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.
1. Objective of Whistle Blowing Policy
A. Provide protection to the Bank and the staff via reporting the presence of any practices that do not agree with the code of conduct of the staff at the Egyptian Arab Land Bank as well as assist in detecting any illegal, unethical or unprofessional conduct or any conduct that violates the regulations in force at the Bank if it becomes possible to identify such conduct, and consequently enable the bank to take the appropriate procedure towards the foregoing.
B. Encourage the staff to report to the officials (Compliance Sector) upon the set out of any employee to commit a wrongdoing, as long as the policy of the Bank protects him if he reports an unacceptable conduct.
C. This policy aims to provide a safe means of communication to the employees to eliminate their fears and to reassure them that they will be protected from any retaliatory acts, or their exposure to harm as a result of reporting any illegitimate or unethical practices.
D. The objective of this policy is that we would work with honesty and sincerity pursuant to a set of values and principles that encourage integrity, transparency and accountability.
2. Scope of policy :
This policy applies to all employees at the Egyptian Arab Land Bank in all sectors and branches. This policy is in force as long as its application does not breach the local laws. The process of whistle blowing and the protection procedures shall continue even upon leaving work at the Bank for any reasons. The Compliance Sector must continuously peruse the reports on the violations committed at the Bank to study them and lay down the guidelines that prevent their occurrence in the future in coordination with the Operation Risk Department and the Inspection Sector to minimize illegitimate and unethical practices that occur at the branches and sectors of the Bank and promote the performance of the staff.
3. Defining unacceptable conduct :
By virtue of this policy, the following types of conducts shall be dealt with, considering them unacceptable
- Unethical, illegal, biased, fraudulent or corrupt conduct.
- Violating the staff code of professional conduct.
- Accepting incentives or funds from third party whether from inside or outside the Bank in return for providing any work with preferential or non-preferential terms.
- Harm, discrimination or any type of violations.
- Unsafe practices at work or causing environmental, health or legal risks.
- Other practices that may cause financial or non-financial loss to our bank or that are in conflict with its interests.
- Any breach to the law or instructions issued by supervisory entities.
- Any violation or errors in applying the policies or procedures endorsed by the management of the Bank that may cause financial risk or damage the reputation of the Bank.
Provided that the whistle blowing process would be built on documents or specified information and evidences without violating any ethical rules acknowledged at the Bank. It shall be imperative upon the management of the Bank to discuss the problems that surface within the scope of work in preservation to the reputation and the regularity of the wheel of work.
4. Whistle blowing :
- Upon gaining knowledge of any illegitimate acts, fraud transactions or any violation to the law, instructions, rules, policies or procedures ... etc., the employee shall use the designated whistle blowing form (enclosed), fulfill the required data and documents and send the form with the supporting documents to the Compliance Sector to study and lay down the required guidelines - in coordination with the Operation Risk Department -that will prevent the occurrence of violations in the future and promote the performance of the staff and the Bank.
- The officials at the Compliance Sector shall comply with the following :
A. Not to disclose the personality of the whistle blower except for maximum necessity.
B. The acceptance of the whistle blowing if the following terms are fulfilled :
- That the whistle blowing would be in writing and signed by the whistle blower.
- Sincerity and honesty in describing the conduct and behavior or the violating incident without exaggerations.
- The achievement of the general interest of the Bank would be the objective of the whistle blowing; i.e. it is not for personal interest.
- Submitting the evidence that establishes the violation supported by documents or facts.
- Preserving the personal privacy of the violator.
- Distancing from any retaliatory indications and signs (malicious).
C. The Compliance Sector shall receive the submitted whistle blows then will put them forward before a committee that is formed from the Compliance, Inspection, Human Resources and Operation Risk Sectors. The committee shall convene once every fortnight to examine and look into escalating the issue, subject matter of the whistle blow, or keep it on file. The works of the committee shall be endorsed by the Chairman of the Board of Directors.
D. Ensure that the investigations are conducted in a right way and at the right time and monitor the investigations at all their phases to guarantee their implementation satisfactorily.
E. Ensure that the appropriate rectification procedures are taken for the whistle blown subject matter and at the right time to reach satisfactory results.
F. Submit a quarterly report - in coordination with the Operation Risk Department - to the Chairman of the Board of Directors to comment on the nature, reasons and the volume of any grave violations that may have been committed, the directives and the satisfactory results reached and if there are issues that were reported and are still pending without reaching a result in their concern.
