The Code of Conduct of PostFinance Ltd. The basis for our actions.

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1 The Code of Conduct of PostFinance Ltd. The basis for our actions.

2 The same principles for everyone. This is why our Code of Conduct is binding. It enables us to strengthen our company s reputation The PostFinance Code of Conduct is the basis for our everyday actions because our company s reputation is very important to us. This is why we insist that all PostFinance Ltd employees behave in accordance with the Code of Conduct. The following questions can be used as a guide: Does my behaviour safeguard the interests of PostFinance? Am I acting in accordance with the corporate culture and values of PostFinance? Is my behaviour legally and ethically correct? Can I accept responsibility for my actions? Would I make the same decision if PostFinance was my own company? Can I justify my actions, even if they are the subject of media reports tomorrow? If we answer yes to these questions, any doubts about our own conduct can be set aside and we can defend our actions unreservedly to all stakeholders. The principles of the Code of Conduct are binding for all employees, regardless of their function and position. This also applies to members of the Board of Directors. Abiding by our principles is an important way of helping to strengthen trust in our brand and of reinforcing PostFinance s good reputation. Prof. Dr. Rolf Watter Chairman of the Board of Directors PostFinance Ltd Hansruedi Köng Chief Executive Officer of PostFinance Ltd 3

3 Company Surpassing support for our customers. That s why they appreciate us. Our positioning: first choice for independent customers PostFinance is one of Switzerland s leading financial institutions. We are number one for payment transactions, our core business. We want to maintain our market leadership in the future. We are the first choice for all private and business customers who manage their finances independently, anytime and anywhere. We provide solutions that make it easier for them to manage their financial affairs and offer added value. For our individual customers, we provide a tailor-made service that fits in perfectly with their value chain. Our market promise: surpassing support There are good reasons why we are the first choice for customers who manage their own finances. They can contact us at any time via e-finance, through our Contact Center or at PostFinance branches and post offices for consultations. We advise our business customers on their premises. Dealing with customers We treat our customers on equal terms. We speak their language and understand what they require. We deal with all concerns in a fast, authoritative and fair manner. An independent mediation body helps resolve any disagreements that arise. A valuable asset: our reputation We do not tolerate illegal or unethical conduct of any kind. We comply with the law and uphold social values in everything we do. We expect our service providers and partners to meet the same high demands we set ourselves. PostFinance s reputation indicates how our company is perceived by stakeholders. Authentic, reliable, trustworthy and responsible. These are its four distinguishing features. Protecting our reputation cannot be left to chance. We have internal rules and regulations, organize specific training courses and carry out the necessary checks. 4

4 Employees We represent PostFinance. Each employee shares this responsibility. A strong corporate culture PostFinance is part of Swiss Post we acknowledge this and are proud of it. Our corporate culture is based on mutual respect and fairness. At PostFinance, everyone is given the same opportunities, regardless of their sex, age, language or origin. We do not tolerate discrimination, workplace bullying or sexual harassment, or any other behaviour that violates human rights. Our employees are the basis for our company s success. They develop both personally and professionally and help take PostFinance to the next level. The company offers a working environment which allows employees to combine performance and passion and which takes health considerations into account. Ambitious diversity management Our employees come from 40 countries, a variety of cultural backgrounds and are at different stages in their lives. At PostFinance we appreciate diversity it opens up business opportunities for our company and offers personal prospects for our employees. Diversity management goes beyond ensuring equal treatment such as wage equality, the advancement of women and the integration of people with disabilities. It also applies to recruiting staff, determining working methods and putting together teams. All our managers are therefore required to apply active diversity management in the course of their managerial duties. 5

5 Employees Joint responsibility for our good reputation PostFinance enjoys a good reputation. This is regularly borne out in customer surveys. This should not only remain so, but should be constantly improved upon. Consequently, each employee regardless of their function and position must be aware of their personal responsibility and act accordingly. We also require all our employees to accept our core values and to behave in a motivated, responsible, customer-oriented manner. We expect high-quality performance and loyalty to PostFinance. This also means playing an active role in observing our Code of Conduct. Our employees first need to be familiar with and abide by this code. Confidentiality at every level Actively safeguarding our customers privacy is one of PostFinance s main priorities. When handling data, employees comply with bank client confidentiality and postal secrecy as well as observing the Data Protection Act and following defined security standards. All employees must treat confidential or pricesensitive information from our service providers and partners accordingly. Valuable information is only accessible to a clearly defined set of people. Discretion is guaranteed by carrying out appropriate checks. We only disclose confidential data and information in cases set out in the legal framework. 6

