Principles of Conduct and Work Ethics in Financial Institutions

In the name of Allah, the Most Gracious, the Most Merciful Saudi Arabian Monetary Authority Headquarters

Office of the Deputy Governor for Supervision
Ref No: 72203 / 67
Date: 04/12/1440
Attachments: 15 rolls

Circular

The Pious
Dear Sirs,
Peace, mercy, and blessings of Allah be upon you,

Subject: Principles of Conduct and Work Ethics in Financial Institutions.

Referring to the supervisory and regulatory role of the Saudi Arabian Monetary Authority over financial institutions under its supervision, and its efforts aimed at protecting the reputation of financial institutions and ensuring that their employees adhere to the principles of prudent conduct, alongside achieving the concept of sound governance and enhancing professional performance and professional behavior.

Attached are the Principles of Conduct and Work Ethics in Financial Institutions, aimed at enhancing professional discipline, integrity, transparency, objectivity, efficiency, loyalty, and effectiveness in the behavior of financial institution employees while performing their duties and tasks.

For your information, and to act in accordance with the provisions of these principles within three months from the date thereof, with providing the Authority with a compliance plan within one month from the date thereof.

Accept my regards,

Fahd bin Ibrahim Al-Shamri
Deputy Governor for Supervision

Distribution Scope:

Banks and commercial banks operating in the Kingdom.
Financing companies and factoring companies operating in the Kingdom.
Insurance companies, reinsurance companies, foreign insurance companies, and licensed free profession companies operating in the Kingdom.
Credit information companies operating in the Kingdom.

P.O. Box 2992, Riyadh 11169, Phone: 4662300 - Fax: 4662543

Principles of Conduct and Work Ethics in Financial Institutions August 2019

Saudi Arabian Monetary Authority
Saudi Arabian Monetary Authority

Table of Contents
First: Introduction 2
A. Objective 2
B. Scope and Adoption 2
Second: Definitions 2
Third: Principles of Conduct and Work Ethics 3 A. Adherence to Professional Conduct and Public Morals 3 B. Interaction with Stakeholders 4
C. Combating Financial and Administrative Corruption 5

Combating Money Laundering and Terrorist Financing and Suspicious Transactions 5
Combating Bribery and Corruption 6
D. Gifts and Hospitality 6
E. Adherence to Systems, Regulations, Instructions, and Policies 7 F. Dealing with Conflicts of Interest 8 G. Maintaining Confidentiality and Information Disclosure Mechanisms 8
Classification of Financial Institution Information 8
Confidentiality Classification 9
H. Use of Insider Information and Market Manipulation Leaks 13
I. Reporting Actual or Potential Violations 13
J. Rewards and Incentives 13
Fourth: Consequences of Non-Compliance with Principles of Conduct and Work Ethics 14

Page Number	Issue Date	Issue Number	Principles of Conduct and Work Ethics in Financial Institutions
1-14	August 2019	1.0

First: Introduction

A. Objective
The Principles of Conduct and Work Ethics in Financial Institutions contained in this document aim to ensure that the performance of financial institution personnel is within a system of ethical values and principles that enhance professional discipline, integrity, transparency, objectivity, efficiency, loyalty, and effectiveness in the behavior of financial institution employees while performing their duties and tasks.

Consolidating these behavioral and ethical principles will achieve the vision and mission of the financial institution, protect its reputation, and ensure that its employees adhere to the principles of prudent conduct, and achieve the concept of sound governance and enhance the professional performance and professional behavior of its personnel, rewarding the diligent and holding the negligent accountable, and improving the image of the financial institution in general.

Therefore, these principles must be transformed into behavior and practices applied by financial institution personnel, and continuous guidance through all possible communication channels by the financial institution, and they must form a reference tool that outlines the basic rules guiding them on how to interact with each other when performing their duties and the qualities they must possess.

B. Scope and Adoption
These principles apply to all financial institution personnel, provided that the Board of Directors of the financial institution adopts a code of conduct and work ethics for them in accordance with these principles and the relevant systems, regulations, and instructions issued by the competent authorities.

These principles define the minimum rules of conduct, and all managers within the financial institution are responsible for enabling their employees to access these principles, having them acknowledge them, attaching them to the employee's file with the competent administration, and ensuring that they are aware of them. They are also responsible for determining whether more detailed instructions or procedures are needed within their administration to comply with these principles. The financial institution must provide all its personnel with a sufficient understanding of these principles during their onboarding period.

