First State Trust Bank Ethical Principles

OBJECTIVE AND SCOPE:  First State Trust Bank A.S. considers Ethical Principles as an integral part of adopted Corporate Governance Principles. Our ethical principles are integrity of rules to which we shall conform as related to our every kind of business and operations with our customers, our personnel and other banks and institutions.

The purpose of Ethical Principles is to ensure continuity of community’;s present sense of respect to banking profession, to maintain such sense of respect, which is named as profession pride, in a developing manner, to protect stability and confidence in banking sector and to emphasize top level service quality consideration which is adopted by First State Trust Bank .

DEFINITIONS
Below definitions, which take place in this text, mean as follows;
Bank: Is First State Trust Bank A.S.
Personnel: Is personnel of First State Trust Bank A.S.
Ethics: Is integrity of measures which examine values, norms, rules, which constitute basis for individual and social relations, from correct-wrong or good-bad points of view.
Professional Ethics: Is internal organization attitude culture, which brings certain rules for solution of problems which arise in and out of extent of the profession, while individuals of the profession group regulate relations with each other and with the community.


GENERAL PRINCIPLES

1. Ethical Principles constitute a part to Bank’;s Human Resources Policies and Procedures. All personnel and contract personnel are subject to such ethical principles. Personnel sign “Personnel’;s Commitment Related to Conformity with First State Trust Bank ’;s Ethical Principles” and thus, accordingly, undertake that he/she shall act in the extent of Bank’;s policies and procedures, and statutes and instructions and other regulations. Personnel, who act contrary to ethical principles, shall be subject to sanctions indicated in Bank’;s Discipline Procedure.

2. For the purpose to ensure efficient operation of banking system, to prevent transactions and applications, which may cause considerable damages for the economy, and as well as, to care for social benefits and to protect the environment, bank takes into consideration the requirements related to protection of rights and benefits of its customers, ensuring confidence and stability in financial markets, economical development, and carries out activities in line with below indicated general principles.
2.1. Honesty:  While performing its activities, it acts honestly and complies with professional ethical principles as related to its relations with its customers, personnel, shareholders, group companies and other institutions and foundations.
2.2. Objectiveness:  It first adopts the principle; “respect to human beings is the basis for success”, and acts in line with regulations and legislations and does not discriminate amongst personnel, it provides product and service of equal quality to all customers, it refrains from prejudiced attitudes and conflicts of interests, its approaches both to its personnel and customers are in fair manner.
2.3. Reliability:  It provides clear, comprehensible and correct information to customers during all services and operations in mutual understanding of confidence.
2.4. Transparency:  It informs its customer on issues, such as; rights and liabilities, benefits and risks, as related to products and services which are provided to them.
2.5. Care for Social Benefits and Respect for Environment:  Besides principle of profitability in all of its activities, it pays utmost care to give support for social and cultural activities in line with care for social benefits and respect for environment principles.
2.6. Fight Against Laundry (Acquitting) of Value of Riches Acquired Illegally: For healthy implementations in banking activities, it adopts fight against laundry (acquitting) of value of riches acquired illegally, improprieties and similar crimes as an important principle in the extent of both international norms and terms of national regulations and legislations, and pays care to cooperate both with its own people and also with other related institutions and foundations and competent authorities. It also takes necessary precautions in line with this purpose internally, and organizes education programs for its personnel.
2.7. Insider Trading: Bank takes every kind of necessary precautions to prevent usage of information obtained internally, in other words, so called insider trading.
2.8. Customers With Whom Banking Relations Can Not Be Established  :  It refrains from establishing banking relations with customers, who have low profile social reputation (customers, whose names are referred together with criminal issues, such as; illegal arms trafficking, environmental pollution, bribery, etc.). It does not take place in events, which would cause its name to be referred together with such customers bearing indicated character.

RELATIONS WITH OTHER BANKS

3. Exchange of Information:  Bank realizes honest and systematic exchange of information with other banks on every subject in the extent regulations and legislations allow, on the condition not to violate customers’; secrets and banking secrets.

