COVERED PERSONS
Conflict of Interest Policy shall be applicable to the following:
1. Board of Directors;
2. All Officers;
3. Rank and Files;
4. Consultants;
5. Immediate family members related to DOS up to 2nd degree of consanguinity or affinity; and
6. Any other individuals contracted to work in behalf of the Bank.
POLICY STATEMENT
The bank does not bear those who place their interest above that of organization, clients, or business partners. The conflict-of-interest policies in place to elevate the interest of the bank above that of the personal interests of directors, officers, and employees. These policies forbid directors, officers, and employees from using their position of authority or rank to directly or indirectly develop personal gain or advantage. Each employee is enjoined to exercise utmost discretion, prudence, and mature judgment in the discharge of his duties and responsibilities, so as to avoid both appearance and the fact of conflict of-interest situations, such as:
1. Transacting business, on behalf of the Bank, with institutions in which their affiliates are connected;
2. Engaging in lending and/or investing, trading and other similar business activities as well as borrowing and lending of money among and between employees and clients.
3. All employees must keep confidential information pertains to Bank that has not been made public and safeguard information of the Bank’s clients including its employee.
4. Personal trading using Bank to engage in treasury activities such as investment, dealing or trading by trading officers, traders and other officers and employees in the Treasury Department, Trust operations and Risk Management Department for their own personal accounts.
5. All trading transactions shall be done on an arm’s length basis, that is, in accordance with applicable regulatory procedures, accounting standards and provisions of the Philippine Laws as well as the Bank’s own internal standards in dealing with all clients and counter parties as well as those Bank’s affiliates and subsidiaries shall represent actual economic market transactions.
6. Dealing with the Bank’s clients, suppliers, contractors, service providers, etc. directly or indirectly such as:
a. Purchasing of goods or service from clients or supplier at lower market price;
b. Using Bank-client relations to be able to avail of special rates with respect to clients’ products and services;
c. Tries to influence business decisions including purchased and/or delivery of services by means of any commission, payment, special
discount on a product or service or any form of gift or donation;
d. Solicitation of personal business for personal interest from clients or the Bank’s supplier.
7. Another employment or accepting outside works without management approval;
8. Receiving of gifts, percentage, discounts and commission in exchange for a favor to a client is strictly prohibited;
9. Acceptance of bribes and token gifts voluntarily given in any form by a third party to a Director, Officer, Staff or Consultant may be acceptedand kept by the recipient is prohibited.
10. Directors, officers, staff and consultants are discouraged to use any property (e.g. vehicles, resorts and vacation houses) belong to a client, supplier, etc. for personal welfare or even for Company purposes.
11. All employees shall desist from soliciting in any kind from clients, suppliers and vendors such as sponsorship of bank activities, non-bank activities and or personal events where such may harm in the performance of their job. Exception is when the solicitation has been endorsed and with prior approval of the management.
12. All Directors, Officers, Staffs and Consultants refrain from receiving sponsorship, free travel and or any accommodations includes conventions, conferences, exhibits, or other similar events from clients, suppliers and or vendors. It may allowed if (i) the bank will benefit, (ii) prior approval of the management, (iii) all expenses paid by the Bank.
13. Citystate Savings Bank, Inc. shall deliver the same fairness, opportunity, transparency and accountability in dealing with suppliers, contractors, vendors in obtaining of products and services.
a. The Bank’s purchasing unit should give equal opportunity to bid with each suppliers, contractors and vendors.
b. Established proper criteria in dealing with its suppliers, contractors, vendors in conducting of bidding.
c. The Bank’s employee should not purchase goods and services from the suppliers/vendors other than normal course of transaction. Any
significant discounts in prices/rates, terms, etc. should be transparent and made available upon checking.
d. All business transaction with the suppliers/vendors should be properly documented and reflected in the books of the Bank.
e. All directors, bank employees should be free from any obligations to the suppliers/vendors and their positions should not be used for
personal interest.
f. Directors, Employees and Consultants should disclose their relationship with the suppliers/vendors their previous business / official transactions and their relationship with any of the stockholders, Employees and representatives in dealing business transactions directly or indirectly with such parties.
DISCLOSURE AND DISCIPLINARY ACTION
1. Directors, Employees or Consultants should disclose immediately any conflict of interest happened whether actual, misleading or probable immediately to the immediate supervisor.7 The disclosure should be made in writing copy furnish Human Resources Department and Compliance Office.
2. Any one is expected to report any conflict of interest or any other violations to the Heads of Human Resource Department, Compliance office and Internal Audit Department.
3. Investigation of the reported violations of this policy or the Code of Discipline shall be investigated by the Discipline Committee (DisCom) giving each party involve to explain.
4. Disciplinary actions is depend on the severity of the violations stated in the Code of Discipline.
5. In the case of the suppliers/vendors violating this policy, sanctions may impose but not restricted to termination of business relationship or blacklisting depend on the ground of the violation.
REVIEW
This policy is reviewed on a regular basis and at least once a year.