Second: Definitions
A. Work Ethics: A set of ethical standards, rules, and behavioral etiquettes that an employee must possess in their profession towards their work, fellow employees, and society as a whole.

B. Financial Institution: Banks, commercial banks, branches of foreign banks, insurance and reinsurance companies, foreign insurance companies, free profession companies, financing companies, factoring companies, and public credit information companies in the Kingdom supervised by the Saudi Arabian Monetary Authority.

C. Financial Institution Personnel: Board members, supervisory board members, executive officials, employees (permanent and retired), consultants, and employees working through a third party.

D. Stakeholders: Anyone with an interest in the financial institution, such as shareholders, creditors, customers, employees, and any external party.

E. Professional Conduct: Performing job duties with honesty, integrity, and objectivity according to best practices, and continuously striving to achieve the financial institution's goals, with practices within the scope of authorized powers, and performing work without negligence and without violating systems and regulations, and not for the purpose of harming the public interest or achieving personal interest.

F. Insider Information: Any information, data, numbers, or statistics, whether verbal, written, or electronic, obtained or accessed by any financial institution personnel by virtue of the nature of their work or by virtue of their assignment to the financial institution, which is not available to others.

G. Confidential Information, Data, or Documents: Any information or documents not available to the public which relate to the work and administrative and financial arrangements or the financial status of the financial institution.

H. Conflict of Interest: The situation in which the objectivity and independence of any financial institution personnel are affected during the performance of their duties by a confirmed or potential personal material or moral interest in them or in one of their acquaintances, or when their performance of their job is affected by direct or indirect personal considerations, with their knowledge of information related to the decision.

I. Personal Interest: The personal benefit that can be achieved by any financial institution personnel by virtue of the nature of their work or their job position and the authorities entrusted to them.

J. Disclosure: The employee informing the competent administration in the financial institution of the cases specified by the financial institution as requiring disclosure according to the disclosure policy prepared by the financial institution.

K. Regulatory Accountability: Holding a person accountable for actions issued by them in violation of prevailing systems and policies, which leads to harm to others or to the interests of the establishment where they work.

Third: Principles of Conduct and Work Ethics

A. Adherence to Professional Conduct and Public Morals Financial institution personnel must adhere to the following:

Upholding the highest ethical standards through transparency, integrity, honesty, and good morals in all dealings among themselves and with stakeholders.
Rejecting everything that undermines the honor and dignity of the position, whether inside or outside the workplace or during non-working hours, and abstaining from any actions or practices that violate etiquette, traditions, and general customs, and staying away from delving into the political affairs or religious or sectarian beliefs of others or inciting against them, or any form of racism.
Not obstructing the flow of work or causing disturbance or inciting to it.

Page Number	Issue Date	Issue Number	Principles of Conduct and Work Ethics in Financial Institutions
2-14	August 2019	1.0

Page Number	Issue Date	Issue Number	Principles of Conduct and Work Ethics in Financial Institutions
3-14	August 2019	1.0

Performing work with accuracy and objectivity to achieve the interest of the work, and upgrading work skills through continuous learning and training.
Maintaining the reputation of the financial institution by not harming it through publishing information, statements, or comments about it through using media or various communication channels or by any means or method whatsoever.
Preserving working time (official duty, overtime, or official missions) for performing and completing work tasks.
Maintaining professional secrets related to work, and not disclosing any information whose disclosure may harm the interest of the financial institution, whether during the period of work or after leaving it.
Ensuring familiarity with systems and applying them without any violation, non-compliance, or negligence.
Adhering to the official dress code and public morals in harmony with the systems of the Kingdom of Saudi Arabia during official working hours, training courses, and all occasions and participations where the employee represents the financial institution.
Obtaining prior approval from the financial institution in case of publishing information, statements, or comments about it through using media or various communication channels or by any means or method whatsoever.
Optimal and permitted use of the information technology infrastructure and technical resources owned and belonging to the financial institution in a manner that does not conflict with the flow of work.

B. Interaction with Stakeholders

Stakeholders are of great importance in the financial institution, and they must be treated in a manner that achieves transparency, integrity, and cooperation with the highest standards of professionalism. The stakeholder policy prepared by the financial institution defines the general principles and guidelines for relations with them through:

Ambition: That the financial institution be the most trusted partner and the best experience for stakeholders, making business easy and fast.
Connection: That the financial institution be a constructive partner for stakeholders by providing clear and honest advice, and providing necessary information about products and services to make sound decisions.
Response: That the financial institution gives importance to stakeholder complaints and comments and manages them promptly, effectively, and fairly in accordance with prevailing systems and regulations and to achieve the highest standards of professionalism.
Enhancing the principle of trust: That the financial institution provides clear, understandable, accurate, and updated information to stakeholders within the framework of mutual trust in all its services and operations, and performs stakeholder services in a timely and complete manner, where time factor is an important element in the financial system.