4.  Conducts Related to Personnel
4.1. As related to personnel employment, Bank refrains from every kind of operation which would cause unfair competition.
4.2. Although there is contract and conduct freedom in personnel employment, it pays care that personnel employments are in moderate level and thus, do not interrupt other bank’;s services.
4.3. As a general policy, it does not make attempts, which are contrary to objective goodwill rules, such as; personnel transfer from other banks in groups or in teams, or transfer of personnel, who have benefited from educational programs provided by another bank, following end of such education period.
4.4. It acts in honest and straight-forward manner while responding to other banks as related to information requested by them about its ex-personnel.

5. Competition:  Bank considers competition as a race appropriate to regulations and legislations which ensures conclusion of liberal economical decisions amongst all banks in the sector. Therefore, besides the fact that it cares for its own benefits in its activities, which it carries out in free market economy, in the extent of below indicated principles, it also refrains from acts which cause unfair competition;
Such principles are;
• Generally to maintain continuous trust to banking sector,
• To work hard for development of the sector,
• To care for mutual benefits.
Such principles also include declarations and acts/behaviors of personnel.

6. Announcements and Advertisements
6.1. Bank acts in compliance with laws and general ethics, and in an honest and realistic manner for announcements, proclamations and advertisements related to its own financial structure and also to promotion and marketing of banking products and services. It refrains from every kind of statements and images which may be harmful to banking profession’;s esteem, which may create suspicion as related to its management and which may give an impression that it provides more security as compared to other banks.
6.2. Its’; announcements, proclamations and advertisements do not contain statements or formulations which would run down other banks or other banks’; products and services.
6.3. It pays utmost care that advertisements do not reflect a character which would mislead customers, which would humiliate other banks or which would exploit their lack of experience and knowledge

RELATIONS WITH CUSTOMERS

7. Informing Customers: Bank conveys complete and timely information as related to every kind of products and services which it provides to customers, on every stage of service relation and about every subject, as complying with restrictions indicated in regulations and legislations. It refrains from providing incorrect or deficient information to customers in connection with aiming profit.

8. Customers’; Secrets: Bank is obliged to keep secret every kind of information and documents belonging to customers and to conceal them, other than information and documents which should be handed over to authorized people and to competent authorities according to regulations and legislations.

9. Service Quality
9.1. Bank considers service quality as preliminary stipulation to meet customers’; requirements and expectations only by means of quality service to be provided. It works hard to develop its technological infrastructure and well-qualified human resources, which are two basic elements of this concept.
9.2. It provides service of same quality and of same level to all its customers, without favoring any sort of discrimination, such as; nationality, religion, financial and social status, sex, etc. Only, determination of target market and increasing the variety of organizational structure and product range in line with target mass of people, and to refrain from collaboration with customers, who are found risky in the extent of risk management, should not be interpreted as discrimination between customers or as categorization of customers.

 

10. Customer Complaints
10.1. It is all Banks’; personnel’;s responsibility to examine, evaluate their customers’; every kind of complaints and to respond to them as such complaints are concluded.
10.2. Bank investigates the reasons of customers’; complaints and takes necessary precautions to prevent repeat of rightful complaints. It informs its personnel in line with improvement of erroneous operations which cause reasons for complaints and for the purpose to prevent that such erroneous operations are not repeated.

11. Security
11.1. Bank agrees that, the concept “security”, besides physical protection of service environment belonging to customers and to the bank against every kind of negativities, also includes prevention of every sort of violation which may cause technical damages for services provided to customers.
11.2. Due to services improved in line with technological developments and electronic banking and modified service channels, it takes all necessary technical and legal precautions to ensure operation security and to prevent unjust treatment for customers in every kind of service environment. It informs its customers about the issues related to precautions taken and issues to which customers should pay attention.
11.3. It takes every kind of precautions – insurance at the first place – against risks, which may affect its financial status, and which arise due to personnel abuse or negligence, crimes of informatics and every kind of indemnity obligations.

