Compliance & Governance

The Egyptian Arab Land Bank is seeking the compliance of all staff with the values, principles, morals and behavioral rules required to achieve the objectives and interests of the Bank and not to participate in any illegitimate activities that breach the law, such as theft, fraud, cheating and money laundering or any breach to the regulations and laws whether directly or indirectly in preservation to its reputation and the reputation of its staff. From this standpoint, all employees upon gaining knowledge of the presence of any illegitimate or unethical acts, fraud or learning of any acts, circumstances or events that may damage the interests of the Bank or its reputation or upon receiving information on any other breach must report it to the Compliance Sector.

The Compliance Sector shall comply with not disclosing the identity of the whistle blower to guarantee encouraging the staff to disclose such violations and report them, and provide protection to the whistle blower; taking into account that the process of whistle blowing is carried out on basis of documents or specified information within the framework of complete confidentiality.

(Set of Principles, Values & Rules Governing Conduct of Banks Staff )

1. About policy :


This policy aims to ensure the compliance of all employees with the values, principles, ethics and the behavioral rules required to assist in achieving the objectives of the Bank via providing support to the confidence and creating a good climate for work; as it is not sufficient for us to perform our work in a correct way only, but our conduct in performing our work - as well - must be right.


The general principles that this policy covers are represented in the following six principles :


A. Sincerity, integrity and honesty at work.

B. Applying the polices and regulations that regulate the flow of work.

C. Treating others with respect and equality.

D. Maintaining the confidentiality of information.

E. Avoiding conflict of interests

F. Respecting & supporting the Bank


It shall be imperative upon all staff of the Bank to peruse such principles and undertake to comply with them.


We point out that the principles of conduct mentioned in this policy are neither comprehensive nor complete, as they complement the internal regulations, systems, instructions and other rules that govern the conduct of the employee and by which all employees must be restricted at all times; nevertheless, this policy does not limit the rights of the bank's management towards its staff.


2. General directives :


The employees shall comply in dealing with each other with refinement. Hereunder is a reminder of some directives for example without limitation :


2.1 Place the interest of the Bank and its success at the priority of your concerns.

2.2 Place the service of the customer and its desires as main target.

2.3 Be frank, sincere and honest in your dealings.

2.4 Be responsible for your decisions and acts, admit your errors and accept blame.

2.5 Treat others with respect and apologize, if need may be.

2.6 Always be ambitious to high quality and fine level in performance.

2.7 Contribute to building an environment free from discrimination on basis of gender, nationality, faith, race or any unfair classifications.

2.8 Respect the job sequence and do not surpass your immediate superior regardless of how this may be necessary.

2.9 Pay attention to the requests of others and tell them - if you are busy - that you will satisfy their requests when you finish your work so that they would not think that you are ignoring them.

2.10 Help others if they request help, if this was possible and do not give promises that you cannot keep.

2.11 If you borrow something from someone, return it to him and do not give it to another person except by his permission.

2.12 Observe common sense in dealing with others, do not use ambiguous or indecent terms or vocabulary, do not speak in a loud voice and observe the temper and culture of those with whom you are dealing.

2.13 Treat your inferiors as colleague, your equals as friends and your superiors with respect.

2.14 If someone helps you thank him and show him your appreciation to his help.

2.15 Do not underestimate anyone and always remember that no human being is perfect and that if people unite they will complement each other (work by the team spirit).

2.16 Do not always complain at work; for as long as you have the time to complain you definitely have the time to find solutions.


3. General principles :


3.1 Sincerity, integrity & honesty


The work shall be performed with sincerity and honesty,and with respect to the reputation and privacy of others and the principles of equality, fairness and nondiscrimination.


3.1.1 Dealing with persons (natural and juristic) that deal with the bank :


- Relationships with persons (natural and juristic) that deal with the Bank are built on the principles of mutual sincerity and confidence. It shall be imperative upon all to deal with the spirit of honesty, integrity, efficiency, seriousness and diligence to respect such principles.