C. Combating Financial and Administrative Corruption

Combating Money Laundering and Terrorist Financing and Suspicious Transactions

Money laundering and terrorist financing are criminal activities in the Kingdom of Saudi Arabia based on the Anti-Money Laundering System, the Anti-Terrorism Crimes and Financing System, and their implementing regulations. These systems and regulations also include preventive measures that financial institutions and their officials must commit to implementing. The consequences of those crimes committed do not affect only the financial institution but extend to affecting society and the state. Therefore, the financial institution must have policies and procedures that include strict measures to limit the risks of misuse for financial crime purposes. It is incumbent upon financial institution personnel to combat financial crimes, including money laundering and terrorist financing, and to be cautious of any unusual or suspicious activities and report them to the General Department of Financial Investigations in accordance with regulatory requirements.

It is incumbent upon financial institution personnel to apply instructions related to combating money laundering and terrorist financing, including reporting suspicious transactions and activities, and not to alert or hint to the reported person or any other person that they have been reported. In case the report is proven to be unfounded, the reporter bears no responsibility towards the reported person when reporting in good faith.

The financial institution must not assign any of its personnel to anti-money laundering and counter-terrorist financing duties unless they are enrolled in specialized and accredited courses related to combating money laundering and terrorist financing, in addition to providing necessary awareness to all its personnel on matters related to combating money laundering and terrorist financing by all appropriate means such as training courses, newsletters, etc.

Duties and responsibilities of financial institution personnel to achieve this:

Commit to applying the Anti-Money Laundering System, the Anti-Terrorism and Financing System, and the Saudi Arabian Monetary Authority instructions on combating money laundering and terrorist financing.
The employee performs their job duties and tasks in accordance with honesty, integrity, accuracy, and professionalism.
Not engaging in any criminal activities or money laundering or terrorist financing transactions.
The concerned administration in the financial institution must immediately report to the competent administration for combating money laundering and terrorist financing in the financial institution, which in turn reports to the General Department of Financial Investigations at the Saudi Arabian Monetary Authority about all suspicious transactions carried out by stakeholders or financial institution personnel.
Not alerting or hinting to stakeholders, personnel, or others that their activities, which are under investigation by the financial institution or have been or will be reported to the competent authorities, are suspected.

Combating Bribery and Corruption

Bribery is one of the most dangerous crimes and has the most impact on the corruption of societies. The financial institution must condemn corruption and bribery in all its forms, and never allow corruption and bribery in any interaction or interaction with stakeholders. The financial institution also commits to promoting and educating its personnel on the seriousness of the crime of bribery and corruption and its negative effects at the level of the financial institution and society as a whole.

Duties and responsibilities of financial institution personnel to achieve this:

Reporting to managers or competent administrations in the financial institution in case of suspicion of the existence of corruption or bribery.
Not accepting nepotism or favoritism in performing work duties and responsibilities, which may negatively affect the trust of dealings with the financial institution.
Not resorting to any form of moral or administrative corruption and using suspicious or illegal means to complete work.
Not abusing official authority and exploiting influence, and reporting to the competent administrations in the financial institution in case of a case of abuse or exploitation.

D. Gifts and Hospitality

In the context of relationships, gifts and hospitality are offered or accepted. All financial institution personnel must exercise caution and apply sound judgment when offering and accepting gifts from or to stakeholders, to protect the integrity of both the employee and the financial institution according to the Gifts and Hospitality policy approved by the financial institution.

In pursuit of the principle of professionalism and professionalism, it is evaluated whether the gift or hospitality is reasonable, appropriate, and customary, taking into account the value, nature, and timing of the gift/hospitality and the presumed intentions. Financial institution personnel must consider the following:

A. Not requesting or accepting any gift, invitation, service, or item of material or moral value, whether for oneself or for one of one's relatives, from a person or organization that has a relationship or seeks to have a relationship with the financial institution, which could have a direct or indirect effect on the objectivity of financial institution personnel in performing their duties, or which could influence their decisions or force them to commit to something in exchange for accepting it.

