Dear colleagues,
Trust is the foundation of every good relationship. In banking it has a special value, because our clients, business partners, shareholder and the community entrust the Bank every day with what matters to them.
Trust is not built with grand words, but by the way we work, decide and treat one another and the people we work with every day. That is why the way we do business is just as important as the results we achieve.
Over the years, Nova banka has built a reputation as a reliable and responsible domestic financial institution. That reputation was created and is safeguarded by the people who work at the Bank. Every decision we make, every conversation with a client, every business relationship and every action shapes the image we create of the Bank.
That is precisely why the Code of Ethics is not merely a set of rules. It is an expression of the values on which we want to build our Bank, and a reminder of the standards we expect of ourselves and of one another. It gives us guidance on how to act responsibly, professionally and with integrity, especially in situations where the choice is not always simple.
We expect every employee to respect the laws, internal acts and the highest standards of professional conduct, and also to understand the broader meaning of what we do. To protect the interests of clients and of the Bank. To respect our colleagues. To recognise and avoid situations that may compromise our integrity or reputation, and to have the courage to speak up when something is not right.
Our responsibility does not end with compliance with the rules. It implies personal integrity, responsible decision-making and a willingness, in situations where we are not sure, to seek advice and act in the right way.
Managers have a special responsibility. By their example they show every day the kind of culture we want to build. A culture of integrity starts at the top, but it is built by the actions of every individual.
We are building Nova banka as an institution that is trusted, not only because of what we achieve, but also because of the way we achieve those results.
That is why this Code must run through our daily work, because the Bank’s reputation is our personal mark, and the trust we have built together is our shared responsibility.
Thank you for everything you do to make Nova banka a bank that is trusted.
Siniša AdžićPresident of the Management Board
The Code of Ethics is the primary, fundamental system of ethical rules of Nova banka a.d. Banja Luka, and it supplements the provisions of the Law on Banks of Republika Srpska, the regulations adopted on the basis of that law, the standards and rules of the banking profession and other internal acts (hereinafter: the Code and the Bank).
It contains the basic ethical principles and rules of business conduct, based on the vision, mission and values of the Bank, ensuring a professional attitude towards all employees, users/clients and business partners, as well as compliance of operations with laws, other regulations, the Bank’s internal acts, a good business reputation and the Bank’s role in the market.
The purpose of the Code of Ethics is to establish standards and a framework for carrying out everyday business activities at the Bank, ensuring reliability and good governance, compliance of work with legal regulations and internal acts, and business conducted in accordance with the highest professional and ethical standards of management.
The Bank expects its employees, even in situations that are not specifically regulated by the Code, to behave professionally, conscientiously and consistently, in line with the highest standards of responsible conduct, and, in performing their duties, to respect and apply the Bank’s applicable regulations and to act in accordance with the principles set out in this Code.
As the Bank’s primary system of ethical rules, the Code of Ethics is supplemented by the provisions of statutory and secondary legislation and by the Bank’s internal acts.
Ethical rules are the direction to be followed in carrying out everyday tasks, in relations with colleagues, business partners and other stakeholders, in line with the Bank’s good business reputation and its role in the market.
The Bank’s management is particularly committed to ensuring lawful business, which means respect for all relevant regulations, the Bank’s internal rules and contractual obligations.
Among the Bank’s most important achievements is a good business relationship with clients and business partners, which is the result of the work of qualified and dedicated employees who observe ethical standards in performing their work.
The Code of Ethics is intended for all employees of the Bank, regardless of the business roles, functions and jobs they perform, including members of the Bank’s governing bodies. All employees are obliged to familiarise themselves with the Code of Ethics, understand it and align their activities with it. The Bank supports and encourages its employees, as well as its business partners and users/clients, to follow the established ethical standards.
The Code helps situations that are contrary to the Bank’s ethical principles to be noticed more quickly, and it provides information on what to do when there is doubt as to whether certain behaviour is ethically acceptable.
Professional and ethical management standards are the rules, recommendations and best business practices that ensure reliable and good management of the Bank, compliance of operations with laws, secondary legislation and the Bank’s internal acts, and that particularly contribute to adequate management of the Bank’s risks, including operational and reputational risk.
The Code defines acceptable and unacceptable behaviour of all employees, and establishes a policy of zero tolerance for the actions of individuals that may have a negative impact on the Bank’s reputation or that are unacceptable from a legal, moral or ethical point of view.