6 Employees Impeccable integrity Full compliance with legal and regulatory requirements is a matter of course at PostFinance. By setting internal guidelines, we require all our employees to make an effective contribution towards helping us meet these obligations. We make sure that all employees understand what is expected of them and know how to put them into practice. We comply with due diligence obligations and take all the necessary measures to prevent money laundering, financing of terrorism, corruption or other types of crim inal behaviour in connection with the ser vices we provide. We also attach great importance to avoiding conflicts of interest. We identify situ ations of conflict, such as those resulting from secondary employment, and defuse them by taking the appropriate organizational and personnel measures. Employee transactions that could cause conflicts or interest for our customers or for PostFinance itself are prohibited. Comprehensive security We deal with all security issues in a consistent, comprehensive and efficient manner. Our aims are to protect people, to protect the company and to protect tangible and intangible assets. This involves guaranteeing the security of operating materials, particularly information, and complying with legal provisions. We identify security risks associated with our business activity and limit them as much as possible. We respect the data privacy rights of our employees by defining strict dividing lines between their professional and private lives. All employees, particularly managers and the management, must help guarantee utmost security and support their colleagues in their efforts to carry out their tasks safely and efficiently. 7

7 Partners Committed to the same principles. This is our motto when dealing with partners. Expectations of our partners We treat our partners with respect, commitment and esteem. We expect the same treatment from them. It is vital for our partners to abide by our legal and regulatory requirements. We expect them to uphold human rights, to fully outlaw discrimination, abusive practices and corruption, and to refrain from using abusive employment conditions. We expect our partners to meet our demands and to observe our values for socially responsible conduct. As well as strictly adhering to our principles, partners located abroad must observe the provisions of industrial law of the relevant country, guarantee the corresponding minimum wage and comply with regulations governing working time and working conditions. Our sponsoring principles Our sponsoring activities are based on the principle of performance and reward. Our commitments are tailored to a wide crosssection of the population. The emphasis is on long-term national activities. We aim to achieve a balance in the areas of sport, culture and economy. We pay special attention to supporting the next generation in all our sponsoring commitments. Transparent communication culture Openness and transparency are the hallmarks of our communication policy and hence of our dialogue with all stakeholders our customers, the authorities, our owner, Swiss Post Ltd, and our employees. Anything communicated externally is first announced internally. This of course excludes any confidential information protected by bank client confidentiality or postal secrecy. 8

8 Social commitment We have strong ecological and social commitments. We must live up to them. Environmental responsibility We make a conscientious commitment to preserve the environment and to ensure sustainability by making efficient use of resources and minimising damage to the environment. We encourage our employees to implement PostFinance s principles with regard to environmental protection. We also provide stakeholders with detailed information about our activities, progress and objectives in the areas of ecology, social issues and the environment. Social responsibility PostFinance is a socially responsible employer. This is reflected not least by the fact that the large majority of our employees benefit from a collective employment contract negotiated with the social partners. We are well aware that the technical and social skills of our employees are the key to our corporate success. Consequently, PostFinance takes its social responsibility seriously. 9

9 General provisions. Area of responsibility The contents of the Code of Conduct are the responsibility of the Board of Directors of PostFinance Ltd. Observing and implementing its principles and supporting employees is a key managerial responsibility and must be exercised consistently. Every employee carries a part of this responsibility in their everyday actions. If employees find themselves in situations that are not explicitly set out in the Code of Conduct, we ask them to use their common sense. Availability The Code of Conduct is freely accessible to all PostFinance Ltd employees. We adopt an active, comprehensive internal communication policy with regard to the Code of Conduct. The Code of Conduct represents a binding part of the employment contract. Regular internal checks are carried out to ensure that each individual employee is sufficiently familiar with it. Violations Breaches of the Code of Conduct and the applicable requirements in force at PostFinance will not be tolerated and appropriate disciplinary action will be taken in proportion to the specific breach committed. Imposing sanctions on employees who have reported violations in good faith is prohibited. Reporting All employees can contact our specialist unit in connection with the Code of Conduct at any time in writing: questions can be sent and violations reported to the address codeofconduct@ postfinance.ch. 10

10 PostFinance Ltd Mingerstrasse Berne Switzerland ww w.postfinance.ch PF