Our business is legal and we abide by the rules

The employees of the NLB Group are obliged to strictly respect the legislation and other rules prescribing requirements regarding our daily business. We avoid actions that could constitute an alleged or actual breach of prescribed rules.

The employees of the NLB Group analyse and manage risks related to compliance in internal organisation, decision-making processes, disclosure policies, internal reporting and reporting to external (supervisory) institutions. 

The NLB Group has been conducting procedures to discover and prevent money laundering, know your customer procedures and procedures for identifying and preventing financial and other crime – to which we have zero tolerance for these.

In the event of violations of legal provisions and rules related to money laundering or terrorist financing, the NLB Group may suffer damage to its reputation and may also be subject to financial and regulatory sanctions. Therefore, the employees of the NLB Group are obligated to:

• keep up to date with internal policies, rules and procedures to discover suspected money laundering and terrorist financing.
• use procedures and measures to respect sanctions and embargoes that prevent business with certain countries, groups of persons, companies, organisations and individuals, including those connected with terrorist activities, drug smuggling, nuclear weapon development and similar.

To successfully prevent and discover suspicious transactions, every employee who is faced with such transactions in the course of their work has to: act in accordance with internal documents of the NLB Group members and report such transactions to their superiors and the competent internal organisational units.

We at the NLB Group guarantee the highest standards of diligence in the management of confidential data and other information relating to individual members of the NLB Group, the entire NLB Group, the employees, customers and business partners. This is the only way to ensure the discretion of business relationships and build long-term trust.

Employees of the NLB Group are bound to duly protect confidential information, strictly confidential information and business secrets. There is zero tolerance for any events that could result in leaking or forwarding of confidential information, data and business secrets to unauthorised persons.

All employees are obliged to comply with the internal rules and procedures to protect all information and data disclosed to us in the course of our work. This obligation applies to all communication channels, social media, all types of media and means of communication.

Use of data

We may only use the data internally, for the employer’s business purposes.

Disclosure to external parties is permitted only if allowed by regulations or internal rules.

The employees of the NLB Group may not use for their own benefit or forward to any unauthorised third party any confidential information, strictly confidential information or business secret. Any data which could obviously cause material damage if submitted to unauthorised persons shall also be deemed business secret. 

The NLB Group has in place a strict ban on trading in financial instruments based on inside information and other forms of abuse of the market in financial instruments. The NLB Group is bound to protect the confidentiality of inside information on NLB d.d. or other issuers and uses such information only for the purposes for which it was disclosed.

What is inside information?

Certain confidential information is deemed inside information within the meaning of regulations on market abuse prevention. The employees who are disclosed such information, either in the scope of their work assignments or accidentally, shall keep this information strictly confidential and shall not trade on the basis of inside information.

The NLB Group has adopted internal documents establishing measures that prevent conflicts of interest, set up information barriers, ensure timely and transparent disclosure of inside information on NLB d.d., establish control over the implementation of personal transactions, provide regular training in abuse of markets in financial instruments and guarantee full cooperation with the competent regulators.

The NLB Group employees and other liable persons whom we cooperate with or who are included in the corporate governance system are obligated to fulfil their obligations as specified in the regulations governing personal transactions in financial instruments and to comply with the ethical standards, internal acts and rules of the NLB Group.

The NLB Group is committed to fair dealing on the markets where it operates. This includes: avoiding unfair sales and business practices, restrictive agreements, unfair competition and abuse of a potential dominant market position.

We are aware of the risks associated with restricting competition, so we operate in accordance with the applicable laws and internal rules that define our obligations regarding the protection of competition. It is our responsibility to keep up to date with and to act in line with the regulations on the prevention of the restriction of competition and to understand how the risk of unfair competition influences our work obligations.

All our actions and each decision have to be aligned with this Code, the legislation and other regulations applying to the members of the NLB Group, and with the applicable internal acts. We have to be well familiar with these documents and act in line with the instructions regulating the performance of our tasks.

It is our duty to provide accurate and comprehensive documentation about all our business activities.

Every member of the NLB Group plays a key systemic role in the discovery and prevention of money laundering. Money laundering and terrorist financing constitute a severe criminal act prosecuted ex officio. It is therefore the duty of employees, especially those who conduct business with customers, to adhere to the rules and procedures for preventing money laundering and terrorist financing on a daily basis and to identify concerns regarding potential (including future) non-compliance early on, as this is the only way to prevent violations.

When in doubt we refer to our superior or the internal organisational unit in charge of compliance.

Are you considering trading for own account based on the information obtained in the course of your employment? Are you planning to use your employment for personal gain?

The NLB Group has in force a strict ban on insider trading and market abuse.

In the event of a (potential) breach, we should immediately report thereon to the organisational unit in charge of compliance by use of the designated reporting channels in line with internal documents.

Information is crucial for preserving our competitive advantage. Employees in the NLB Group are responsible for the protection of secrecy and integrity as well as availability of information and data owned by members of the NLB Group, our customers, suppliers and other business partners. Therefore we have to comply with all internal rules and procedures and act so that this information and data are properly protected.