The Bank is obliged to ensure regular monitoring of the compliance of all employees’ conduct with the Code and with the standards of corporate culture and risk culture.
A conflict of interest at the level of the Bank is a circumstance or set of circumstances that threaten or may threaten the interests of the Bank, among other things because of the different activities and business of the Bank, members of the banking group, other persons in a special relationship with the Bank and persons related to them, business lines or organisational units of the Bank, in relation to clients, shareholders, employees, significant suppliers, the Bank’s business partners and other relevant persons.
A conflict of interest at the level of an employee is a circumstance or set of circumstances in which the personal interest of an employee of the Bank or a member of the Supervisory Board affects or could affect the impartial and objective performance of the tasks and responsibilities of that employee or member of the Supervisory Board in relation to the interests of the Bank.
When assessing a conflict of interest, all circumstances defined in the Conflict of Interest Policy must be taken into account.
An employee is obliged to avoid circumstances and conduct that could lead to a conflict of interest. In carrying out their activities and in decision-making, every employee is obliged first of all to take into account the interests of the Bank and to subordinate all personal interests to the interests of the Bank, that is, they must not exploit the Bank’s business opportunities for their own account or for the account and in the name of a person with whom they have common interests.
Every employee is obliged to inform their immediate manager without delay of the existence of circumstances that could give rise to a suspicion of a conflict of interest. If a conflict of interest, or circumstances that could lead to a conflict of interest, has been identified, the Bank is obliged to take appropriate measures to eliminate it or to establish control over the circumstances that could lead to a conflict of interest.
The Supervisory Board of the Bank, on the proposal of the director of the Compliance Monitoring Sector and AML and CFT, adopts this Code and ensures its application. Before adoption, the Code of Ethics is submitted to the Management Board of the Bank for information.
The Management Board of the Bank is obliged to ensure that members of the Bank’s governing bodies and employees are familiar with the adopted standards of corporate culture, the Bank’s values and risk culture, its risk appetite and risk-bearing capacity, the Code of Ethics and the rules for preventing conflicts of interest at the Bank, and all employees (identified employees and other employees of the Bank) are obliged to adhere to and work in the spirit of these values and standards.
All employees of the Bank are obliged to be familiar with and to respect the provisions of the Code of Ethics in their daily work, avoiding any inappropriate behaviour and any departure from them. The internal acts that prescribe the above are transparent and available to all employees.
Members of the Bank’s governing bodies are obliged, by their behaviour, to encourage an adequate organisational culture that gives priority to the professional, honest and conscientious performance of business activities at all organisational levels, and to clearly defined, transparent and consistently applied levels of responsibility and authority within the Bank’s organisational structure.
The Bank’s governing bodies are obliged to apply professional and ethical management standards in order to achieve a balance between the interests of the Bank, the Bank’s governing bodies, users/clients, creditors, shareholders, employees, regulatory bodies and other stakeholders.
The compliance monitoring control function is responsible for monitoring and assessing the risk of compliance with laws, recommendations and regulations, and for the mutual consistency of the internal acts that define this area. The compliance monitoring function is also obliged to report regularly, and at least once a year, to the Bank’s governing bodies on compliance of conduct with the Code and with the standards of corporate culture and risk culture, including the identification of potential breaches and reporting on non-compliance issues. If the compliance function identifies significant irregularities and deficiencies, it is obliged to inform the Supervisory Board immediately.
The risk monitoring control function is responsible for supervising the functioning of risk management methods and procedures.
The internal audit control function is responsible for assessing the adequacy and effectiveness of the system of internal controls in this area.
This is an integral document of the corporate family that makes it possible to achieve the highest business objectives in accordance with all applicable laws, rules and regulations and the highest standards of business integrity.
The Bank adheres to good business practice and the highest ethical standards of doing business in the market, ensuring consistent application of laws, other regulations and internal acts. All employees of the Bank, as a member of the corporate family, are obliged, when performing the tasks and duties entrusted to them:
The Bank’s values are a set of guiding principles and fundamental beliefs that help people in the organisation to function together as a team and work towards a common business goal. Values are linked to business relationships, relationships among employees, relationships with clients and the growth of the company. The values that the Bank applies and promotes in its everyday business and work, in relations with colleagues, business partners and other stakeholders, are:
Care for our users comes first. Through everyday business we strive to build good long-term relationships.
Moral values and legal duties matter to us. We approach our work ethically and professionally. We build relationships on mutual trust, respecting the opinions and views of others. Agreements are honoured.
