In accordance with high standards of professional ethics and business practices, we have adopted the Code of Ethics. Based on it, we regulate relationships with all stakeholders in business – clients, employees, suppliers, and the entire community.

If there is a breach of the Bank's Code of Ethics, please report the complaint to the following email address: complaint@zapadbanka.me
complaint@zapadbanka.me

Code of Ethics of Zapad Bank

  1. SUBJECT AND OBJECTIVE OF THE CODE OF ETHICS
  2. The Code of Ethics of Zapad Bank AD Podgorica (hereinafter referred to as the " Code of Ethics ") constitutes a set of standards, ethical norms, and professional behavior in conducting business that employees of Zapad Bank AD Podgorica (hereinafter referred to as "employees") are obliged to adhere to. The aim of the Code of Ethics is to enhance the behavior of employees in accordance with basic moral principles and standards of professional conduct, as well as to promote corporate values.
  3. APPLICATION OF THE CODE OF ETHICS
  4. Employees are obligated to perform their jobs consistently by applying ethical standards and rules of conduct. An employee who is authorized to make decisions at Zapad Bank AD Podgorica (hereinafter referred to as the "Bank") when making decisions is obliged to act within the given authority, guided primarily by the Bank's interests.
  5.    
  6. USAGE OF GENDER-SENSITIVE LANGUAGE 
  7. Terms used in the Code of Ethics referring to individuals in the masculine gender include the same terms in the feminine gender.
  8. IMPARTIALITY AND POLITICAL NEUTRALITY 
  9. An employee is obligated to perform tasks impartially and politically neutrally. It is prohibited for an employee to wear and/or display symbols of political parties or bring propaganda materials into the Bank's official premises. Employees may engage in political activities solely in their personal capacity. Employees are prohibited from influencing the political orientation of other employees in the bank.
  10. PERSONAL AND PROFESSIONAL INTEGRITY 
  11. The Bank respects the right of employees to privacy. Personal information about employees is collected, processed, used, and stored only to the extent necessary to comply with legal and other regulations related to employment, work, and tax obligations.
  12. LOYALTY, PROFESSIONALISM, COURTESY, AND RESPONSIBILITY 
  13. An employee is loyal to the Bank and performs tasks responsibly, honestly, and efficiently according to professional standards. In relationships with clients, members of the Management and Supervisory Board, the secretary, and other employees, the employee is obliged to act fairly and with integrity, executing duties with appropriate skill, due diligence, and commitment. Employees are aware of the responsibility for breaching work obligations and the possibility of legal proceedings and penalties.
  14.    
  15. DEDICATION TO CLIENTS – SERVICE USERS 
  16. Employees perform tasks in a manner that, in accordance with the law, within established rules and procedures, ensures the realization of rights and obligations of service users - legal and natural persons (hereinafter: service users). If a service user is dissatisfied with the Bank's service, the employee informs them that they can file a complaint according to the Bank's procedure.
  17. INTERACTION WITH SERVICE USERS 
  18. In the execution of tasks and in relation to service users, employees:
  19. -act fairly, courteously, and politely, basing their attitude on objectivity, impartiality, and legality,
  20. -behave professionally and constructively, showing interest and patience, especially in dealing with inexperienced clients,
  21. -provide timely, fair, and accurate data and information in accordance with the law and other regulations,
  22. -adhere to the principle of equality, avoiding privileges based on political views, racial, national, ethnic, or social origin, or other personal characteristics and traits,
  23. -respect the personality and dignity of service users.
  24.    
  25. CONFLICT OF INTEREST 
  26. When an employee has a personal interest that affects or may affect the impartial and objective performance of tasks, a conflict of interest arises. This matter is regulated by the Conflict of Interest Management Policy.
  27. PERFORMANCE OF OTHER DUTIES 
  28. Outside working hours, employees must not perform tasks that are inappropriate or could jeopardize the reputation and interests of the Bank. In cases where an employee is unable to assess this on their own, they need to seek advice in writing from their supervisor or the bank's board.
  29. MAINTAINING PUBLIC TRUST 
  30. Employees should behave in a way that preserves and enhances public trust in the impartial and efficient work of the Bank. Outside working hours, employees will refrain from behavior that could negatively impact the Bank's reputation.
  31.    
  32. ACCESS TO INFORMATION
  33. Employees are obliged to provide accurate and complete information on matters for which they are authorized within the scope of their duties, unless disclosing the content of a document to which access is restricted by law.
