Elimination of clash of interests

The Code of Ethics (hereinafter – the Code) of AS LTB Bank (hereinafter – the Bank) sets forth the principles, norms and standards of professional conduct and ethics, to ensure that the Council members, Board members, heads of departments and other employees of the Bank (hereinafter – the Employees) perform their duties with all due honesty, are objective when executing their employment duties and making decisions, observe laws, regulations and standards of compliance, respect the confidentiality of information concerning customers and transactions, as well as commercial secret, and that their conduct and behaviour meets the high standards of ethics. Hence it determines the quality of services that the public can expect when cooperating with the Bank.

The Code of Ethics defines the basic values of the Bank’s corporate identity and provides for the timely identification and management of potential conflicts of interests.

The implementation of the Code is supervised by the Board of the Bank.

Bank’s and Employees’ operation and action ethics basic principles

Lawfulness – performing their functions in the Bank, the Employees must observe the provisions of the regulatory enactments of the Republic of Latvia and international regulations, as well as requirements of the Bank’s internal regulations;
Quality – the Employees value professional, precise and creative work and aspire to do it as well as possible, in order to secure the effectiveness of the Bank’s work and the quality of its services, to stimulate the public confidence in the Bank;
Responsibility – the Employees are conscious of the impact of their activity on the overall results of the Bank’s work; therefore each Employee is personally responsible for the quality of services provided by the Bank;
Loyalty – it means not only the fulfillment of duties and instructions given by the Bank’s management, but also creative support, participation and helpfulness in relations with the Bank’s management and the colleagues. The Employees are conscious of the fact that their common work contributes to the Bank’s development;
Decency and consistency – the public confidence in the Bank depends on the independence and decency of each Employee; therefore the Employees treat their duties with decency and consistency, as well as act appropriately in case a dishonest action has been detected;
Honesty – the Employees adhere to a non-discriminating and equal attitude, fairness and honesty towards all partners and customers.

Basic values of the Bank’s corporate identity

The Bank, being an organized structure, is a constituent part of the society; its activity has an effect on the social environment, therefore the Bank acknowledges the responsibility for its activity before its Employees and the society.

The Bank acknowledges the necessity of competition and has a fair attitude to the competitors and their activity.

In its activity, the Bank observes the principles of environmental friendliness – meets all the environment protection requirements, as well as aspires to use the environmental resources most efficiently.

Any public information distributed by the Bank is prepared on a professional level, is lawful, clear and unambiguous.

The official opinion of the Bank is only expressed by those Employees who are competent and have been authorized by the Bank management to perform such actions; contact between the Bank and the public is maintained through the Bank’s website or mass media. None of the publicly expressed personal opinions of the Employees reflects the official opinion of the Bank.

Relations with partners and customers

Bank’s activity is aimed on its customers’ and partners’ concerns observation and on provision of customers’ required financial services within scope of mutual cooperation and understanding. In relations with partners and customers, the Employees respect and observe their wishes and interests and always provide the customers with all the information regarding the terms of cooperation – about the services, methods of settlement, execution of contracts and responsibility in case of non-fulfillment of contractual obligations, in order to give a customer a possibility to evaluate the appropriateness of the Bank services the customer needs.

The Employees’ attitude to the Bank’s partners and customers is based on the principles of equality, fairness and friendliness, which does not allow any discriminating action against the partners or customers irrespective of their financial status, income, type of the Bank services they use, volumes of transactions, or personal attitude towards a customer or partner.

Taking part in decision-making on the issues related to the partners’ or customers’ interests (preparing documents or taking a decision), the Employees provide the Bank with objective, complete and trustworthy information about them.

Executing their employment duties, the Employees must not give or accept gifts or other benefits if such gifts or benefits may be considered as reward or material stimulation. Gifts, other than souvenirs, from business partners or customers, are considered to be the Bank’s property.

Confidentiality of the Bank’s information

An Employee is careful when using, processing and storing the information entrusted to him/her, and observes the requirements of the Bank’s internal regulations that concern the classification and usage of such information.

Confidential information is any piece of information concerning the Bank, its customers or business partners and not published on the Bank’s website or in mass media.

The Employees act decently, observe confidentiality in all their actions, and care about the protection of information at all levels of the Bank’s activity:

personal data of partners and customers;
information about partners and customers – their accounts, transactions, economic activity, financial status, etc., – that can only be disclosed with the partner’s or customer’s written permission or in cases when such disclosure is required by the regulatory enactments of the Republic of Latvia or the European Union;
information about the Bank’s assets, financial data, intellectual property, internal regulations and information systems.

The Employees are conscious that the Bank’s competitive capacity and reputation depends on the security and confidentiality of information, its disclosure may create losses or otherwise affect the interests of the Bank, its customers or business partners, therefore any actions that may negatively influence the security of the Bank’s information are impermissible for the Employees.

The Employees are responsible not only for the nondisclosure of confidential information to third persons, but also for the prevention of such disclosure as a result of direct or indirect actions (inaction) of other employees or insufficient security of information systems.

The Employees are conscious that the information at their disposal is meant for the purposes of the Bank’s activity only, therefore the Employees do not allow its disclosure or use for obtaining any personal benefit. This also refers to any possible benefit that the third persons, including family members, might get out of the information disclosed by the Employees.

Identification and management of potential conflict of interests

Conflict of interests is a situation in which an Employee, in the course of fulfilling his/her employment duties, has to make a decision, participate in the making of a decision, or perform other activities related to his/her employment, that influence or may influence the Employee’s, his/her relatives’ or business partner’s personal or material interests, and that affects or may affect the Bank’s interests.

Bank identifies conditions which provoke or may provoke conflict of interests, which significantly endangers or harms other customer’s (customers’) business, and determine necessary steps to prevent conflict of interests.

The Employees prevent the occurrence of situations in which they, when fulfilling their employment duties, would or might experience a conflict of interests. The Employees refrain from by-work and sideline employments if those may create suspicions about the potential, seeming or real conflicts of interests, as well as cast a shadow over the Bank’s reputation.

The information provided by the Employees to business partners, existing and potential customers is clear, precise, true and not misleading.

The Bank secures that the departments performing actions between which there occurs of may occur a conflict of interests are mutually independent.

The conditions of transactions performed by the Bank with: the Bank’s shareholders having a substantial holding in the Bank, members of the Council and the Board, head of the department in charge of internal audit, other employees of the Bank authorized to plan, manage and control the Bank’s work and responsible for these functions, as well as the spouses, parents, children of such persons and companies in which such persons have a substantial shareholding, – are not different from the conditions of similar Bank transactions with persons that are not connected with the Bank, and are not in contradiction with the Bank’s interests.

The Employees refuse all gifts other than souvenirs in any deal related to the Bank’s activity, do not accept invitations to certain events if there is a danger of possible conflict of interests.