Our employees are the key to successful business! We rely on internal knowledge. Your ideas and initiatives matter to us so that we can move forward. We invest in the development of teams and in the individual development of employees.
We reach the goal only together!
“A team is not a group of people who work together. A team is a group of people who trust each other.”Simon Sinek
We strive to establish mutually beneficial, caring relationships based on trust and a desire for shared success, providing an outstanding user experience and service.
Our vision is to always do business simply, safely and responsibly, to be a reliable partner and the bank of first choice for our users/clients and employees.
We are a strong and reliable domestic bank, ready to grow together with our users/clients and their ideas, and also to support those who are just starting out. In a simple, accessible and responsible way we direct our business so that care for people and economic progress are woven into our corporate values, and through our activities we confirm that we are also a socially responsible partner of the community.
Guided by our values and valuing our reputation, we follow ethical principles and act with respect and goodwill towards colleagues, users/clients, partners and other persons with whom we come into contact. We are responsible for the results of our work and for our working environment.
The Bank’s basic principles in relations with third parties are set out in the Bank’s Code of Ethics. They include transparency, user satisfaction with services, care for clients, constant improvement of services and socially responsible business.
Continuous development is a necessary condition of our success, which is why we attach great importance to the professional and personal development of our employees. The Bank’s aim is to provide opportunities for training and for the development of professional, leadership and managerial competencies, and we encourage our employees to work on their own progress and to strive to achieve the best possible results.
The Bank’s relations with government authorities, local authorities and regulatory bodies are based on the principles of transparency, cooperation and compliance with the law and other regulations. Employees of the Bank should act professionally, expressing the official position of the Bank, and should not prevent the competent authorities from conducting official investigations, supervision and controls.
At every moment of its operations the Bank respects the law and complies with all applicable laws and regulations. The Bank refuses to do business with individuals, companies or institutions if their business is in any way connected with activities that are illegal or may be considered unethical.
Employees, shareholders and members of the Bank’s governing bodies who, in exercising their powers and responsibilities, have access to certain confidential information relating to the Bank, its users/clients or business partners, are obliged to keep such data in accordance with the law, other regulations, internal acts and the Code, and may not use them for their personal needs or disclose them to third parties. The Bank takes particular care to protect personal data, in accordance with the law, other regulations and the Bank’s internal acts.
All data on clients obtained directly or indirectly are strictly confidential and are used exclusively for internal purposes. Without the prior and express approval of clients, the Bank does not provide confidential data to third parties or institutions, except in the case of a justified request by the competent state authorities or the exchange of general information among banks. Employees are obliged to apply the Bank’s principles in their work in dealing with associates, users/clients, suppliers, competitors, institutions, shareholders and the general public.
All employees and members of the governing bodies are expected to observe the following rules on the handling of inside information: it is prohibited to disclose confidential information to other persons, except where the information is disclosed and made available in the course of regular business, a profession or duties; it is prohibited to use inside information when giving advice or recommendations to other persons regarding trading in securities, and when trading in the securities to which this information relates, for one’s own account or for the account of a third party.
As an important financial entity in the market of Bosnia and Herzegovina, the Bank is aware of its impact on the environment, and of the fact that acting and doing business in the community also implies constant care and respect for society.
The Bank performs all its obligations towards clients, regulators, shareholders, suppliers and third parties in a timely manner and in this way sets an example for all of them. In performing our obligations we do business on the principles of conscientiousness and fairness within the fundamental principles of the law of obligations.
We strive for long-term profitable business, while wishing to contribute to the improvement of social standards and the protection of the environment, and to avoid harmful consequences for society and the environment.
Respect for the rights and legitimate interests of the Bank’s shareholders and the provision of equal conditions for all shareholders are the foundation of the corporate governance system and of the Bank’s relationship with shareholders, where we create favourable conditions in which shareholders can exercise their rights, including the right to participate in management and to vote at the shareholders’ meeting, and the right to receive relevant information on the Bank’s activities in a timely and regular manner, strictly respecting the statutory obligations and powers of the Bank’s governing bodies. The Bank has built a system that enables the Bank to be managed in a transparent manner, with respect for the highest standards of banking, business ethics, avoidance of all circumstances that constitute or could constitute a conflict of interest, application of a conservative risk management system and established internal control mechanisms, and public disclosure of all information that is significant for the Bank’s business.
All activities of the Bank are directed towards preserving and increasing shareholders’ capital, and the existing management system protects shareholders’ capital from all circumstances that could diminish it.
