It is our wish for the clients to recognise the NLB Group as a trustworthy, sincere, correct, discrete and transparent financial institution, helping them ensure financial security and risk management. The clients and other stakeholders must also know the importance of ethical business and responsible conduct for the Bank.
In the framework of taking care of the employees, we pay great attention also to the assurance of positive climate among the employees, ethical operations, equality of employees, prevention of any hostilities and violence against employees and promotion of the freedom of speech. By ensuring employee satisfaction with work, we guarantee their personal satisfaction and thus better efficiency.
Compliance, responsibility and integrity of the NLB Group’s operations
Prohibition of any form of mobbing, as well as practical examples and guidelines for the employees have been included in the Code of Conduct of the NLB Group, which is the basic document defining the desired and prohibited conduct in NLB d.d. and the NLB Group. NLB d.d. has appointed the officer for the prevention of harassment and mobbing at work. It has also established the Joint Committee for the Prevention of Harassment and Mobbing, consisting of the representative of the Bank, the Workers' Council and the representative trade unions.
With the purpose to ensure the dignity of employees and to provide a working environment in which no worker is exposed to maltreatment and sexual or other harassment by anybody, the NLB has established a system for preventing all forms of mobbing. A special commission for the renewal of anti-mobbing mechanisms in NLB d.d., composed of the representatives of the Bank, the NLB Workers' Council and the NLB Trade Union, revised the Policy for Prevention of Harassment and Mobbing of Employees in Nova Ljubljanska banka d.d., the Rules on the Prevention of Harassment and Mobbing at Work in NLB d.d. and the Instructions for the business process Prevention of harassment and mobbing at work. By using these documents and the established procedures, the Bank also determines prohibited actions on case-by-case basis and defines the procedure for their treatment and sanctioning of prohibited actions.
Also at the level of the NLB Group, equal opportunities, justice and promoting culture focused on performance are respected. The personnel policies and practices are based on culture promoting equal opportunities and performance of employees. Discrimination is prohibited in the HR management practice. The relationship between employees and the management is founded on trust, support and constant feed-back. In the case of disagreement, the conflict resolution procedure is defined.
Employees participate in the Workers’ Council and the Trade Union with which the Bank regularly cooperates at formal meetings and through consultations. The organisational climate/employment engagement and organisational culture are of key importance and, therefore, regular measurements are carried out and also an action plan for improvements is prepared. In most cases personnel practice of the Bank is above legislative minimum because the goal of the Bank is to ensure that employees are highly motivated and included in the Bank's operations. In addition to penalty in the case of non-fulfilment of legislative requirements the employees are considered to be the key to success. This is the reason why the Bank regularly monitors engagement of employees and the organisational culture and regularly checks the personnel practice.
In the Code of Conduct of the NLB Group, the NLB Group prescribes its core values and principles of conduct, thus establishing uniform rules of conduct in the daily operations throughout the NLB Group. In this way the NLB Group expresses its expectations that all employees and external business partners of NLB d.d. and NLB Group members respect human rights, employee rights and general standards of conduct defined in the Code of Conduct of the NLB Group.
The Code of Conduct of the NLB Group was already comprehensively revised in 2017. Through regular activities (risk identification, investigation of suspected misconduct etc.), a regular review of appropriateness of its implementation is also carried out, which, considering the size of the NLB Group, is at a high level. The implementation of the Code of Conduct (formerly the Code of Ethics and the Code of Corporate Compliance) is verified by preventive checking of the compliance of the areas and processes, which also include risks of conduct (unethical behaviour, risks of internal and external fraud, conflict of interest risks, corruption risks, risks of violations in the field of information protection and personal data protection, etc.) as typical risks of compliance and integrity.
The NLB Group implements its standards of conduct by having established internal policies and procedures in order to prevent any breach of these standards, by carrying out regular training of employees and training of the target groups in the area of ethical conduct standards, and by performing regular assessments of risks in relation to outsourced providers and suppliers. Special procedures and channels for (anonymous) reporting suspected misconduct are established (including the internally accessible (NLB Net) and publicly accessibly application Whistler at: whistler.nlb.si), as well as procedures and mechanisms for treating suspected misconduct and adopting corrective measures. Measures for the protection of informants (internal and external) have been implemented in the whole NLB Group.
