Breaches or compromise of this Code
of Conduct are treated seriously and may result in disciplinary action, as
established by the Bank, from probation, deduction of wages, demotion
and/or reduction in pay, up to termination of employment, as the case
maybe. Moreover, the Bank may consider not adjusting salary for those
under investigation or disciplinary actions being taken.
In 2022, there were 23 significant
cases of the Code of Conduct breaches, all of which were cases of
misconduct (no cases of corruption, bribery, discrimination, harassment,
violation of customer privacy data, conflicts of interest, money
laundering, insider trading, or antitrust/anti-competitive practices). All
of these cases had been managed and the Bank has enhanced its risk
management process and reviewed its internal control and compliance to
ensure higher efficiency and to prevent potential breaches. For instance,
significant work processes have been improved to be more prudent,
authentication process and power of attorney granted for financial
transactions has been monitored, and processes to detect employees’
misconduct and seeking undue benefits have also been enhanced. Moreover,
the Bank had considered these cases and taken actions against those who
failed to comply with the Code of Conduct through written warning,
deduction of wages and termination of employment, as the case may be.