The Supervisory Board of the Bank adopts this Code and ensures its application. The Management Board of the Bank is obliged to ensure that members of the Bank’s governing bodies and employees are familiar with this Code, the adopted standards of corporate culture, the Bank’s values and risk culture, its risk appetite and risk-bearing capacity, and the rules for preventing conflicts of interest at the Bank.
A member of the bank’s governing body is obliged, by their behaviour, to encourage an adequate organisational culture that gives the highest priority to the professional, honest and conscientious performance of business activities at all organisational levels, and to clearly defined, transparent and consistently applied levels of responsibility and authority within the bank’s organisational structure. The bank’s governing bodies are obliged to apply professional and ethical management standards in order to achieve a balance between the interests of the Bank, the Bank’s governing bodies, clients, creditors, shareholders, employees, regulators and other stakeholders. This is achieved by acting in accordance with legal regulations, supervisory and regulatory rules, the rules of the profession and the Code, so as to leave as little room as possible for the personal judgement of a member of the bank’s governing body.
Members of the bank’s governing bodies and all managers have an additional responsibility for creating and maintaining a corporate culture and behaviour in which employees know and understand their duties and feel free to report their concerns and problems.
Members of the governing bodies and all managers are, in particular, obliged to:
An atmosphere of open communication among employees is an atmosphere of openness and honesty in which employees can freely discuss ethical issues, and managers take their opinion into account. At the same time, the expression does not mean that an individual may disclose business, inside, personal and other confidential information of the Bank, its clients and third parties.
The Bank’s independent control functions, which include the internal audit function, the risk management function and the compliance monitoring function (“Compliance”), assist the Bank’s senior management in establishing an efficient and effective control environment and in acting in accordance with the Code, the established corporate culture, values and risk culture.
In accordance with the principle of three lines of defence, these functions do not replace effective risk supervision by the heads of the Bank’s organisational units and parts, who are obliged to manage risks every day within the business segments they lead.
The Bank is obliged to ensure regular monitoring of the compliance of the conduct of members of the Bank’s governing bodies and employees with the Code and with the standards of corporate culture and risk culture. The compliance monitoring function is obliged to report regularly, and at least once a year, to the bank’s governing bodies on compliance of conduct with the Code and with the standards of corporate culture and risk culture, including the identification of potential breaches and reporting on non-compliance issues. If the compliance monitoring function identifies significant irregularities and deficiencies, it is obliged to inform the Supervisory Board immediately.
Members of the Bank’s governing bodies act in accordance with high professional and ethical standards of managing the Bank in order to achieve a balance between the interests of the Bank, users/clients, creditors, shareholders, employees, the Banking Agency and other stakeholders, and they work to the greatest extent possible to prevent the making of decisions based on personal interests that may lead or have already led to a conflict of interest.
By their behaviour, members of the Bank’s governing bodies encourage an adequate organisational culture that gives the highest priority to the professional, honest and conscientious performance of business activities at all organisational levels, and to clearly defined, transparent and consistently applied levels of responsibility and authority within the Bank’s organisational structure.
Members of the Bank’s governing bodies, and all employees of the Bank, must also refrain in private from conduct:
All employees, as well as members of the Bank’s bodies, are obliged to avoid circumstances and conduct that could lead to a conflict of interest between them and the Bank, that is, the Banking Group, or between them and a person who has economic, political or other interests in common with the interests of a member of a governing body, or that indicate joint action by a member of a governing body and that other person.
When carrying out activities and making decisions, the interests of the Bank must be taken into account first and personal interests subordinated to the interests of the Bank, that is, the Bank’s business opportunities must not be exploited for one’s own account or for the account and in the name of a person who has common interests with them.
Employees are obliged to report circumstances from which a conflict of interest may arise, as well as any change in those circumstances. Circumstances or relationships from which conflicts of interest arise include:
More detailed rules on preventing, identifying and managing conflicts of interest at the Bank are regulated by the internal act the Conflict of Interest Management Policy.
There are certain cases and circumstances that must be reported to the competent organisational units of the Bank, namely:
Irregularities may be reported to the Compliance Monitoring Department.
The Bank is obliged to ensure that an employee is not punished in any way if they report irregularities in good faith or if they ask that other employees also behave in accordance with the Code.
All information received from an employee is considered confidential, and irregularities that are observed are investigated in accordance with the relevant internal acts of the Bank. An employee has the right to anonymity when providing information, both orally and in writing.
