Code of Conduct

1. Purpose

This Code of Conduct (Ref: COMP-CE-001) establishes the fundamental principles and standards of professional behaviour that the Bank expects of every individual acting on its behalf. It reflects the Bank's commitment to operating with integrity, fairness, and transparency in all of its dealings with customers, regulators, shareholders, and the wider community.

2. Scope

This Code applies to all employees (permanent, temporary, and contract), officers, directors, and any third party acting on behalf of the Bank, regardless of seniority, function, or geographic location.

3. Core Principles

3.1 Integrity

All individuals must act honestly and with integrity in all professional activities. The Bank expects the highest standards of ethical conduct, and employees must not engage in any behaviour that could bring the Bank into disrepute or undermine trust in the financial system.

3.2 Client-Centric Conduct

The interests of the Bank's clients must be at the centre of all business decisions. Employees must treat customers fairly, provide clear and accurate information, and ensure that products and services are suitable for the customer's needs. This obligation is reinforced by MiFID II conduct requirements and the FCA's Consumer Duty (where applicable).

3.3 Compliance with Laws and Regulations

All employees must comply with applicable laws, regulations, and internal policies. This includes, but is not limited to, anti-money laundering legislation, data protection regulations, sanctions requirements, market abuse regulations, and prudential rules. Ignorance of the law is not an acceptable defence.

3.4 Respect and Inclusion

The Bank is committed to a workplace free from discrimination, harassment, and bullying. All employees must treat colleagues, clients, and business partners with respect and dignity, regardless of race, gender, sexual orientation, religion, disability, age, or any other protected characteristic.

3.5 Confidentiality

Employees must protect confidential information, including customer data, proprietary business information, and trade secrets. Confidential information must only be disclosed on a need-to-know basis and in accordance with applicable data protection and information security policies.

4. Specific Obligations

4.1 Conflicts of Interest

Employees must identify, disclose, and manage any actual or potential conflicts of interest. Personal interests must never take priority over the interests of the Bank or its clients. Refer to COMP-CE-003 for the full Conflicts of Interest Policy.

4.2 Gifts and Entertainment

Employees must not offer or accept gifts, hospitality, or entertainment that could create a conflict of interest or the appearance of impropriety. All gifts and entertainment above EUR 100 must be declared and pre-approved. Refer to COMP-CE-004 for detailed requirements.

4.3 Anti-Bribery and Corruption

The Bank has zero tolerance for bribery and corruption. Employees must not offer, promise, give, request, or accept any bribe, facilitation payment, or improper inducement, whether directly or through third parties. The Bank complies with the UK Bribery Act 2010, the US Foreign Corrupt Practices Act, and equivalent legislation in all operating jurisdictions.

4.4 Market Conduct

Employees with access to inside information or who participate in the Bank's trading activities must comply with the Market Abuse Regulation (EU No 596/2014) and all applicable market conduct rules. Insider dealing, unlawful disclosure of inside information, and market manipulation are criminal offences. Refer to COMP-CE-005 for the Market Abuse Prevention policy.

4.5 Whistleblowing

Employees who become aware of actual or suspected misconduct, regulatory breaches, or unethical behaviour are encouraged and expected to report their concerns through the Bank's whistleblowing channels without fear of retaliation. Refer to COMP-CE-002 for the Whistleblowing Policy.

5. Consequences of Non-Compliance

Breaches of this Code may result in disciplinary action, up to and including termination of employment, and may also give rise to criminal or regulatory proceedings. All employees are required to attest annually that they have read, understood, and will comply with this Code.

6. Reporting Concerns

Employees may report concerns or seek guidance through their line manager, the Compliance Department, the HR Department, or the confidential whistleblowing hotline.

7. Review

This Code is reviewed annually by the Legal & Compliance Department. Next review: Q1 2027.