Code of Ethics and Business Conduct
Message from the Board
At Creditbank s.a.l. (hereinafter: the Bank), we believe that conducting banking activities with ethics is critical to our long term success. Ethics, integrity and honesty are the foundations based on which we build our reputation and our competitive excellence.
Each director, officer and employee is expected to abide by the highest standards of ethical conduct in every business undertaking and banking relationship, either internally or with our clients, partners and competitors.
To that end, the Board of Directors has approved and adopted, this Code of Ethics and Business Conduct (hereinafter: the Code).
This Code is intended to document some of the specific principles of ethics and conduct which shall be followed by the Bank’s directors, officers and employees in the performance of their responsibilities related to the Bank’s business and activities. The purpose of the Code is to promote:
Each director, officer and employee has read and become familiar with the ethical standards described in this Code and may be required, from time to time, to affirm his adherence to such standards by signing the attached Receipt.
- Compliance with applicable laws and regulations.
- Integrity, honesty and ethical conduct.
- A work environment free of Conflicts of Interests.
- Fair, accurate, timely and understandable disclosure to the public.
- Respecting banking secrecy law and protecting confidential information.
- Internal reporting of violations of this Code.
- Accountability for non-compliance to this Code.
The Bank’s Board of Directors is responsible for administrating this Code, in particular, setting the standards of business conduct contained in this Code and updating these standards as it deems appropriate to reflect (i) changes in the legal and regulatory framework applicable to the Bank, (ii) the Bank’s own business practices, as well as (iii) the prevailing ethical standards and best practices within the sectors in which the Bank operates. While the Bank’s General Manager will oversee the efficient implementation of this Code, it is the individual responsibility of each director, officer and employee of the Bank to comply with this Code.
III. Compliance with Laws and Regulations
The Bank is committed to conducting its banking activities in compliance with all applicable laws and regulations. All directors, officers and employees acting on behalf of the Bank are expected to obey the law, and shall in no way, knowingly or intentionally, commit any illegal act or instruct or authorize others to do so, for any reason, in connection with any decision or activity that is or may appear to be related to his employment with the Bank.
To that end, they have the responsibility to learn and understand said laws and regulations which are applicable to the banking sector in general and in particular to their department’s activity.
Specifically, the Bank is committed:
- To comply with all Lebanese laws and regulations applicable to the Bank as well as the Collective Labor Agreement, and other applicable rules and principles that govern the Bank’s subsidiaries.
- To comply with all Lebanese laws and regulations relating to anti-money laundering and counter-financing terrorism.
- Not to provide any kind of advice (whether in written or orally) or services to clients aiming for the partial or total avoidance of applicable taxation laws, and in particular the Foreign Account Tax Compliance Act (FATCA).
- To maintain a safe and healthy work environment.
- To promote a workplace that is free from inappropriate behavior, discrimination or harassment based on race, color, religion, sex or other factors that are unrelated to the Bank’s business interests.
- To conduct its activities in full compliance with all applicable environmental laws.
IV. Ethical Conduct
The Bank is committed to conducting its business ethically and honestly and applying appropriate protection standards while dealing with its customers. Each director, officer and employee shall at all times deal fairly with the Bank’s clients, shareholders, employees, partners and stakeholders and in accordance with this Code and in connection with each action and decision that is or may reasonably appear to be related to his employment in the Bank.
1- Ethical Principles
The following is a non-exhaustive list of Ethical principles that should be observed by the Bank, its directors, officers and employees:
1.1- Directors, officers and employees are prohibited from seeking or accepting anything of value (including services, discounts or entertainment) from clients, suppliers or anyone else in return for any business (mainly granting loans), service or restricted information of the Bank. This includes gifts provided solely in gratitude for a previously provided service.
1.2- Directors, officers and employees must protect and seek to ensure efficient use of the Bank’s assets, as well as protect against the improper disclosure, theft or misuse of the Bank’s intellectual and physical property.
1.3- The Bank must offer products and services on a competitive basis and will not tolerate any use or attempted use of improper incentives to obtain business.
