GUIDELINES
TO PREVENT CORRUPTION
ZiraatBank BH d.d. (hereinafter: the Bank) is committed to combating corruption in all its forms, where corruption is related to offering or accepting, directly or indirectly, money or other benefits with a view to influencing the recipient, for the purpose of incentive or reward for the execution or functions / activities or their non-implementation. The foregoing therefore covers both "active corruption" (offering) and "passive corruption" (acceptance), and cases involving public bodies ("public corruption"), and also relationships between private persons ("private corruption"), is corruption aimed at performing an act that constitutes an infringement of an official's official duties ("direct corruption") or is it a corruption aimed at carrying out the act through someone else's position ("indirect corruption"), whether it be "prior corruption" or that which "follows" after the performance of official duties.
These Guidelines:
• identify principles and sensitive areas and define the roles, responsibilities and macro-processes of managing the risk of corruption by the Bank in the context of its own business activities in the context of the Bank's active cooperation in the fight against corruption, with the aim of protecting the integrity, reputation and preserving the reputation of key players;
• monitors the business in which the Bank participates as a client executor, using a system for controlling the risk of money laundering and terrorist financing;
• provide general information to all employees of the Bank on measures taken by the Bank to identify and reduce corruption risks and to manage them.
All executives and employees of the Bank are expected to comply strictly with and comply with these Guidelines, as well as with all internal rules and laws that are related and aimed at preventing corruption.
External associates (suppliers, agents, brokers, consultants, experts, business partners and the like) who assist the Bank in carrying out its activities (hereinafter referred to as "third parties") are also required to comply with the principles set out in this Guideline.
REGULATORY FRAMEWORK
Preventing corruption at all levels is the key to a successful anti-corruption policy. In the fight against corruption, the Bank follows the basic principles set out in:
• Legislation of Bosnia and Herzegovina;
• International conventions ratified by Bosnia and Herzegovina;
FOREIGN REGULATIONS
In the fight against corruption, the Bank follows the basic principles enshrined in the applicable conventions as well as international best practices.
In this context, of particular importance are:
• "Convention for the Suppression of Bribery of Foreign Public Officials in International Business", 1997, Organization for Economic Co-operation and Development (OECD);
• the “Convention against Corruption”, adopted by Resolution 58/4 of 31 October 2003, United Nations (“United Nations” or “UN”);
• "Criminal Law Convention on Corruption" and "Civil Law Convention on Corruption", 1999 Council of Europe;
• Council Framework Decision 2003/568 / JHA of 22 July 2003 on combating corruption in the private sector, 2003 Council of the European Union
• “Guidelines of the Wolfsburg Corruption Prevention Group”, 2011, Wolfsburg Group
• “Rules of the International Chamber of Commerce on Combating Corruption”, 2011 International Chamber of Commerce (ICC)
• “Business Principles for Combating Bribery, a Multi-stakeholder Initiative Led by Transparency International”, 2013, Transparency International
• “2015-16 G20 Anti-Corruption Implementation Plan”, 2014, G-20
NATIONAL LEGISLATION
Regarding domestic legislation, the main regulations are:
• Criminal Code of Bosnia and Herzegovina, Entity Laws and Brcko District Law
• Criminal Procedure Code of Bosnia and Herzegovina, Entity Laws and Brcko District Law
• Law on Prevention of Money Laundering and Financing of Terrorist Activities of Bosnia and Herzegovina
• Freedom of Access to Information Act
• Entity Labor Law
• Law on Conflict of Interests in the Institutions of Government of Bosnia and Herzegovina and the Entities
• Law on the Agency for the Prevention of Corruption and Coordination against Corruption
The Bank applies the principle of zero tolerance against corruption and prohibit it in any form, direct or indirect, adhering to the values of integrity, principles of professionalism, perseverance, diligence, honesty, fairness and responsibility.
In line with these principles and adhering to the values and restrictions contained in the Code of Ethics, the Bank will not tolerate any kind of corruption, in any way of form, even if such activities were to be possibly accepted, tolerated or not challenged in accordance with the positive regulations of the Bosnia and Herzegovina
Thus, the costs of gifts and entertainment, charitable donations, sponsorships, relationships with third parties, the purchase, management and disposition of investments, property and real estate, employment are carefully designed, defined and monitored through internal guidelines to unambiguously identify and timely identify potential corruption risks.
In case of additional questions or uncertainties, please contact us by e-mail:
informacije@ziraatbank.ba