If an employee took part in activities that breach the Code, but voluntarily admitted it, that circumstance may be taken into account when considering possible liability. It is prohibited to deliberately submit false information or information that may be misleading.
We value our reputation, we follow ethical principles and we fulfil the obligations we undertake at any time and in all circumstances. We act with respect and goodwill towards our colleagues, clients, partners and any other person with whom we come into contact. We are responsible for the results of our work and for our working environment.
Users/clients are the foundation of our business, and the key condition for the development of the Bank’s business lies in improving relationships with users/clients, to whom we want to provide a service based on honesty, transparency and consistency. We develop an individual approach to each client, because it is important to us to earn their trust.
Clients’ needs are the focus of the Bank’s business and are what sets Nova banka apart from the competition. In that sense we constantly develop applicable models that will meet clients’ basic and specific requirements, and mechanisms on the basis of which clients will be aware that the Bank considers every request of theirs with due care and the highest professional standards.
Every employee of the Bank is obliged to keep the promises made to clients and to respond immediately to any request of theirs, to take personal responsibility for the results of their work, to admit mistakes, to learn from them and to take all necessary measures to perform their duty and tasks to a high standard. All employees of the Bank are obliged to give sound advice that does not mislead the client and to inform them of all possible risks. Feedback from our clients is very important for our development and for improving our business.
Feedback from our clients is very important for our development and for improving our business. When dealing with client complaints, the Bank should, as soon as possible, take measures to resolve the problem and prevent similar situations in the future. The Bank values every piece of information about its work and carefully analyses all comments and remarks, because this improves the quality of its services and helps maintain client loyalty. When handling its clients’ information, the Bank takes all necessary measures to protect that information.
The Bank strictly complies with labour legislation, seeks to support a reasonable balance between the private life and professional duties of employees, and respects their obligations outside the scope of work duties and responsibilities. The Bank guarantees its employees appropriate reward for their work and equal opportunities for career development based on an assessment of their performance and competencies, also taking into account their aspirations for further professional career development.
In the process of evaluating employees’ work, the Bank fosters a culture of feedback, in which managers provide their subordinates with information on the evaluation of their work. In order to improve the efficiency and motivation of our employees, we continuously improve the system of salaries, benefits and other payments, in accordance with applicable regulations.
Continuous development is a necessary condition of our success, which is why we attach great importance to the professional and personal development of our employees. The Bank’s aim is to provide a wide range of opportunities for training and for the development of the professional, leadership and managerial competencies of the members of its team. We encourage our employees to work on their own progress and to strive to achieve the best possible results.
Our aim is to create and maintain a working environment that enables every member of our team to realise their full potential. Our employees openly express their opinions and are not afraid to talk about their problems. We admit our mistakes, learn from them and take action.
We value working as a team, in which every individual’s opinion is taken into account. We respect the opinions of others and share knowledge and resources in order to achieve outstanding results, ensure a high quality of business and support personal and collective growth. Members of our team treat one another as they would clients; they are open and trust one another.
Our common duty is to create an atmosphere of understanding and trust, and to maintain the productivity of the working environment. Derogatory, vulgar, indecent, cruel, discriminatory, aggressive or offensive language, gestures or behaviour are not permitted in our team. In our team we value diversity. The Bank strictly prohibits any form of direct or indirect discrimination, including discrimination on the basis of religion, age, gender and other characteristics.
Employees of the Bank, in accordance with the Labour Law and the Work Rulebook, and the signed employment contract, have the right to:
In addition to the above, an employee also has the right to professional development if it is in the interest of the Bank and helps the employee to perform the job more effectively and successfully, in accordance with the position to which they are assigned by the employment contract and/or a decision.
When performing the tasks entrusted to them, within the meaning of the Law and the Work Rulebook, an employee has the following obligations:
During the notice period, the employee is obliged to make every necessary effort to complete all work that has been started, to fulfil the obligations undertaken, to give instructions on their work functions to the competent person designated by the Bank, and to acquaint that person with the state of the work they perform.
We believe that all members of our team must act with due care and not allow the misuse or waste of the Bank’s property, information, or funds allocated for travel or other purposes. In using the Bank’s property, our employees are guided first of all by the interests of the Bank. We spend money only if spending for business purposes cannot be avoided. We save the Bank’s funds and cover costs as if we were using our own money. We take care of the Bank’s property as if it were our own.
In certain cases, it may be permitted to use the Bank’s telephone, fax, photocopier, computer, email or similar equipment for personal purposes if this does not constitute abuse, does not interfere with the performance of duties and does not involve unlawful activities, all in accordance with the Bank’s internal acts, which employees must observe.
