Anti-Corruption Code of Conduct

Bank Handlowy w Warszawie S.A.

Introduction

Bank Handlowy w Warszawie S.A., operating under the name Citi Handlowy (“Bank”) takes a zero-tolerance approach to corruption and bribery in all aspects of the Bank’s activities.

The Bank cares for its image, reputation and trust which it enjoys among its clients and business partners by observing ethical norms and undertaking effective anti-corruption efforts.

Purpose

This Code of Conduct is a set of rules used by the Bank for the purpose of managing the risk of corruption and bribery both in Bank's internal relationships and its dealings with third parties.

This Code of Conduct is part of the Bank’s anti-corruption policy consisting of:

• Rules for giving and accepting gifts, participating in events and counteracting corrupt practices (the Bank has in place a formal process for approving and registering gifts and invitations to events),
• Code of conduct for the Bank's employees,
• Training programs,
• Information activities,
• Internal control mechanisms of the first and second level,
• Assessment of the risk of non-compliance as regards anti-corruption efforts.

Definitions

Corruption – means promising, soliciting, offering, giving or receiving, directly or indirectly, any kind of undue financial or personal advantage or benefit in exchange for acting or omitting to act in the performance of professional duties.

Financial advantage – any kind of good capable of satisfying a particular need. The Bank's policy defines financial advantages as gifts, events, meals or special events. This can involve not only an increase in the wealth of the person receiving the benefit, but also the award of favorable contracts, for example, loans, credit, contracts mandating the performance of specific activities or works, or other private financial advantage.

Personal advantage – a non-financial benefit improving the situation of the person who receives it, i.e. all that is deemed as beneficiary or satisfying the need of the person receiving the advantage, which does not have the form of money, for example: favoritism in providing
a job or a favor based on acquaintances and familiar relationships, awarding an honorary title, granting an award, acquiring certain skills.

Public Official – a person defined in Article 115 paragraph 19 of the Penal Code.

Code of Conduct

• All the Bank's employees and business partners acting on behalf of the Bank are committed to complying with the Bank's established rules for giving and accepting gifts, participating in events and counteracting corrupt practices.
• The conduct of rules establishing the relationships with Public Officials is an essential element of the anti-corruption policy.
• Anti-corruption policy is widely communicated and promoted at the Bank through mandatory training, guidelines and meetings with employees.
• The Bank prevents illegal practices by managing the risk of non-compliance by indicating the absolutely prohibited practices.

It is forbidden, among other things, to:
- accept or give gifts in the form of cash or its equivalent;
- accept or give gifts or organize events related to the business relationship that goes beyond the generally accepted customs and practices;
- make donations for political purposes.

Employee accountability

Preventing, detecting and reporting corruption and bribery is the responsibility of every Bank employee. There are appropriate guidelines in place that enable employees to identify and prevent the risk of corruption in dealings with business partners, including representatives, consulting companies, suppliers, distributors and subcontractors. All employees must avoid any actions that are likely to violate the zero tolerance policy on corruption and expose the Bank to allegations of engaging in practices in breach of the applicable norms and regulations.

Breach of the anti-corruption policy is considered employee misconduct and may result in the Bank taking disciplinary action against the employee as per the Work Regulations and the employee being held criminally liable under the generally applicable legal regulations.

Reporting policy violations

Any suspected breach of the anti-corruption policy or other legal regulations should be reported anonymously or with the reporting person's personal data by sending the reported violation to the following address:

Szef Pionu Zgodności
Bank Handlowy w Warszawie S.A.
Pion Zgodności
ul. Traugutta 7/9
00-950 Warszawa

The Bank employees may report policy violations by using the reporting channels described in the internal Bank regulations.

All such reported violations will be handled in a confidential manner and examined with due diligence. The Bank ensures the protection of personal data of the person reporting the violation and the person accused of the violation in accordance with the legislation in force.

http://www.citibank.pl/poland/homepage/polish/files2/informacja_o_przetwarzaniu_danych_osobowych.pdf

Corruption and bribery risk monitoring

The Bank continually monitors anti-corruption policy compliance with legal regulations in this regard.