Whistle Blower Protection Policy
The Egyptian Arab Land Bank shall comply with guaranteeing the protection of the whistle blower to guarantee the encouragement of the staff to take the initiative by disclosing violations and reporting them pursuant to documents and specific information without violating any ethical rules acknowledged at the Bank. Causing harm to the whistle blower by any employee with good faith is considered violation to this policy.
* The protection of the whistle blower is achieved pursuant to the following :
- Providing the maximum degree of confidentiality.
- Concealing the identity and personality of the whistle blower.
- Moving the whistle blower to a different department or his obtainment of a leave.
- If the matter necessitates providing special protection procedures, the Compliance Officer shall escalate the matter to the management of the Bank or the Audit Committee to take the required procedures.
- If any employee participates in causing harm to the whistle blower, disciplinary measures shall be taken against him as this is considered violation to this policy.
* On the contrary, all disciplinary measures and legal deterrent proceedings shall be taken against the whistle blower if he submits a false or a misleading whistle blow.
* It shall be imperative upon the heads of branches/sectors to carry out the following :
- Ensure that this policy has been received by all employees and was signed.
- Assist the staff and encourage it to report unacceptable conduct.
- Ensure that the whistle blower is protected.
- Ensure that the whistle blowing process is not a malicious report or notice.
* It shall be imperative upon the Compliance Sector to keep the registers, reports and documents represented in the following for at least 5 years :
- The policy and any amendments that it undergoes.
- The whistle blowing reports pertaining to the whistle blown issue as well as the investigation, its results & any procedures taken.
- Copies of all reports submitted to the Audit Committee.
(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
* 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.
4. Respecting & supporting the Bank
Loyalty to the Bank is the axis of conduct of all employees who must pay full care and attention to the foregoing.
4.1 Respecting the Bank
- Declaring any fact or making any statement that may affect the regulations of the Bank and its rules or that my distort in its image or its reputation with its customers and the public in general must be refrained from at all times. This commitment shall continue even after leaving work at the Bank.
- Avoid taking party whether directly or indirectly in activities that may threaten the interest of the Bank, its image or reputation.
- The name of the Bank, its trademark and any form of intellectual property shall only be used for work purposes and pursuant to the standards in force in this concern.
- Upon gaining knowledge of any illegitimate acts or fraudulent transactions, learning of any circumstances, incidents or acts that may damage the interests of the Bank or its reputation with regards to integrity and honesty or knowing of any other breach or violation to these principles, this must be reported by the method determined in this document.
- If an internal or legal investigation with regards to the business of the Bank is conducted, everyone must participate and cooperate in this matter without discussing the issue with other parties.
- No retaliatory acts including threatening or attempting to impose such retaliatory acts must not be taken against any individual merely for taking part in the investigation.
4.2 Protection of data on the computer and using e-Networks
- All information posted and dealt with across the e-Networks of the Bank are its property.
- The use of the employee to the e-Networks could be monitored at any time without prior notice.
- Upon using or accessing data across the computer, the security information determined in the policies and standards of the Bank must be known and applied.
- Without limiting the generality of the above, we must maintain the following :
* The website security and the right of access confidentiality such as the username and the passwords.
* The inclusive use of the passwords by refraining from the deliberate use of the same password by another employee.
* The confidentiality & property of the documents, information and software of the Bank.
* The access criteria and the actual precautions for the computers.
- Upon using the e-Networks of the Bank, everyone must be knowledgeable of and apply the policies and the guidelines of the Bank in this field. Without determining the generality of the above, the following must be
* During working hours the e-Networks must be used to assume the duties related to work.
* That the information transmitted via the e-Networks agrees with the security and safety standards of the Bank.
* That the telecommunications across the e-Networks do not involve defamation or damage to the reputation, not aggressive or bear annoyance and threat, dot not contain illegitimate message, are characterized by decency and bear the meanings of respect.
* The computer systems at the bank must not be used for illegitimate purposes such as visiting indecent websites or websites containing undesirable materials, and that the rules of copyrights are not violated.
- Upon learning that the information security arrangements at the Bank were violated or that there are illegitimate attempts to access the computer systems of the Bank without permit, the management must be notified at once.
4.3 Relationships with mass media
Communications with the mass media shall be carried out via the spokesmen of the Bank only or any other person delegated to represent the Bank in dealing with the mass media according to the instructions of the Bank in this concern. Contacting any mass media or giving statements or information without a prior permit from the Bank shall be absolutely forbidden.