We preserve the confidentiality of information received in the course of business activities and we understand the difference between matters we may discuss only with colleagues and information we may share with relatives and friends.
The Bank limits the ability of employees who are in a conflict of interest to act and make decisions independently. Employees are obliged to report circumstances from which a conflict of interest may arise, as well as any change in those circumstances. If there is a dilemma as to the existence of a conflict of interest, you must immediately seek advice from your immediate superior and the Compliance Monitoring Department on how to proceed.
Circumstances or relationships from which conflicts of interest arise include:
The rules on identifying, preventing and managing conflicts of interest at the Bank are set out in the Conflict of Interest Management Policy.
In most cases, working with close relatives is not prohibited. However, in order to reduce conflicts of interest to a minimum, the Bank maintains the principle of limited work and cooperation between close relatives and prohibits favouritism based on family ties.
Working together by close relatives who are directly or functionally subordinate to one another is prohibited. Every case of employment of close relatives of employees of the Bank and the Banking Group, including members of the governing bodies and persons with a qualifying holding in the Bank, must be recorded in the Conflict of Interest Register kept by the Compliance Monitoring Department.
The Bank recognises the right of its employees to be engaged outside the Bank, provided that the following rules are respected:
In order to avoid a conflict of interest, the Bank expects employees to inform their immediate superior of any work they perform or intend to perform outside the Bank and to request the consent of the competent organisational units and the bank’s governing bodies, when necessary.
Additional rules for employees who enter into relations with clients and partners, in particular restrictions on participation in ownership interests or governing bodies of other legal entities, and on carrying out an independent business activity, are prescribed by the Policy on Managing the Risk of Conflict of Interest and Corruption. In the event of any doubts regarding employees’ additional engagement, the Compliance Monitoring Department should be consulted.
In ordinary business relations, giving gifts is intended solely to promote the image of the Bank, and does not go beyond the bounds of ordinary business practice or courtesy, or serve as a means of obtaining privileged treatment in the conduct of any practice and/or activity that can be linked to the Bank.
The Bank supports the development of partnership relations with clients and partners and allows the exchange of appropriate gifts that are in line with good business practice and custom. The exchange of business gifts and invitations to certain events is acceptable, but care must be taken that such cases do not harm the reputation of the Bank.
Gifts must have a clear and transparent purpose and must not give the impression of an unlawful activity. It is not permitted to offer and/or promise gifts, donations or other benefits to officials or civil servants in an inappropriate manner, including where they are employees of foreign states or international public organisations. Promises or offers to third parties in an inappropriate manner, within the relations mentioned, are not permitted.
Employees must not receive gifts from any third party if:
When promoting itself, the Bank is obliged to apply ordinary business practices, and behaviour and practices that are not in accordance with the law and, where known, the codes of ethics of individual companies and bodies, including public bodies, with which relations are maintained, must be avoided. The foregoing does not apply to gifts of small value given in accordance with the principles and procedures of the previous paragraph.
Members of the Bank’s governing bodies and employees must not receive gifts or tokens of attention that go beyond the limits of small, that is, symbolic value or the usual rules of courtesy, nor accept, for their own benefit or for the benefit of other persons, other benefits or advantages offered that are inappropriate to ordinary business relations and that compromise the independence of judgement and the business integrity of the employee.
Employees are obliged to report every gift received to their manager.
No employee of the Bank may accept or request personal services or payments, nor may they make such offers to a third party. Bribery in any form is completely unacceptable. For any knowledge of the receiving or giving of a bribe, the employee who has that knowledge is obliged to report it to the Compliance Monitoring Department (the Compliance Monitoring Sector and the prevention of money laundering and financing of terrorist activities).
The Bank seeks to create a working environment in which individual differences are accepted and respected. Any form of discrimination based on the actual or assumed characteristics of a person is prohibited, including but not limited to race, ethnic origin, skin colour, gender, religion, political or other belief, national or social origin, marital status, state of health, and similar.
The Bank prohibits harassment at work, that is, any behaviour towards an employee, a group of employees or the employer that may cause harm of a physical, psychological or sexual nature.
The Bank prohibits behaviour based on intimidating employees, especially if employees are thereby forced to perform actions that are not in accordance with the Bank’s internal acts or applicable legal regulations.
Any verbal, non-verbal or physical form of behaviour that is directed at, or that may lead to, a violation of a person’s dignity or the creation of a humiliating and offensive environment is prohibited.
