Code of Ethics of Erste Bank Hungary Zrt.

Code of Ethics of Erste Bank Hungary Zrt.

Contents Introduction 3 Purpose of the Code of Ethics 4 Related legislation 5 (Institutional) commitments of the Bank 6 Conduct towards customers 12 Conduct towards suppliers 16 Conduct at the workplace 17 Consequence Management and Ethics Committee 24 2

Code of Ethics of Erste Bank Hungary Zrt. It contains the commitments of the Bank and its rules applicable to employee conduct, which ensure that the employees act fairly when providing financial and investment services, bearing in mind the customers interests, It specifies norms of conduct, which contribute to strengthening the customers confidence in the Bank and the ethical operation of the Bank, It provides guidance for the employees of the Bank in their relationships and for the general behaviour to be followed in their business conduct. 3

The purpose of the Code of Ethics is to set the following uniform principles for all employees of the Bank and persons under other engagements with the Bank for work, and to ensure compliance with these principles: summary of the behavioural and work rules relating to the highest level of services to be provided to customers; compliance with the acts and other legislation, internal regulations and professional orders under any circumstances; compliance with professional requirements and work of impeccable quality; professional integrity, honesty, fairness and transparency; ethical business practices and conduct in line with the interests of the Bank; conduct based on responsibility and discretion; collegiality and teamwork. 4

Related legislation Act CCXXXVII of 2013 on Credit Institutions and Financial Enterprises Act CLXV of 2013 on Complaints and Reports of Public Interest Act V of 2013 on the Civil Code Act C of 2012 on the Criminal Code Act I of 2012 on the Labour Code Act CXII of 2011 on Informational Self-determination and Freedom of Information Act CXXXVIII of 2007 on Investment Businesses and Commodities Exchange Service Providers and the Rules Regarding the Activities Which They May Engage in Act CXX of 2001 on Capital Markets Act LVII over 1996 on the Prohibition of Unfair and Restrictive Market Practices 5

(Institutional) commitments of the Bank Compliance with legislation Provision of the highest level of services Protection of the employees rights Requirement of fair treatment Prohibition of unfair and restrictive market practices Fight against money laundering and the financing of terrorism Compliance with economic sanctions and embargoes Prohibition of bribery and anti-corruption attitude Property protection 6

1. Compliance with legislation The Management of the Bank is committed to full compliance with the legislation applicable to all of its activities relating to the services provided by the Bank (on its own right or as an agent) and to ensuring compliance with the same by the persons subject to the Code. Within its activities, the Bank complies and ensures compliance with the rules applicable to the protection of life, physical safety, health and the environment. 2. Provision of the highest level of services The Bank is committed to providing the highest levels of services in line with the customers true financial needs and risk assumption abilities. It uses its best endeavour to ensure high quality customer service, therefore, it continuously improves the quality of its services and continuously conducts customer satisfaction surveys in order to learn its customers opinion. 7

3. Protection of the employees rights The Bank takes into account its employees interests on the basis of fair consideration and respects their rights attached to their person. 4. Requirement of fair treatment The Bank is committed to comply with the requirements of fair business practices to the maximum extent and to have a fair attitude towards its customers, contractual partners, competitors and employees; provide equal opportunity to everyone in accordance with the principle of equal treatment irrespective of their citizenship, nationality, marital status (including registered life partnerships and partnerships recognised by the relevant acts), age, sex, race, colour, sexual identity, sexual orientation, political view, and political and religious affiliation. 8

5. Prohibition of unfair and restrictive market practices The Management of the Bank is committed to, and interested in, ensuring the prevalence of market conditions that create free and fair conditions and competition. The Bank refrains from any conduct that may result in the restriction market competition or the abuse of dominant position, such as: engaging in unfair economic competition (in a manner infringing or jeopardising the lawful interests of customers, competitors and partners); making or accepting proposals aimed at agreeing on buy or sell rates, dividing sources of supply, sharing marketing information affecting competition, and dividing the market and customers (cartel agreement); discussing topics that are considered relevant to the restriction of competition (e.g. rates, pricing policy, costs and marketing strategies) at the meetings of professional advocacy organisations; making the receipt or use of products or services dependent on the receipt of other goods or services (tie-in sales). The Bank considers financial institutions competitors that are entitled to fair, ethical procedures and compliance with the rules applicable to market competition and, at the same time, expects others to act in the same way towards the Bank. 9