  34. In the course of their duties, employees will not request access to information that is not necessary for their job, and they will use available information in the prescribed manner.
  35. BANKING SECRECY
  36. Employees shall, in accordance with regulations, safeguard data, documentation, information, and facts constituting banking secrecy, which are accessible to them in the performance of their duties.
  37. REPORTING UNETHICAL REQUESTS
  38. An employee who believes that they are being asked to act in a manner that is inappropriate, unethical, or otherwise inconsistent with the Code of Ethics, shall report such a request to the person responsible for compliance monitoring or the Bank's board of directors, and act in accordance with the law. Employees are obliged to report violations of the rules and principles of the Code of Ethics by other employees.
  39. GIFTS AND OFFERS
  40. An employee must not request payment for performing tasks for which payment is not prescribed. 
  41. Employees must not request or accept gifts, offered benefits, privileges, or provide any other advantage for themselves personally, their family, close relatives, friends, or other legal and natural persons with whom they have private, business, or political contacts and cooperation. 
  42. Employees must not offer or provide any privileges or gifts related to the tasks they perform unless authorized by law or other regulations.
  43. PROTECTION OF ASSETS AND RESOURCES
  44. Employees are responsible for effective and economical management and use of material and financial resources entrusted to them in the performance of their duties, as well as preventing their unlawful use. 
  45. Employees should take measures prescribed for the protection of entrusted work resources, equipment, and items and for eliminating the possibility of material damage to the Bank, in accordance with the Bank's internal regulations.
  46. SECTOR - DEPARTMENT HEAD
  47. The sector or department head points out shortcomings in an employee's work to the Board of Directors and the Supervisory Board for appropriate measures regarding actions that are not in line with the provisions of the Code of Ethics. Sector and department managers, the Compliance Monitoring Manager, the bank's secretary, and the board of directors set an example for proper ethical behavior through their personal conduct.
  48.    
  49. RELATIONSHIP BETWEEN THE SECTOR MANAGER AND EMPLOYEE
  50. The sector or department head, in relation to employees, should, in the performance of their duties:
  51. -act fairly and honestly, with due care and respect for the employee,
  52. -consider impartial advice,
  53. -provide protection against threats, attacks, and other actions that violate the integrity of the employee,
  54. -ensure the confidentiality of the employee,
  55. -dedicate themselves to professional education, skill improvement, advancement, work culture, and constant improvement of the social standard of employees,
  56. -ensure that the employee acts in accordance with the standards and rules of the Code of Ethics.
  57. EMPLOYEE'S CONDUCT TOWARDS OTHER EMPLOYEES
  58. In dealing with other employees in the performance of their duties, employees should:
  59. -provide necessary cooperation,
  60. -promote a working atmosphere and maintain proper relationships with their behavior,
  61. -not disrupt the workflow,
  62. -avoid actions that disturb other employees and have harmful consequences for the Bank's operations,
  63. -respect the personal and other characteristics of employees.
  64. CONDUCT WITH FORMER EMPLOYEES
  65. In providing services and access to information, employees must not provide privileged access to individuals whose employment has ceased at the Bank. An employee whose employment has ceased at the Bank is prohibited from using official documentation and Bank data for a period of 5 years after the termination of employment at the Bank.
  66.    
  67. EMPLOYMENT OUTSIDE THE BANK
  68. Employees must not misuse their job duties for employment outside the Bank. 
  69. Employees must not allow outside employment to cause any potential or actual conflict of interest, and they are obligated to disclose to the board of directors or the supervisory board any job offer that could lead to a conflict of interest. 
  70. Employees must immediately communicate their acceptance of a job offer outside the Bank.
  71. LIVING AND WORKING ENVIRONMENT
  72. The Bank is committed to actively and consistently protecting the living and working environment, aiming to preserve it for the needs of future generations. 
  73. Employees should be dedicated to improving conditions for work in a healthy living and working environment.
  74. DECENT DRESS CODE AND CONDUCT
  75. Employees are required to maintain the Bank's reputation through decent dress code and personal conducz.
  76. VIOLATION OF THE CODE OF ETHICS
  77. Employees are disciplinary responsible for violating the standards and rules of the Code of Ethics, in accordance with the law.
  78. FINAL PROVISIONS
  79. The Code of Ethics comes into effect on the day of adoption and applies from January 1, 2022. As of the effective date, the Code of Ethics dated June 4, 2015, is no longer valid.
  80.    ‍‍
  81. Chairman of the Management Board,
  82.     Vadym Morokhovskyy