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Group Conflicts of Interest Policy

The Group Policy’s main objective is to set out general principles in order to ensure that the Group establishes implements and maintains effective conflicts of interest policies and procedures for the identification, prevention and management of Conflicts of Interest (COI) and to comply with legal and regulatory framework.

All Bank stakeholders and especially Directors, Management body and all members of staff have a personal responsibility to disclose any COI and abstain (or obtain relevant measures) from a transaction that may have a COI. This responsibility should be explicitly stated in all employment contracts, agreements with various stakeholders, service providers, suppliers etc. (The full policy forms part of the Board manual app 15)