1.4- With regard to suppliers, the selection of products and services to be purchased by officers and employees for the Bank is based solely on the internal procedures covering best value and service.
1.5- With regard to officers and employees, the Bank is committed to diversity and equal opportunity. Supervisory personnel are reminded to hire, assess and reward employees strictly on the merit of qualifications and job performance.
1.6- Directors, officers and employees shall not abuse of their position and take advantage of the Bank for personal gain.
1.7- Directors, officers and employees should not use the Bank's name or any of its affiliated entities, either directly or indirectly, to endorse any public issue, political candidate, political party or business interest, product or service.
1.8- Keeping the political opinions of the Bank’s directors, officers and employees separate from the Bank’s business.
2- Customer Protection Principles
The following are the principles that are followed by the Bank while dealing with its customers:
2.1- Transparency and Disclosure: The Bank shall deal with customers in a continuously fair, equitable and professional manner.
2.2- Suitability: The Bank shall gather sufficient information from the customer to ensure that the product or service meets his financial situation and needs.
2.3- Awareness and Education: the Bank shall provide Customers with (i) a list of their rights and responsibilities containing clear information on customer’s protection, (ii) Key Fact Statement containing ample key information on the conditions, benefits and risks of products or services, as well as a detailed list of the fees and charges collected by the Bank
2.4- Fair and Sustainable Marketing Campaigns: The Bank shall ensure that advertisements are clear, transparent, comprehensive, and do not contain any misleading information.
2.5- Confidentiality (Secrecy and Data Protection): The Bank shall protect the customers’ personal and financial information in compliance with Banking Secrecy Law and without prejudice to Anti-Money Laundering and Counter Financing Terrorism Law.
2.6- Complaints handling: an efficient mechanism is developed enabling customers to submit their claims and guaranteeing the fair and timely follow-up and outcome thereof.
A Customer Protection Unit insures the appropriate implementation of the above Customer Protection Principles.
V. Conflicts of Interest
As part of their employment responsibilities, directors, officers and employees are expected to act in a way that contributes to the financial success of the Bank, enhances its reputation and fosters its client relationships. This requires that they should not be involved in any activity which creates or reasonably could be expected to give rise to a conflict of interests between their personal interests and the Bank’s interests.
A conflict of interest may occur when the directors, officers and employees private interests in any way interferes—or even appears to interfere—with the interests of the Bank. A conflict situation can arise when a person has interests that may impair the objective performance of his duties to the Bank.
Therefore, directors, officers and employees shall take all reasonable actions necessary to avoid all conflicts of interests and shall disclose any matter that they believe might raise doubt regarding their ability to act objectively and in the Bank’s best interests.
Illustrative examples of situations that may involve a conflict of interest include but are not limited to:
- Conducting business with a firm owned, partially owned or controlled by a director, officer, or employee or a relative of such person.
- Owning any undisclosed financial interest with the Bank’s clients or competitors.
- Performing work, with or without compensation, for a competitor, client or supplier of the Bank, or doing any work for a third party that may adversely affect the performance or judgment on the job or diminish the ability to devote the necessary time and attention to the Bank-related duties.
- Using the Bank’s property, materials, supplies funds or other resources for personal purposes.
- Borrowing from any of the Bank’s suppliers or clients.
- In making personal investments decisions, directors, officers and employees must carefully avoid the use of any restricted information they have obtained through their employment.
- Participation in the consideration or approval of any extension of credit, any waiver of fees, advantageous financial conditions, or approval of any other transaction between the Bank and directors, officers and employees or anyone in their immediate family, or with other people, companies, partnerships, or other organizations in which they or any member of their immediate family have a significant financial interest.
- Accepting a personal fiduciary appointment for anyone who is a client of the Bank (except in close family relationships or unless you have the prior written approval of the Board of Directors).
- Accepting a Power of Attorney for anyone who is a client of the Bank (except in close family relationships or unless you have the prior written approval of the Board of Directors).