If an employee considers that, according to the above, they are a victim of harassment or discrimination, they must inform the Human Resources Segment, which will then take appropriate measures.
The Instruction on the procedure for protection against harassment at work at the employer, in accordance with the Law on Protection against Harassment at Work, regulates the procedure for protection against harassment at work and in connection with work at Nova banka a.d. Banja Luka, in particular: the manner of submitting a request, the appointment of a person or commission for submitting and conducting the procedure for protection against harassment at the employer, the person to whom the request is submitted and the manner of ensuring the confidentiality of data, and all other matters essential for conducting the procedure for protection against harassment at work at the employer.
The Bank adheres to good business practice and the highest ethical standards of doing business in the market, ensuring consistent application of laws, other regulations and internal acts.
Employees of the Bank are obliged, in performing their work:
As an organisation with many years of practice, operating in the territory of Bosnia and Herzegovina, the Bank nurtures and respects the standards of fair competition, doing business in accordance with the applicable regulations governing the protection of market competition.
Preserving its integrity, the Bank, when selecting business partners for the provision of services, the supply of goods and similar, takes a non-discriminatory approach, fostering the principle of equality, entirely without privileged partners. In that sense, respect for the fundamental human rights guaranteed by the Constitution and international conventions is a priority in business, both with the environment and within the Bank through conduct towards colleagues.
The Bank takes all prescribed measures, actions and procedures in order to prevent and detect money laundering and the financing of terrorist activities, in accordance with applicable regulations, and takes all prescribed identification and monitoring measures, in order to ensure that business relationships are established only with reliable users/clients and partners who carry out lawful activities and use funds from lawful sources.
Employees in the branch network are obliged to act in accordance with the internal acts that prescribe the prevention of money laundering and the financing of terrorist activities.
Corruption is any act or omission, by abuse of official authority or position for private purposes, in order to obtain unlawful material or any other benefit for oneself or another, undertaken by a responsible person or a person engaged to work, and every employee in their daily work should make a reasonable effort to reduce the risk of business relationships with counterparties that are, or could be, involved in corrupt activities.
In its business the Bank strictly adheres to the rules related to the obligations of combating corruption in any form and is committed to promoting a culture of prevention and zero tolerance of corruption at the Bank and in society.
Employees of the Bank must under no circumstances, directly or indirectly, personally or through third parties, give, promise, request or receive a bribe, or pay to speed up administrative or other proceedings.
Every person engaged to work at the Bank has the right to report corruption. It is prohibited to abuse the reporting of corruption by submitting information that the reporting person knows, at the time of reporting, to be untrue, or by reporting that seeks a material benefit as a reward or compensation for submitting information and evidence of corruption, as well as any activity of preventing persons engaged to work at the Bank from reporting corruption.
More detailed rules on preventing and reporting corruption and corrupt behaviour are set out in special internal acts of the Bank.
Employees, shareholders and members of the Bank’s governing bodies who, in exercising their powers and responsibilities, have access to certain confidential information relating to the Bank, its clients or business partners, are obliged to keep such data in accordance with the law, other regulations, internal acts and the Code, and may not use such data for their personal needs or disclose them to third parties.
Identified and other employees, as well as any other person engaged to work at the Bank on any basis, and persons who carry out an external audit, are obliged to keep a business secret in relation to any information they have learned in the course of performing the work or duties within their area of work, and may not use it for other purposes or communicate it to third parties.
A banking secret, according to the definition given by the law, is data, a fact or knowledge obtained by members of the Bank’s bodies and committees, shareholders, employees of the Bank in performing work and carrying out duties within their competence, as well as persons of the company that carries out the external audit of the Bank and other persons who, because of the nature of the work they perform, have access to such data, the disclosure of which to an unauthorised person has caused or could cause harmful consequences for the Bank and its clients.
Employees may use secret data they have obtained in accordance with this law exclusively for the purpose for which they were obtained, and may not disclose them to third parties or enable those persons to learn and use these data, except in the cases prescribed by this law.
Disclosure of a business secret, that is, negligent performance of work and tasks that may lead to the disclosure of an official or business secret, is classified as a serious breach of work duty and work discipline in accordance with the Work Rulebook and the Rulebook on Disciplinary and Material Liability of Employees.
In the event of a serious breach of work duty, that is, inadequate keeping of a business/banking secret by an employee, in addition to the misdemeanour liability established by law and the corresponding misdemeanour sanction, disciplinary proceedings will also be initiated against the employee in accordance with the prescribed procedures.
