Ethics, values and Compliance

mBank’s Code of Conduct is binding to all employees, managers and the Management Board. It forms the basis of internal relations and relations with external partners and suppliers. It defines acceptable and prohibited business practices, appropriate behaviour at the work place, financial rules and corporate social responsibility.

We appointed an Ethics Officer in 2018, who:

• helps to develop ethical standards for the bank and co-ordinates their execution,
• supervises Compliance of the bank’s activities with those standards among others by issuing opinions on motions tabled to the Management Board,
• is responsible for making the ethics topics more populat among the employees, among others through the intranet,

• prepares guidelines, isues opinions and supports employees in resolving ethical dilemmas
• sits in the Anti-mobbing Committee,
• represents the bank in the Ethics Committe of the Polish Banks Association.

The Ethics Officer prepares the, accepted by the Management Board, so called Lessons learnt – available for all the employees descriptions of real cases, when the company avoided making a mistake of an ethical character or corrected the mistake already made, and thus improving the standards of work basing on this knowledge.

The real or potential irregularities – breaches of procedures, internal regulations or our ethical rules – can be reported by employees and clients anonymously not only to the ethics oficer, but alsothough the continouosly developed whistleblowing app.). It can be used daily, 24h, on every computer with access to the internet. More detailed information can be found at bkms-system.net.

In 2019 we will examine the knowledge on how to deal with ethical issues among employees, among other by measuring the popularity of whistleblowing app. The ethics oficer will prepare the etihs trainings programme, tailored to the needs of particular areas. Moreover, we plan to introduce the UN Global Compact ethical standard.

We always check whether the investment applying for financing by mBank has valid decisions and consents issued by relevant administrative bodies. We reduce the risk of our clients’ funds being involved in illegal projects, e.g. without public consultations or compensation for environmental losses.

In the case of large projects, financed by bank consortia, we employ or require the employment of a technical advisor. It secures the investment process and monitors its progress, which allows for quick detection of potential irregularities, including social or environmental ones.

Moreover, the Policy on providing services and financing to entities operating in areas that are particularly sensitive in terms of mBank’s reputation risk (in force since January 1, 2016) introduces restrictions on opening accounts and granting loans to companies, including existing customers of the bank that operate:

• based on child labour, forced or otherwise grossly human rights abuses,
• oriented towards economic exploitation of areas of high natural value,
•  threatening the global cultural heritage.

Such an approach is directly in line with The Ten Principles of the UN Global Compact, to which we have been signatories since 2015.

We have also included provisions concerning social and environmental risks in the following documents:

• mBank’s credit risk policy towards corporate clients, updated in 2018,
• The rules for financing defence entities.

The public’s confidence in financial service providers relies on their full compliance with the applicable laws and regulations. For this reason all our plans, including new products and services, are subject to in-depth multi-step compliance review. Furthermore, we monitor expected legal amendments and prepare our organisation well ahead of time.

The importance we attach to this area and the effectiveness of our procedures are confirmed by the small number of complaints concerning non-compliance of mBank Group companies with the law and regulations in the social and economic area.

In 2018, a total of 5 cases against mBank (Financial Ombudsman, Municipal Financial Ombudsman, subpoena to a court settlement attempt and to the Commission on Banking Ethics) were filed through dispute resolution mechanisms.

We are actively involved in the activities of various associations. We are a member of both international and national organisations and regions in which we are present.