Group Whistleblowing Policy
Bank of Cyprus Group promotes high standards of ethics and a transparent compliance culture that encourages accountability and detects and discourages any form of misconduct. Bank of Cyprus’s whistleblowing procedure provides confidential and secure means for our employees to report and raise concerns about practices or conduct that is contrary to our values and principles.
More specifically, the Policy general principles include:
- Concerns in good faith, about wrongdoing or malpractice are raised in confidence or anonymously without fear of victimization, discrimination, disadvantage or dismissal.
- A climate of accountability is promoted with respect to Group resources, including its employees and key stakeholders.
- Procedures for the reporting of any matters of concern are clearly provided. The persons concerned are able to bypass the main channels for whistleblowing if these prove inappropriate, and use the anonymous/confidential reporting line.
- Disclosures are managed in a timely consistent and professional manner
- Reported incidents will be verified in the appropriate manner and if confirmed, the Bank shall take all necessary steps to identify appropriate remedies.
Group Corporate Governance Policy
The Board of Directors, management and staff of the Group must comply with the provisions of this Policy which acts as a guide to principles, actions and responsible conduct. This Policy applies to the entire BOC Group, its subsidiaries and affiliate companies for compliance.
The Policy, in conjunction with the Bank’s Articles of Association, By-Laws, the Board Manual and the charters of the Board Committees, constitute the governance framework of the Bank. (The full policy forms part of the Board manual app 16)
Group Fitness & Probity Policy
This Policy sets out in writing the Group’s strategy in assessing the fitness and probity of persons who hold, or who are appointed or elected to an assessed position. This is in line with the professional values and long-term interests of the Group and its Code of Conduct. As part of the governance structure of the Group, the Fitness & Probity Policy provides for prudent management and strengthens the efficiency of risk management of the Group.
In brief, the responsibilities of the Bank in relation to the above legal and regulatory framework are:
- To make the initial and continuous assessment of the fitness and probity of assessed persons
- To ensure that assessed persons have the requisite experience, specialisation and knowledge for the discharge of their duties and responsibilities
- To ensure that the assessed persons demonstrate honesty, reliability and integrity, characteristics which promote the culture of compliance in an organisation
- To ensure that the NCG Committee adopts the necessary internal policies for the assessment of the fitness and probity of assessed persons.
This document sets out the criteria for the assessment of the suitability of persons who hold specific and important positions within the Group and the appropriate procedure to be adopted and implemented in order to ensure that the persons involved are suitable for the position they hold on a continuous basis.
The requisite knowledge, experience and abilities of each individual as well as the general requirements for the composition of the Board of Directors are factors that may ensure that informed and professional decisions are taken for the direction of the Bank, the risk management oversight and the regulatory environment it operates in. (The full policy forms part of the Board manual app 17)
Group Board Diversity Policy
The Bank of Cyprus Group recognizes the benefits and necessity of having an adequately diverse Board which will include and make good use of differences in the skills, regional and industry experience, background, race, age, gender and other distinctions between Directors. Such differences will be taken into account when determining the optimum composition for the Board. All Board appointments will be made primarily on merit based on skills, ethics and experience and irrespective of colour, race, nationality /ethnicity, disability, age, gender, religion, sexual orientation, political opinion or any other unfair criterion. (The full policy forms part of the Board manual app 23).
Following the issue of the Group Diversity Policy in May 2015, the Board endorsed the recommended target set by the Nominations and Corporate Governance Committee for a minimum female participation of 40% in the Board as from year 2020. An action plan, which currently is in progress, was approved by the Nominations and Corporate Governance Committee in June 2016 describing the intervening actions leading to the accomplishment of this target.
Group Conflicts of Interest Policy
The Group Conflicts of Interest Policy’s main objective is to ensure that the Group maintains effective conflicts of interest processes and procedures for the identification, prevention and management of Conflicts of Interest (COI) and to comply with the legal and regulatory frameworks.
All Bank stakeholders, in particular Directors, Executives and Managers including all members of staff have a personal responsibility to disclose any COI and abstain from a transaction that may have a COI or take the appropriate steps to manage the 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)
Group Nominations Policy
The Group Board Nominations Policy describes a) the Board’s process for identifying Director nominees b) the manner by which shareholders may recommend Director nominees and c) minimum Director qualifications.
The Nominations and Corporate Governance Committee conducts the search for suitable candidates by identifying individuals qualified to become members of the Board of Directors and recommends to the Board, the nominees to stand for election as Directors. In considering candidates the Committee will take into account whether a candidate has the skills, experience and background that adds to and complements the range of skills, experience and background of existing Directors. (The full policy forms part of the Board manual app 4)
Group Anti Bribery Policy
The Group values its reputation for ethical behaviour and for financial integrity and reliability. It recognizes that over and above the commission of any crime, any involvement in bribery will damage its image and reputation.
The Group is committed to prohibit the offering, promising, giving, accepting or soliciting of an advantage (monetary or not) as an inducement for an action which is illegal or a breach of trust or for performing functions or activities improperly or to reward persons for already performing their activities improperly.
This policy has been adopted by the Board of Directors and is communicated to everyone involved to ensure their commitment to it. The Board of Directors applies a "zero tolerance" approach to acts of bribery by any of our employees or any business partners. (The full policy forms part of the Board manual app 14)