RELATIONS WITH PERSONNEL

12. General Qualifications of Personnel: Bank pays utmost care that its personnel are constituted of individuals, who pay attention to protect reputation of the institution and sector, at which he/she practices, in the community, and who have the knowledge, experience and responsibility which their missions require.

13. Employment and Career Improvement
13.1. It pays utmost care to ensure equal opportunities for all bank’;s personnel, without favoring any discrimination, both during employment stage and also during career improvement, in the extent of personal capability and career planning.
13.2. Bank acts in line with the principle to steer human resources in the best way, and in order to make its personnel reach the current knowledge level which the banking profession requires, supports them by means of providing opportunities for them, such as; education, courses, seminars and similar events.
13.3. As regards to professional career improvement of Bank’;s personnel, it considers care for devotion to Bank’;s Ethical Principles as criterion for its evaluations, as well as knowledge, capability and personal success.

14. Principles for Representation and Working Environment
14.1. It establishes internal regulations to ensure that Bank’;s personnel are clean and well dressed up as appropriate to reputation of banking profession and that they are aware that they represent the bank.
14.2. Bank takes precautions in line with efforts to increase personnel’;s motivation in all service units and to provide service under better conditions, and ensures formation of a healthy and secure working environment.
14.3. Bank pays utmost care to employ number of personnel as appropriate to business volume, organizes its personnel as to obtain maximum efficiency within working hours, works extremely hard to ensure that working hours are not exceeded and that annual vacations are taken on regular basis.

15. Personnel’;s Relations with Customers
15.1. It realizes internal regulations to prevent Bank’;s personnel;
• Go in relations inappropriate to ethical principles with customers, such as; debt- receivable, suretyship and opening mutual accounts,
• Offer valuable gifts to present or potential customers,
• Obtain personal benefits both through their own working environment and also through their customers’; business opportunities, by using their professional positions.
15.2. All loan operations, to which family members or relatives of personnel are a party, shall be carried out by other employees.

16. Professional Rules and Ethical Principles which Personnel have to Comply with
16.1. Bank’;s personnel are obliged;
• Not to act contrary to principles of justice, correctness, honesty, reliability and social responsibility,
• To comply primarily with Banking Law and related regulations and also with internal and external regulations and legislations, while fulfilling the tasks which they are entrusted with,
• To maintain equitable relations with other personnel, to be in cooperation with other employees in the process to reach mutual targets by means of team spirit to be created in the bank,
• To refrain from acts which may damage Bank’;s esteem and reputation, also to take necessary precautions in order to prevent occurrence of potential actions,
• Not to make attempts for the purpose to aim support for any political group or candidate, not to take place in political process as company’;s representative, not to attend political caigns to raise money or other caigns or not to use company’;s corporate body, name for such activities,
• To realize their personal and financial issues in a responsible manner and to keep them under control  (e.g. not to incur a debt which they are unable to pay back),
• To act in maximum level of professionalism in the extent of their responsibilities related to their own tasks, in order to meet needs of customers and people in internal organization, and to work in an efficient and productive way as to reach their own personal targets and targets of the management and the company and as to meet customers’; needs,
• Not to disclose information and data, which they have obtained while carrying out their tasks, to third persons in any way, other than authorized persons or institutions as indicated in laws and statues/instructions, and not to use such information and data for speculative purposes  (directly or through intervention of third persons),
• To inform customers fully and in a clear manner about issues, such as; rights and liabilities, benefits and risks related to products and services provided to them,
• To provide impartial and equitable service to customers who receive same type of service,
• To dress up clean and in a well-cared manner as appropriate to reputation of banking profession and in the way that they are aware that they represent the bank,
• To act economically in using bank’;s assets and resources, not to use them in an inefficient manner and beyond the purpose, to ensure that necessary precautions are taken in relation to prevent every kind of potential/present risks which may cause loss of assets,
• To be responsible for having the capacity to give explanations as related to duties they are entrusted with, during the realization of services,
• Not to be assigned to a duty at any private and public establishment without the consent of their bank, other than associations, foundations, cooperatives and similar organizations,
• Not to carry out activities which would be deemed as “Commercial Business Enterprise” or as “Tradesman’;s Enterprise”,
• Not to carry out other activities which bring income without the prior consent of the Bank, and not to demand extra payment for services rendered out of normal working hours. Terms of Bank’;s Discipline Procedure are kept reserved.
16.2. Bank ensures fulfillment of all requirements as regards to personnel’;s rights related to current Labor Law, as timely and complete.
16.3. Determination of Incongruities and Sanctions:  If Bank’;s personnel’;s operations or actions contrary to ethical principles are determined, necessary sanctions shall be applied in the extent of Discipline Procedure. It does not remove the requirement for the bank to apply sanctions, if acts contrary to ethical rules, at the same time, also constitute crime according to laws.