Additionally, an internal survey in the area of ethics and compliance is carried out annually in the core members of the NLB Group. This survey is carried out to check the perception of the Bank’s employees in relation to ethical conduct and compliance of operations, also in relation to the situation as regards the perception of misconduct prevention. Based on the analysis of which the Bank’s Management Board is informed, measures are drafted for the improvement of the situation, such as the implementation of target inspections of the areas of operation, special training, etc. In 2018, it was found based on the survey on ethics and compliance that the culture of ethics and compliance was strengthening, therefore, the NLB Group will continue to perform the activities aimed at increasing the awareness in this area.
The implementation of the Code of Conduct in the NLB Group is also a part of regular assessment in NLB d.d. in the area of corporate identity, and one element of that is the assessment of ethical culture, the efficiency of the system of prevention of misconduct or report of suspected violations, the tone at the top, the commitment of the Bank’s management, corporate identity, etc. The Code of Conduct of the NLB Group sets the standards and rules of conduct that apply to all employees, regardless of the job or location, as well as to the contractors acting on behalf of the NLB Group.
The Code defines the values and basic rules of ethical business conduct that are respected, encouraged and expected in the NLB Group. Our values and beliefs support our long-term goal which is to constantly improve the culture of our daily operations in the countries in which the NLB Group is present.
The NLB Group demands that every employee, regardless of their job or location of work, as well as every other stakeholder of the NLB Group, live in accordance with the highest standards of integrity in everything they do. The key for achieving these standards is strong culture of compliance practised by the NLB Group, with due diligence of all employees in accordance with its policies, rules and other internal acts and in line with the relevant legislation and regulations in the legal environments in which the NLB Group operates.
Protection of the privacy of bank clients is one of the key rules of conduct laid down in the Code of Conduct of the NLB Group. Additionally, the Corporate Security Policy of NLB d.d. defines the basic goals and principles of protecting people, facilities (business premises), information and assets of both the Bank and its clients. One of the key or fundamental goals of corporate security is to protect the data and information of our clients and thereby ensure privacy. With the implemented measures, the Bank ensures data confidentiality both as regard its own data processing and when the data are processed by contracted processors. One of the goals is also to ensure the legality of operations and the reputation of NLB d.d. This approach is also used by individual NLB Group members.
The risks arising from possible unauthorised access to data on clients, disclosure of data on clients and lack of professionalism or inappropriate behaviour of bank employees are managed by controlling accesses to applications with data and using audit trails, and precise methodologies, procedures and instructions for work.
The privacy of NLB d.d. clients and clients of individual NLB Group members is, following the new EU rules in the area of personal data protection (GDPR) which entered into force in 2018, ensured by implementing the relevant measures, such as:
- the need to know principle: in practice this means an employee has the authorisation or the right of access only to those data and information that they need to perform their regular work tasks;
- regular verification/checking of the adequacy of the rights granted to access data;
- regular training and raising the awareness of employees about the importance of data and information protection and ethical conduct;
- established privacy zones in the Bank's branches;
- identifying potential data protection violations by employees;
- carrying out security checks on application support and the computer network in order to identify potential vulnerabilities that would undermine the confidentiality of data and information.
The NLB Group already emphasised the awareness of the significance of fight against corruption and bribery in the Code of Conduct of the NLB Group by prescribing that the NLB Group has zero tolerance to such misconduct. All forms of bribery and corruption must be rejected in NLB d.d. and the NLB Group. These forms of action are unfair, illegal and damage the countries in which the corruptive practices take place, and the society in general. NLB d.d. and the NLB Group expect the same from our clients, business partners and third parties. NLB d.d. and the NLB Group expect the same from our clients, business partners and third parties. Therefore, all employees of the NLB Group are subject to limitations in giving and accepting gifts, offering hospitality and otherwise influencing the conduct of the employees of the NLB Group. Specific measures for managing the risks associated therewith are also prescribed. They are laid down in the Policy on Conflict of Interest Management and Corruption Prevention of NLB d.d. and the NLB Group.
In accordance with the Corporate Governance Policy of the NLB Group, the Standards for Compliance and Integrity also define obligations of the NLB Group members to adopt all internal acts of NLB d.d. on the prevention of corruption and conflicts of interest, and to comply with their obligations.
In 2018, the NLB Group members implemented the new Policy on Conflict of Interest Management and Corruption Prevention of NLB d.d. and the NLB Group, which, due to clearer rules, additional awareness raising, established control mechanisms and training in this field, represents a significant improvement in the implementation of respective activities.