- Manifesting the spirit of professionalism, transparency and honesty in all communications with the customers of the Bank by providing full information without misleading or deceiving them directly or indirectly; whether this was deliberate or was a result of negligence, delinquency or lack of knowledge.


3.1.2 Relations with Board of Directors


- The information submitted to the Board of Directors must be correct, clear, precise and complete.

- The data, information and reports shall be submitted regularly on all activities of the bank, each within hiss competence.


3.2 Application of laws, policies & regulations regulating flow of work


3.2.1 Observing laws related to standing policies, regulations and procedures


- Observing at all times the stipulation and the spirit of the law and avoiding any negligence or delinquency that may lead to beaching the law.

- Reporting immediate upon gaining knowledge of any issue that result in damage, the breach of the law or such principles, policies, systems and procedures at the Bank.


3.2.2 Observing the procedures related to combating fraudulent acts, money laundering and terrorism financing


- Refraining from taking part in fraudulent acts, whether directly or indirectly.

- Not to participate in any illegitimate and law breaching activities such as theft, fraud and trickery; whether this was directly or indirectly.

- Not to allow, facilitate or participate in money laundering transactions whether by acceptance or finance, the exchange or the concealment of funds obtained from illegitimate activities, or related to terrorism financing in compliance with anti-money laundering and counter terrorism financing guidelines.


3.3 Treating others with respect & equality


Others must be respected, and dealing with the employees and the public in general must be carried out without discrimination. There is no room for indignity, partiality or nuisance in any form at work.


3.3.1 Staff treatment


- Working by the team spirit, supporting communication among all employees in a constructive and effective manner and exchanging the appropriate information upon performing tasks, while maintaining the confidentiality of information.

- Notifying the management of any act from an employee at work that involves the infringement of the dignity of another employee.

- Maintaining the sound and healthy climate that the Bank complies with providing to its employees, including their security and safety during their presence at work.


3.3.2 Dealing inside the Bank


The bank endeavors to provide a work climate that is free from all types of discrimination or frustration; where all procedures available are taken to guarantee that no employee is exposed to discrimination or nuisance to encourage the existence of a healthy and sound work climate, and harmonious and coordinated professional relationships that are based on mutual confidence and respect to guarantee the comfort and safety of its employees.


3.3.3 Dealing with the society


- The Bank endeavors to encourage the participation of social activities, whether, educational cultural, health or others, provided that this would not contradict the work at the Bank and the principles included in this policy.

- Not to participate in the abovementioned social activities in the name of the Bank except by its consent.

- Preserving the environment is an integral part of the social responsibilities and duties of the Bank and its staff.


3.4 Maintaining confidentiality of information


Maintaining the authenticity, confidentiality, security and privacy of the information related to the Bank, the accounts of its customers, members of its Board of Directors, the staff and the customers of the bank in general.


3.4.1 Maintaining confidentiality


- Maintaining confidential information and not disclosing it except in implementation to a law or an order from the court. Among such confidential information are registers, internal reports, procedures, documents, work plans, information technology devices and the software used at the Bank as well as the data of the Bank's customers, financial data, strategies and the methods and means used at the Bank, the agreements, audit reports and the personal notes on the files of the employees. These are all confidential and may not be disclosed without a specified order from the competent entity.

- The compliance with the policies pertaining to the protection of the personal information in force at the Bank as well as all polices and standards that govern the security of confidential information.

- Not to disclose any personal information that was obtained during the performance of work to any other parties or employees inside the Bank in application to the principle "Knowledge as Needed", including information on the customers of the Bank which must not be disclosed except in implementation to the law or court order.

- Always endeavoring to protect the personal and confidential information that was accessed; whether inside the bank or outside.

- Taking the required procedures to protect personal and confidential information and the following in

particular :

* Not leaving files or documents that contain personal or confidential information that could be accessed by irrelevant third party and place them in a safe place.

* Not to talk in public about the business of the Bank in a manner that exposes personal or confidential information to risk.