Every employee of the Bank, in performing their work, may come to know inside information about the Bank or another organisation before that information becomes public. Using such information to obtain a benefit for oneself or for third parties is a serious breach of the relevant regulations.
All employees and members of the governing bodies are expected to observe certain rules on the handling of inside information:
Over years of operating in the banking and financial sector, the Bank has also actively contributed to socially important projects, that is, events related to culture, art, sport, science, charity programmes and education.
Our relationship with the community is based on mutual trust, respect and active partnership. Through participation in various events, donations and sponsorships, the Bank supports socially beneficial events and promotes responsible behaviour.
In the process of allocating funds for this purpose, it is imperative to ensure that any donation or sponsorship is in line with the Bank’s values and corporate integrity.
The Bank may award a donation to support programmes, projects or activities in the fields of education, sport, culture, art, social and health assistance, environmental protection, and for humanitarian purposes.
The Bank’s relations with government authorities, local authorities and regulatory bodies are based on the principles of transparency, cooperation and compliance with the law and other regulations. Employees of the Bank should act courteously and professionally, expressing only the official position of the Bank, without preventing the competent authorities from conducting official investigations, supervision and controls.
The Bank ensures the management of information, as one of the important parts of its business, through accurate reporting, transparency and a professional relationship with the public (through the media and social networks), taking care to protect confidential information and personal data.
Reporting is carried out in a timely manner and in accordance with applicable regulations. In its reports the Bank presents accurate and reliable data and actively works to suppress any occurrence of untimely, inaccurate or incomplete information. Information it provides to the public concerning its business and financial position is verified, accurate and reliable.
A significant role in public presentation and appearance, public relations, and building and protecting the corporate image is played by the Marketing and Corporate Communications Segment, as well as the competent responsible person at the Bank whom the Bank has previously authorised to perform these or similar tasks.
Employees of the Bank, when meeting representatives of the media in connection with the Bank’s activities, are not authorised to respond on its behalf unless they have prior permission from the competent members of the Bank, which also applies to any other communication channels, including digital platforms and social networks as a form of communication with the public, which are treated as public communication.
It is particularly important to emphasise that every public communication carries a great responsibility in terms of compliance with applicable regulations, and it is necessary to ensure the credibility and integrity of the information conveyed.
The Bank takes particular care to protect personal data, in accordance with the law, other regulations and the Bank’s internal acts.
Employees, shareholders and members of the bank’s governing bodies who, in exercising their powers and responsibilities, have access to certain confidential information relating to the Bank, its clients or business partners, are obliged to keep such data in accordance with the law, other regulations, internal acts and the Code, and may not use such data for their personal needs or disclose them to third parties.
Employees of the Bank are obliged, when handling personal data within the job description of their position, to respect the provisions of the Bank’s internal acts that regulate the protection of personal data at the Bank, that is, the provisions of the applicable regulations in this area.
Employees should remember that communication on social networks is usually public in nature. Employees are prohibited from spreading or discussing information related to the Bank’s activities on public internet resources, including a prohibition on using the Bank’s logo, trademark and brand without the Bank’s permission, and on publishing photographs and video recordings that may discredit the Bank’s business reputation.
The Bank respects human rights and recognises their importance and universality. We fully respect and support the human rights established by the Constitution and international conventions, such as the United Nations Universal Declaration of Human Rights, the European Convention for the Protection of Human Rights and Fundamental Freedoms, and others.
Respect for human rights and fundamental freedoms is reflected in our internal acts and in our conduct towards our colleagues, clients, partners and other parties with whom we cooperate.
All employees of the Bank, as well as persons who are only entering into an employment relationship with the Bank, must be familiar with the provisions of this document and are obliged to respect its provisions.
Employees and members of the Bank’s governing bodies are expected to act responsibly with regard to the Bank’s reputation, not to take part in inappropriate behaviour of any kind, and in particular not in the conscious and intentional disregard or breach of the Code, nor in inducing others to such conduct. In addition to respecting the provisions of the Code, employees and members of the Bank’s governing bodies are obliged to respect all applicable laws, other regulations and internal acts.
A breach of any provision of the Code is considered a breach of work duty or work discipline. Depending on the seriousness of the breach, in proceedings conducted on the basis of the relevant regulations and the Bank’s internal acts, appropriate measures provided for by the law governing employment relations and by the Bank’s internal acts may be imposed on the employee.
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