VI. Disclosure of the Bank’s Financials
The Bank's financials, periodic reports and other essential data are to be timely maintained with accuracy and honesty in strict compliance with applicable laws, regulations and accounting principles.
When preparing such records, directors, officers and employees are not to make false or misleading entries in records nor permit the existence of any fund or asset or liability which is not fully and properly recorded on the Bank's books.
No transactions, agreements, programs, plans, lending, obligations or payments shall be entered into, made or recorded with the understanding that their use is for other than the stated purpose.
Directors, officers and employees shall not make any false or misleading statements about such records or conceal information from management or the Bank's auditors. They shall fully cooperate with the internal and independent auditors and counsels. This means providing them with complete and accurate information. Any omissions or inaccuracies in the Bank's records should be reported immediately to the Board of Directors.
Directors, officers and employees shall maintain a system of internal controls that will provide reasonable assurances to management that material information about the Bank is made known to management, particularly during the periods in which the Bank’s periodic reports are being prepared. They shall also present information in a clear and orderly manner in the Bank’s periodic reports, and prohibit the establishment of any undisclosed or unrecorded funds or assets.
VII. Confidentiality and Banking Secrecy
Directors, officers and employees are expected to treat information entrusted to them by clients and employees as restricted or highly restricted, privileged, confidential information and protected by the Lebanese Banking Secrecy Law dated September 3, 1956. This includes information contained in Bank’s books and formalities, correspondence, and in general all kind of information related to the Bank's clients (including their names, assets and properties of whatsoever nature), in addition to any information related to the Bank’s scope of work, and/or computer programs (Software), and/or documents and contracts of whatsoever nature, and/or internal management, working and auditing procedures.
Also, the use of the Bank's computer systems provides employees access to restricted customer information based on the business/support function(s) being performed. Employees are granted access to the Bank's various computer systems to perform their job duties. Each employee is expected to protect the access granted to him and to keep any associated passwords restricted at all times.
Directors, officers and employees are prohibited from disclosing confidential information except in response to a valid judicial decision or court order and in strict compliance with the provisions of the Lebanese Banking Secrecy Law dated September 3, 1956, while taking into consideration the compulsory disclosure according to the Lebanese laws and regulations related to anti-money laundering and counter-financing terrorism.
Directors, officers and employees are also prohibited from disclosing information related to the Bank’s subsidiaries or affiliates until it has been published in reports or otherwise made generally available to the public.
The obligation to maintain the confidentiality of the information continues even after directors, officers and employees are no longer employed by the Bank. The improper or personal use of confidential information may subject directors, officers and employees to senior penalties as provided in laws and regulations.
VIII. Sanctions for violation of this Code
The Bank is committed to taking prompt and consistent action in response to any violation of this Code.
The Bank will promptly investigate reports of suspected violations. It will evaluate suspected violations on a case-by-case basis.
Any Director, officer or employee who violates the Code is subject to appropriate disciplinary action, including immediate termination and, when necessary, reporting the violation to authorities.
IX. Reporting Violations of this Code
Any officer or employee who knows of or reasonably suspects a material departure from any provision of this Code is under the obligation of promptly reporting (orally or in writing, if preferred anonymously) the relevant information to the immediate attention of the Bank’s General Manager in order to take adequate actions.
In case a director becomes aware of or reasonably suspects any breach of this Code, he shall report it to the Chairman of the Board in order to take adequate action.
The Bank will not tolerate retaliation in any form against any person who, in good faith reports suspected violations of the Code. Anyone found to have retaliated against another employee for any such conduct, will be subject to appropriate disciplinary action, including immediate termination.
X. Amendment to, or Waiver of, this Code
Any amendment to, or waiver of, any provision of this Code with regard to any director, officer or employee must be approved by the Board of Directors.
XI. Questions about this Code
This Code is neither a contract nor a comprehensive manual that covers every situation that any director, officer or employee might encounter. This Code creates no contractual rights.
Any director, officer or employee who has questions about the meaning or application of any provision or requirement of this Code is encouraged to submit questions in writing to the Corporate Governance Secretariat.