6. Mylogo Fight is member of against Erste Group (this is money optional: please cancel laundering completely from the Master, and if not needed the or just financing cancel this info) of terrorism The fight against money laundering and the financing of terrorism is a global issue, against which the Bank, integrated into the financial system of the world, fights in cooperation with financial operators with the most stringent means, within the framework provided by law. It tries to prevent by continuous measures that its organisational system, infrastructure, products and services can be used for the purposes of money laundering and the financing of terrorism. Even in the case of the slightest suspicion of money laundering and the financing of terrorism, the Bank files the appropriate reports with the competent authorities. 7. Compliance with economic sanctions and embargos The Bank fully complies with the regulations of the European Union and the United States applicable to economic sanctions and embargoes. Economic sanctions may limit or prohibit business relations with the specified governments and organisations and persons acting on their behalf. Sanctions may include investments made in the territories of certain countries, engagement in trade with the given country, and the provision of goods, technologies and services (including financial and investment services). 10

8. Prohibition of bribery and anti-corruption attitude The Employees of the Bank must engage in conduct at all times that cannot give rise to even the appearance of bribery and corruption, and during their work, they may not promise or accept any benefit, money, gift or other valuables in any way; they may do so only within the framework of the relevant code of the Bank. Both forms of bribery (active and passive) are criminal offences. 9. Property protection The protection and preservation of the condition of the properties of the Bank and its customers and suppliers are every employee s essential job obligations. The fraudulent misuse of assets ( third party property ) placed in the employee s care constitutes a criminal offence. Physical objects, cash, securities, bank accounts, securities accounts, intellectual property and all information qualifying as bank secret, securities secret, insurance secret, cash desk secret, trade secret and personal data also qualify, among other things, as assets. 11

Conduct towards customers Ensuring compliance with legislation Provision of fair information to customers Professional awareness towards customers Protection of the data of customers (secrecy) 12

1. Ensuring compliance with legislation The employees of the Bank are obliged to draw the customer s attention to compliance with the relevant legislative provisions in force; may not propose or support a procedure, activity or conduct that may result in an infringement committed by the customer, including obligations towards the State (e.g. tax rules); are required by law to fulfil the obligation of reporting potential breaches of law to the competent authorities. The Bank has devised various procedures to screen out and report such conduct by perpetrators. 13

2. Provision of fair information to customers Fair and full information on the services to be provided must be provided to customers. In customer relations, efforts must be made to ensure that the customers understand the terms and conditions of the products offered and sold to them and are able to consider the risks that may be inherent in such products. 3. Professional awareness towards customers Conduct towards customers must be characterised by professional awareness, honesty, skills to take the initiative, helpfulness and a sense of responsibility. Everyone must aim at long-term relationships with customers; at the same time, they must always maintain their independence in their relationship with customers. 14

4. Protection of the data of customers (secrecy) The relationship between the Bank and its customers is based on mutual trust. The Bank declares its commitment to customers whereby it appropriately protects and treats their bank and securities secrets, personal data and other information defined by various secrecy provisions and available to the Bank. The Bank ensures that only those of its employees gain access to such information who are absolutely required to do so in order to fulfil their job duties. The employees of the Bank are obliged to keep the above information that has come to their possession without limitation in time. Such information may be disclosed to third parties only on the basis of the customer s written consent or in the cases itemised in the relevant act. 15

Conduct towards suppliers The Bank selects its contractual partners (suppliers) and enters into contracts with them on the basis of objective considerations. The Bank expects suppliers to enforce and ensure compliance with all principles and rules of conduct that have also been set by the Bank towards itself in the Code of Ethics and which the Bank itself adheres to in their whole supplier chain. It develops its business relations by bearing in mind these principles. The protection of trade secrets is enforced also in supplier relations: the Bank ensures also for its business partners that only those gain access to such information who are absolutely required to do so in order to fulfil their job duties. By applying the secrecy provisions of the contracts concluded with suppliers and the provisions of the separate secrecy declarations to be signed by suppliers, the Bank also establishes a guarantee for the protection of its own trade secrets. Conduct towards its business partners must also be characterised by professional awareness, honesty, skills to take the initiative, helpfulness and responsibility. An effort must be made to establish long-term relations also with business partners; at the same time, every employee must maintain their independence in their relations with business partners. 16

