, costs, gifts, hospitality, deciding on employment, sponsorships, donations, activities of our clients, and so on. We are obliged to carefully consider which activities can be exposed to corruption risks and prevent such actions.

Gifts that are absolutely prohibited to give or accept are rejected categorically. The NLB Group is aware that certain gifts of small value can be part of establishment or maintenance of a business relationship. If we receive such attention, the gifts or expressions of hospitality may in no way affect the business decisions we adopt.

In the case of suspicion as well as actual misconduct of our colleagues, customers, business partners and other persons, the employees are obliged to report such actions. Only if we are aware of this can we react swiftly and prevent damage or restrict damage that the employees or other members of the Group will have difficulties remedying.

To report irregularities, we use the established paths for reporting violations which guarantee our anonymity, or contact the organizational unit in charge of compliance.