"PIRAEUS BANK ICB" JSC is a subsidiary of Piraeus Financial Holdings S.A. (Greece), which in its activities adheres to the highest standards of compliance - legal requirements, market standards, corporate ethics, rules of fair competition and prevention of conflicts of interest.  
To ensure an effective compliance system, the bank has established a separate structural unit - the Compliance Control Department, whose activities are to organize the mitigation and/or providing recommendations for avoidance of compliance risk in the following areas:

• preventing legalizing proceeds from crime and preventing terrorist financing
• eligibility of customers in terms of compliance risk eligibility
• protection of customers’ personal data / bank secrecy
• preventing abusing internal information and preventing market abuse
• Code of conduct (ethics)
• external employment of bank’s employees
• gifts and participation of the bank’s employees in external events
• marketing and sales
• customer service
• transparency in offering products and services
• customer complaints
• conflicts of interest
• consumer rights protection
• compatibility of new products and services with the current regulatory framework
• outsourcing (critical/non-critical).

The entire Compliance system is aimed at consistent, effective and clear compliance risk management, which the bank is exposed to in carrying out its activities and at ensuring compliance with the Bank's risk appetite for compliance risk (Risk Appetite Statement)".

• Law of Ukraine «on Prevention and Counteraction to Legalization (Laundering) of Criminal Proceeds, Terrorism Financing and Financing of Proliferation of Weapons of Mass Destruction»No. 361-IX of 06.12.2019.
• Resolution of Board of the National Bank of Ukraine «on Approval of the Regulation on Financial Monitoring by Banks»No. 65 of 19.05.2020.

Piraeus Bank has developed a Code of Conduct (ethics) in order to comply with the highest standards of business ethics. The Code defines the basic corporate values and is the basis of corporate culture, which is supported by law and created on the basis of ethical principles. Adherence to clear and transparent rules of conduct set out in the Code protects the business reputation of the Bank and its employees, provides favorable working conditions, affects relations between employees.

OUR CORPORATE VALUES

The «Corporate Values» lie at the core of the Bank’s actions and decisions. They reflect the principles of doing business and ensure the implementation of strategy and building up of an impeccable business reputation.

The Conflict of Interest Prevention Policy was adopted by the Bank in order to perform its obligations regarding the maintenance and implementation of efficient administrative procedures and control mechanisms for identifying the existing or potential conflict of interest and its management during service provision.

The «Сonflict of interest» may arise during the provision of a certain service, performance of a financial transaction, or on a constant basis. Should the conflict of interest harm the interests of customers or the Bank, the main objective of the bank is to identify and manage such situations in accordance with the provisions of applicable legislation.

In order to ensure control over the timely detection, prevention and settlement of conflicts of interest, the bank has introduced a Policy for the Prevention of Conflicts of Interest.
"Conflict of interest" should be understood as existing and potential conflicts between personal interests and job or professional responsibilities of the Bank's employee, which may affect the conscientious performance of their duties, objectivity and impartiality of decision-making.

 CHANNELS FOR INFORMING ABOUT VIOLATION (personally/anonymously, with no risk of punishment):

• official website of the Bank (notification about violation) 
• messages to the electronic address: whistleblowing@piraeusbank.ua
• messages to the electronic address: compliance@piraeusbank.ua
• call using autonomous telephone numbers:

+38 (067) 217-99-96 – Chief Compliance Officer (CCO)
+38 (067) 214-46-93 – Compliance Control Department’s employees”.