Due to its regional presence, the NLB Group is exposed to the risks of corruption in South-Eastern Europe. In the scope of the SOTIS/ECRA process (General assessment of integrity and compliance risks/Enterprise Compliance and integrity Risk Assessment), which the NLB Group carries out annually, the assessment of the corruption risk at the level of NLB d.d., at the level of the core NLB Group members and at the level of the whole NLB Group is also carried out. A special questionnaire is used for that purpose (model World Economic Forum: Good Practice Guidelines on Conducting Third-Party Due Diligence, Partnering Against Corruption Initiative - PACI).
Based on the SOTIS/ECRA assessments made, in 2018 the NLB Group did not detect any significant new risk in the area of fight against corruption and bribery. Nevertheless, in the scope of their regular tasks, the compliance functions performed activities aimed at raising awareness and improving the risk culture also in relation to this area. Moreover, the approach to the management of such risks in daily operations was also enhanced, for instance by implementing the assessment of such risks in relations with suppliers.
In the scope of fight against corruption and bribery, the NLB Group performs several activities to manage the related risks. In 2018, regular annual training was organised for all employees and management in NLB d.d. and the NLB Group members in the field of corruption and conflicts of interest. Specific targeted training was also organised for target employee groups (sales network, managers, new employees) in the field of harmful practices, channels available for reporting suspected misconduct, corruption, conflicts of interests and breaches of the Code of Conduct of the NLB Group. The risk arising from conflicts of interest and corruption is assessed for outsourced providers and suppliers and other contractual partners of NLB d.d. and the NLB Group. The necessary procedures and mechanisms for treating suspected misconduct and adopting corrective measures in the case of suspected misconduct have been established. For appropriate identification of such events, various channels are used for reporting suspected misconduct, published on the Intranet (NLB Net), in internal documents (including the Code of Conduct of the NLB Group), and the internally and publicly accessible Whistler application for reporting suspected misconduct (also enabling anonymous reporting). NLB d.d. and the NLB Group have implemented the planned measures to protect the informants (internal and external), and defined who adopts them and in what way, and how the protection of informants is ensured.
Freedom of expression is one of the fundamental human rights that the NLB Group strongly encourages – both among the employees and in relations with our clients and other stakeholders, both on digital platforms and in personal communication.
Freedom of expression in NLB d.d.
Intranet NLB d.d. (NLB Net) thus enables publication of information and news about the developments concerning the Bank and in the Bank, commenting, asking questions, liking and giving ideas and making proposals, to which a special web page, “City of Ideas” (Mesto idej), is dedicated. Each organisational unit has its own Intranet web page, on which the employees actively cooperate in the designing of the contents and respond to them. Twoway communication is strictly encouraged, and it is taken care that questions are responded by relevant answers.
There is also a special web page for the Trade Union and the Workers' Council, which actively organise the web page and participate in the communication by making comments.
In 2018 we continued with live stream addresses by the president of the Management Board, a form of open communication named the Open House of President of the Management Board. It is a live stream, during which the President of the Management Board briefly summarises the current events in the Bank, and then answers questions that are posted by employees either through NLB Net or through the e-mail address created specifically for this purpose.
NLB d.d. encourages clients to send their opinion on their experience with the Bank, which they can do through several channels: by e-mail, via the website and social networks (in 2018, Facebook was added by Instagram), as well as directly by a call of video call to the NLB Contact Centre, and in area branches and branch offices. We find that the number of comments under the publications on the NLB Net is increasing, as well as the cooperation of employees in different prize games and surveys, in which they are asked about their opinion on the banking services or events in the Bank.
The employees are satisfied with the possibility of expressing their views and comments, since open communication contributes to a better atmosphere, trust and openness.
Promoting freedom of expression in other members of the NLB Group
In 2017 all members of the NLB Group established their NLB Net following the example of NLB d.d. NLB Net. Thus, comments and questions can be expressed in all members of the NLB Group. In addition, a common platform of the NLB Group – NLB Group Net was established in 2017, featuring the most topical news from all markets where the NLB Group operates. Freedom of comment and thus freedom of expression is provided on this platform as well. The NLB Group members also encourage their clients to give their opinion on their experience with the bank through channels and in the way as described above.
Lidija Žigić, President of the Management Board of NLB Banka Sarajevo, candidate for the Woman of the Year
We are proud that Lidija Žigić, President of the Management Board of NLB Banka Sarajevo, was nominated candidate for the Woman of the Year by the Ladies In Magazin