RELATIONS WITH PUBLIC INSTITUTIONS AND ESTABLISHMENTS

17. As related to its relations with public institutions and establishments, Bank acts in line with honesty and transparency principles, and pays utmost care to submit information, documents and records in correct, complete and timely manner, which are requested for audit and control purposes, in accordance with regulations and legislations.

18. Bank pays utmost care that relations with the state and state establishments are maintained by persons, who are officially entrusted to manage such tasks.

IMPROVEMENT OF BANKING ETHICAL PRINCIPLES

19. Notification Policy
19.1. Our bank supports and encourages our personnel, who have witnessed that any of our employee performs an application or attitude contrary to principles of ethics, to notify such performance, even if subject application is realized by a top level manager or by his/her colleague. The extent of notification policy is as follows :
• Infringement of ethical attitude rules,
• Acting contrary to Bank’;s policies and procedures,
• Violation of laws and statues,
• Events of bribery,
• Situations which harms Bank’;s reputation,
19.2. None of our Bank’;s manager or personnel can threaten, harass the employee who has made the notification, lower his/her title, suspend his/her mission or apply discrimination of any kind to this employee.
19.3. Our Bank shall investigate all notifications, open or not signed, and shall inform our employee about the outcome.
19.4. Our Bank shall ensure that the name of our employee, who has made the notification, is kept as confidential; unless such employee’;s clear consent is received. Under ordinary conditions, such notifications shall not be conveyed to competent authorities, before extensive investigation is not completed and before our employee, who has made the notification, is informed
19.5. Such policy does not cover “personal complaints”, where different policies shall be applied, and subjects of “Human Resources Department”.

20. Notifications for Infringements
20.1. Our personnel, who wish to make notifications about persons who act contrary to ethical rules which take place in this regulation, should, before all else, inform their affiliated managers.
20.2. In the event, the person, who has performed the infringement, is the manager of the notifying employee, such infringement should be notified to Human Resources Management as “personal complaint”, and to Audit Committee, if a situation “specific for the establishment” is in question.
20.3. In order to protect our establishment’;s reputation, it is personal responsibility of all of our personnel to notify any suspicious situation.

21. Bank’;s Management is always open to personnel’;s opinions and proposals, as to ensure continuous development of Ethical Principles. It may share modifications and rehabilitations, which it finds appropriate, with other banks through Banks Association..

COMPLIANCE WITH LAWS

22. Compliance with Laws and Regulations:  It is personnel’;s responsibility to be aware of all laws and regulations which affect Bank’;s activities. Compliance Unit shall give support to personnel on this subject. Personnel, at the same time, are obliged to act in compliance with such laws and regulations, and also have to ensure that legal regulations and legislations are an integral part of regulations related to products and services of our Bank. Products and services, which are not found appropriate by legal authorities, can not be presented to customers, even if such products and services are profitable for the Bank.

VALIDITY

23. This document, which includes ethical values, becomes effective following the approval of Board of Directors.

 
 
Our Commitment to Privacy

First State Trust Bank Privacy Statement

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