The Company's officers and staff
adhere to the appropriate standards
of behavior in the workplace,
dealings with clients and other
stakeholders, the proper handling
and dissemination of corporate
information, as well as the proper
observance of regulatory policies
as embodied in its parent Bank's
Employee Code of Conduct.
The BDOUB Code of Conduct (“Code”) outlines the principles and policies that govern the activities of the institution, and to which all directors, officers and employees and those that work for the institution, its subsidiaries and affiliates, should read and follow.
These principles and policies reflect the values the institution subscribes to and promotes.
The implementing rules and administrative details are left to Management to issue and enforce.
Covered individuals or parties are responsible for maintaining ethical standards including accounting controls.
They are expected to comply fully with appropriate laws and regulations, as well as with the internal standards or policies and procedures.
They are not to use the institution's name improperly nor to
misrepresent it for personal gains or advantage.
All covered individuals shall not deliberately mislead
customers, the public or other colleagues by making false or misleading statements or by withholding information.
Anybody who becomes aware of any violations of law,
regulations or policies should report his suspicions to his superiors or to any of the designated office or individuals.
The institution's assets (physical, financial or intellectual) may be used only for proper purposes.
The institution is committed to fair employment practices and a work place free from discrimination, harassment (including sexual harassment) or intimidation of employees.
The institution is committed to a workplace free from drug use or sale.
The institution is committed to the safety of the employees and others in its premises.
Conduct Relating to Customers and External Constituencies
The customers, suppliers, competitors or other who deal with the institution and its related enterprises must be treated fairly.
Accepting and giving of gifts, including entertainment services or activities, are not permitted except as may be allowed by strict internal guidelines.
The institution strictly prohibits the acceptance of gratuities,
extraordinary commissions or any form of payment from customers or suppliers in exchange for favorable treatment or considerations.
Publications, speeches, media interviews and advertisements need appropriate internal clearance; this includes lobbying activities in support of any particular legislative proposals.
Due respect to the privacy and confidentiality of dealings with customers shall be strictly observed.
Certain transactions or information shall not be made available to groups or individuals within the institution where there may exist potential conflict on interest, more particularly between credit and investment operations.
Complaints from customers shall be handled with expediency in accordance with internal rules.
The institution will not make political donations that may be
interpreted as an attempt to encourage favorable treatment of the Bank and any of its subsidiaries, affiliates, directors, officers and employees.
Trading in the institution's and related entities' securities while in possession of material non-public information is not permitted and is considered illegal.
Real and perceived conflict of interest shall be avoided when investing in outside business activities or accepting Directorships.
Queries of complaints from stockholders shall be immediately referred to the designated office or officials.
Certain rules and procedures are enforced as regards the items enumerated below, and deviations from these standards shall be considered in the individuals' performance ratings:
Attendance and punctuality are expected from all concerned
(they not only make effective use of time but also reflect courtesy to others).
Integrity (honesty, professional behavior) is expected to be
observed in all dealings with customers, regulators, co-employees, and the public in general.
Engaging in fraud, directly or indirectly, connivance and
facilitation in committing fraud are totally prohibited.
Decorum must be observed to promote harmony and respect within the organization and in dealing with external constituencies.
Prescribed uniform shall be followed for clear identity and
loyalty; it also promotes the institution's image and values.
Loyalty which is the highest commitment to the interest of the institution is expected from all concerned.
Covered individuals are expected to refrain from moving
business away from the institution or encouraging others to leave the institution, even after the covered individuals' have themselves left the institution.
Office rules on use or custody of electronic facilities and other assets of the institution shall be strictly observed by all concerned.
The institution reserves the right to impose corresponding
sanctions and/or penalties for violations of the “Code”, which includes dismissal from service without prejudice to further legal, administrative or criminal charges depending on the offense.
From time to time, specific laws are implemented which require the special attention and strict observance by all concerned. All concerned, who shall be advised of such requirements, shall ensure their individual responsibilities are complied with.
Some specifics:
Bank Secrecy Act
Anti-Money Laundering Act
Customers Protection Act
(Approved by the Board of Directors per Resolution No.66-2007
dated 24 February 2007)
The Bank, in compliance with legal and regulatory requirements, maintains transparency of related party transactions between and among the Bank and its subsidiaries,affiliated companies, directors, officers, stockholders, related interests (DOSRI), and joint ventures.
BDO employs high ethical standards in its business dealings to ensure the integrity of its employees and the organization. The Bank does not allow the acceptance, directly or indirectly, of any gift, gratuity, favor, loan or any item having monetary value or any other form of compensation from business partners, clients, suppliers and other third party service providers in connection with a service that may, in any way, influence employees’ decisionmaking.
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