- All registers must clarify in full detail and with precision all accounting and financial transactions as well as the reports, invoices, accounting statements and entries and other documents. Counterfeiting documents, deleting any data that deal with the authenticity of a report, withdrawing unauthentic or false reports or submitting false data is forbidden.
- The soundness and authenticity of all information, reports, registers and any other documents that are sent to the Board of Directors, the auditors and supervisory and regulatory entities inside the bank and outside must be ensured.
- In case of gaining knowledge of the presence of error, misconduct, omission, negligence, false, counterfeiting or distortion in the preparation, evaluation, reviewing and auditing books, reports, registers and financial statements or any other documents of the Bank, such breach must be reported at once pursuant to the rules of the Bank pertaining to the report of breaches related to accounts.
4.5 No smoking policy
- Smoking is absolutely forbidden in all venues and branches of the Bank pursuant to the law except in the places designated for the foregoing.
- Drinking liquor in all venues and branches of the bank is also forbidden.
4.6 Using cell phone at work place
- All cell phones shall be put on the silent mode during meetings.
- Minimizing as much as possible the use of the cell phone during working hours.
4.7 Clothing system
- The professional spirit in appearing before third party must be acquired by the appropriate appearance and outfit.
- The staff shall comply with wearing coordinated attire with composed colors.
- Men shall comply with wearing ties and distancing from nonofficial outfits during work.
- Women shall comply with wearing outfits that suit the nature of work.
- Employees working in jobs that require a uniform shall comply with the foregoing.
5. Document application
5.1 Document scope of application
- The employees of the Bank by all their job grades including managers and the Board of Directors.
- Employees and workers by temporary contracts, trainees and providers of consulting services.
- These principles shall apply throughout the period of association of the persons mentioned above with the Bank or throughout dealing with it even after leaving work at the Bank.
5.1 Declaring & undertaking to respect the document
- All employees at the Bank must draw up a declaration attesting that they have received a copy of this document, the approval to abide by what is mentioned in it and the performance of their obligations by its virtue.
- The new employees at the Bank must also draw up the abovementioned declaration before assuming work as a condition for their employment.
- The declaration must be renewed whenever substantial amendments are introduced into the purport of this document.
5.3 Document application entity
The Compliance Sector is the entity responsible pursuant to the governance instructions issued by the Central Bank of Egypt for guaranteeing the application and implementation of this document effectively and uniformly.
It is the entity responsible for implementing the procedures required to guarantee that the employees are aware of the document, its purport and interpretation and that it will take the disciplinary procedures in case of breaching it. It is also responsible for proposing the introduction of amendments into it so as to always reflect the conducts required to protect the reputation of the Bank and its employees.
The objective of this document is to be a guide to all employees, trainees and workers by contracts and consultants with regards to the appropriate conduct upon performing their duties at the Bank.
- There are several available methods to obtain inquiries about an act that contradicts this document or inquire about the method of preparing a report on a case that looks suspicious and unusual or involves a breach to this document.
- The employees must send any inquiries pertaining to the application or interpretation of this document to their immediate superior, their superior's manager or the Compliance Sector as they deem appropriate pursuant to the circumstances.
5.5. Whistle blowing
- Whistle blowing reports shall be put forward before the Compliance Sector.
- The Compliance Sector shall comply with not disclosing the personality of the whistle blower except for maximum necessity.
- The Compliance Sector shall comply with accepting the whistle blow if it fulfills the following :
* That it would be in writing and signed by the whistle blower.
* Integrity, impartiality and distant from any personal effects.
* Sincerity and honesty in describing the breaching conduct and behavior.
* The achievement of the general interest of the Bank would be the objective of the whistle blowing.
* Submitting the evidence that establishes the breach.
* Preserving the personal privacy of the breaching party.
* Distancing from any retaliatory indications and signs (malicious).
- Any employee that whistle blows without complying with what is mentioned above shall be considered in breach to the provisions of these rules and shall be subject to the disciplinary procedures at the Bank.
- The Bank guarantees the right of protection from any arbitrary procedure to anyone who whistle blows in a right and correct form and who adopts all required steps and terms.
The employees that contradict this documents shall be subject to disciplinary or legal procedures pursuant to the penal regulations endorsed by the Bank.