The Bank has codes of conduct for its staff, the members of the Control Committee, the Board of Directors and the President. These codes are intended to serve as guidance in ethical dilemmas and to provide a shared approach to acceptable behaviour for NIB.
The codes of conduct are in place to prevent conflicts of interest, to prohibit the use of insider information, to provide guidelines for handling confidential information, for receiving and offering gifts, and for hospitality and representation. In addition, the codes contain limitations to the staff’s and the President’s possibility to trade in financial instruments.
Once a year, or when changes occur, the staff, the President and the members of the Board must disclose to the Chief Compliance Officer (CCO) any personal financial and business interests that might cause a conflict of interest.
The Code of Conduct for staff also requires staff to report any allegations or suspicions of fraud and corruption to the CCO of NIB.
To ensure vigilance and awareness among staff, the Office of the Chief Compliance Officer (OCCO) trains new staff and members of the governance bodies, and provides regular information sessions on the codes of conduct, integrity and fighting corruption.
As part of its training activities, OCCO has developed an e-learning tool for increasing awareness of the Code of Conduct for staff. The e-learning includes a test and will be rolled during 2016.