Conduct at the workplace General requirements for employees General requirements for managers Protection of reputation and trade secrets Prohibition of discrimination and harassment Prohibition of insider trading and market manipulation Conflict of interest Whistle-blowing System 17

1. General requirements for employees Their liaison with customers, colleagues and partners should be characterised by professional competence, attentiveness and discretion. Their conduct and appearance should meet the requirements of the Bank. In fulfilling their duties, they should follow the instructions of their superiors. They should perform their tasks carefully, with due assiduousness and skills to take the initiative, and in time. They should comply with the legislation applicable to secrecy. 2. General requirements for managers They should be just and consistent in their work relations. They should refrain from any conduct that may infringe their colleagues human dignity and the requirement for fair treatment. They should refrain from overstepping their competence. They should help create a confident atmosphere with open complication. 18

3. Protection of reputation and trade secrets Every employee of the Bank represents the Bank towards third parties. Employees should refrain from any conduct that may be suitable for infringing the reputation of the Bank both at and outside their workplace. must, when visiting community websites on the Internet (Facebook, Twitter, etc.), engage in conduct complying with the Code of Ethics, which may be expected of bank employees; are PROHIBITED to discuss topics that may also contain trade secret in public places. All facts, information, solution or data associated with the activities of the Bank, which may represent an advantage over competitors or, if disclosed, may cause a detriment to the Bank, qualify as trade secrets. 19

4. Prohibition of discrimination and harassment The Bank aims at creating a work environment in which cultural diversity is accepted and where individual differences are valued and respected. Any discrimination or harassment based on individuals citizenship, nationality, marital status, age, sex, race, colour, sexual identity, sexual orientation, political view, political, religious or cultural affiliation, origin, disability or any other difference in personal characteristics protected by law is absolutely unacceptable. 20

5. Prohibition of insider trading and market manipulation The laws of Hungary in force definitely prohibit and punish insider trading and market manipulation. It qualifies as insider trading if the employee learns insider information (thereby becoming an insider) and, by using such information, enters into a transaction for the financial instrument affected by such information or gives an instruction to conclude such transaction; passes on insider information to third parties (even if not receiving any consideration for it); recommends other people to enter into transactions for financial instruments affected by insider information. The person who has information influencing the price of financial instruments not known to market players is an insider. Insiderness arises when the person in question is aware that the information is insider information. The manipulation of the price or value of financial instruments quoted on the stock exchange or introduced to the regulated market qualifies as market manipulation. 21

6. Conflict of interest Employees may not engage in conduct and may not fill a position in connection with their position, work or the interests of the Bank, which results in a conflict of interest. Pursuant to the Credit Institutions Act, conflicts of interest may be personal or transaction-related. Pursuant to the Investment Businesses Act, all conflicts of interests that have or carry the risk of detrimental consequences to the customer, which may arise in respect of the provision of investment and supplementary services, must be treated as conflict of interest. All employees (both new hires and old employees) are obliged to make a declaration on conflict-of-interest issues. 22

7. Whistle-blowing System The Bank operates an employer s Whistle-blowing System pursuant to Act CLXV of 2013 on Complaints and Reports of Public Interest. The purpose of the Whistle-blowing System is to allow all employees and contractual partners of the Bank to anonymously report any misuse, abuse or breach of rules (including ethical rules) and obligations. The Bank will investigate every case reported, will establish whether any rule has been breached, and will take the necessary steps needed to solve the case. The protection of Whistle-blowers is especially important for the Bank, therefore, the Whistle-blower may not suffer any negative consequences due to his or her Whistleblowing. Reports made in good faith will not result in a legal disadvantage even when it is proven later that the conduct reported is not deemed misuse or abuse. 23

Consequence Management and Ethics Committee (CMC) The Bank applies the principle of zero tolerance in the case of concealing or hiding of ethical or fraudulent acts or participation in such acts (i.e. draws the boundary of tolerance against the perpetrator, shifts liability onto the perpetrator with all of its labour law, criminal law and other consequences). The Bank investigates any wilful or negligent breach of rules committed by its employees. On the basis of the investigation, the CMC makes a decision on sanctions and consequences. The CMC provides anonymous information to the employees of the Bank about the cases heard by it and the sanctions and consequences applied in such cases. 24