* Seeking caution upon using any information on the computer or via e-Communication methods.

* Maintaining the computers, electronic tools, portables and the information that they contain from theft or loss.

* Restrict oneself to the security procedures and criteria upon perusing or sending personal or confidential information by fax or e-Devices.

* Taking the appropriate arrangements to dispose of or to transmit documents that contain personal or confidential information to maintain their confidential nature (coding, shredding, archiving and others).


- Respect the confidentiality obligations mentioned above at all times to guarantee the privacy of personal and confidential information and continue the application of the foregoing after the expiry of the employment relationship with the Bank. In such case, all personal and confidential documents and papers related to work at the Bank must be returned.


3.5 Avoiding conflict of interests


The principles that the Bank lays down to avoid situations that could lead to conflict of interests must be complied with to maintain the confidence of customers in compliance with honesty and accountability at work.


3.5.1 Conflict of interests

The required procedures and arrangements must be taken to avoid any conflict of interests whether actually, probable or suspicious.


- The case of conflict of interests arises when the employee is in a position that necessitates him at the end whether directly or indirectly to select :


* Between the interests of the Bank or its customers and his personal interests or the interests of any person related to him in any way.

* Between the interests of two or more customers of the bank.

* In a position that may affect at the end his loyalty to the Bank or his decisions.


For example without limitation, the following in particular are prohibited :


- Disclosing or using any personal or confidential information to achieve personal interests or interests of other parties. This prohibition applies even after leaving work at the Bank.

- Benefiting from a specific position or situation inside work to achieve personal interest or the interests of other parties.

- Influencing or trying to influence the Bank's negotiations or transactions for a personal benefit or the benefit of other parties.

- Prejudicing or the undue preferential treatment of some parties at the expense of other parties.

- Running a business that could intertwine with working at the Bank.

- Assuming private work or works for the interest of third party with or without pay during official working hours or others except by a prior permit from the management.


* Carrying out the following works shall be prohibited except after obtaining a prior permit from the immediate superior :


- Using the devices or the services of the Bank's employees for purposes that are not related to the performing the work of the Bank; unless such use is reasonable and agrees with the internal regulations of the Bank.

- Assuming activities that are unrelated to the duties of work during working hours.

- Forming a partnership/or doing business with one of the customers of the Bank.


* Considering that it is not possible to lay down a comprehensive list of all cases and situations that could represent conflict of interests, upon the occurrence of conflict of interests whether actual, probable or suspicious, the issue must be reported to the immediate superior or the required inquiries as mentioned in this policy must be conducted.

When the employee is a party in such situation, it shall be imperative upon him to adopt the recommendations or directives issued in this concern by the officials at the Bank in connection with implementing this policy.


3.5.2 Gifts & entertainment


If an entity that deals with the Bank presents a gift or an entertainment to an employee or a person related to or close to him, caution must be taken before accepting it; taking into account that this would not directly or indirectly entail any effects on the interests of work.


Hereunder are the determinants for accepting gifts, compliments and entertainment :


* In principle, it is preferable that gifts, compliments or entertainments would not be accepted in avoidance of any suspicion.

* The motives and circumstances in which the gift or the entertainment are submitted must be neutral and legitimate.

* The value of the gift or the entertainment must be reasonable (symbolic).

* The gift or entertainment must not affect under any circumstance the decisions made by the employee or that he must make.

* The gift or entertainment must not lead to any feeling of commitment or undertaking towards the party presenting it.

* The gift or entertainment must not lead to an embarrassing situation to the employee or the Bank if the public gains knowledge of it.

* Cash gifts or gifts taking the form of cheques or precious metals (gold, diamonds, ...) must not be accepted regardless of the circumstances in which they are presented.

* The employee is prohibited from requesting or encouraging the presentation of gifts or entertainment from third party.

* Requesting or accepting a discount, secret commissions and bribes or other payments upon performing duties is completely forbidden. The employee must notify the management if any sort of the foregoing with regards to another employee occurs.