B. Regulatory accountability applies to anyone proven to have committed, participated in, or assisted in violating systems related to requesting or accepting gifts and invitations, and this applies equally to current and former financial institution personnel.

C. If refusing the gift would cause offense to the financial institution, or if returning it is not practically possible, or if it was offered to financial institution personnel in official visits and occasions or when receiving official guests, which includes rules of courtesy and visit protocols and occasions acceptance, the gift may be accepted provided that the following are observed:

It must not be cash in any case, or in the form of a loan, or shares, or financial derivatives.
The gift and its value must be customary to offer, according to the occasion it was offered for and its nature, such as trophies, for example, but not limited to.
If the gift is a discount or waiver of fees, it must relate to an invitation to attend a conference or meeting that enhances knowledge and has a positive impact on the work of the financial institution and does not give rise to a conflict of interest.
The gift offered must not be related to the recipient's share in the financial institution or was offered as a result of working in the financial institution.
The giver of the gift must not have a special or general interest they hope to obtain from the financial institution or one of its personnel.
D. The employee may accept an award from other entities with which the financial institution deals as a result of achieving an achievement, subject to the following:
The award must be part of a declared, recognized, and directed program given on a regular basis.
Winners must be selected according to declared criteria.
Obtaining prior approval from the financial institution for this.
E. The recipient of the gift must provide a written disclosure directly to the compliance administration after receiving the gift through a disclosure form in the following cases:
If the gift has value and can be sold for it.
If the gift is perishable and its value exceeds (1000) Riyals.
F. Financial institution personnel are prohibited from offering gifts, donations, and invitations to those who have a work relationship with the financial institution in a personal capacity, unless offered through the competent administration according to the policy approved by the financial institution on this matter. G. Accepting or requesting gifts and donations that entail the possibility of harming the reputation of the financial institution is prohibited.

E. Adherence to Systems, Regulations, Instructions, and Policies

Adherence to systems, regulations, instructions, and policies is one of the most important foundations and factors for the success of the financial institution and maintaining its reputation and credibility. Its personnel must ensure familiarity with and compliance with the prevailing systems, regulations, instructions, and policies related to work and their assigned duties, and apply them without any violation, non-compliance, or negligence, and not conduct any transactions in the name of the financial institution that may violate the systems, regulations, instructions, or policies related to the financial institution.

Page Number	Issue Date	Issue Number	Principles of Conduct and Work Ethics in Financial Institutions
6-14	August 2019	1.0

Page Number	Issue Date	Issue Number	Principles of Conduct and Work Ethics in Financial Institutions
7-14	August 2019	1.0

F. Dealing with Conflicts of Interest

To protect the financial institution and stakeholders, all financial institution personnel bear the responsibility of identifying any potential or actual conflict of interest that may negatively affect the financial institution / or stakeholders. In cases where a conflict of interest cannot be prevented, it must be managed appropriately, so that the financial institution manages conflicts of interest through a set of controls, policies, and procedures.

G. Maintaining Confidentiality and Information Disclosure Mechanisms

Information is an important asset for the financial institution's business, and preserving it is an important factor for the success and continuity of the financial institution. All information related to stakeholders at the financial institution or its personnel is the property of the financial institution. The financial institution must prepare a set of controls and procedures for destroying unused or damaged documents and devices.

The financial institution classifies information in terms of confidentiality degree as follows:

Classification of Financial Institution Information

A. General Information:
Information that falls within the public scope and is available free of charge and available to the public through one of the authorized channels of the financial institution.

B. Internal Information:
Information that is not disclosed to persons from outside the financial institution.

C. Confidential Information:
All non-public information related to the financial institution or its personnel or stakeholders. Financial institution personnel who are aware of this information must protect it, and it may only be disclosed to other financial institution personnel on a need-to-know basis. Unauthorized disclosure of confidential information may result in legal consequences consisting of lawsuits, regulatory penalties, or reputational damage. Examples of confidential information include: the institution's private information or strategies, competitively sensitive information, trade secrets, communications, stakeholder lists, or research data. Unauthorized persons must be prevented from accessing this information.

D. Highly Confidential Information:
Information that has been entrusted to some financial institution personnel, the disclosure of which without authorization would significantly affect the financial institution or its personnel or stakeholders. Information should be available to employees only to the extent that it includes the need for the business of the financial institution they are assigned to, and financial institution personnel must comply with the information security policy, especially those related to dealing with different types of information. Accessing highly confidential information is strictly prohibited except for authorized employees.

Confidentiality Classification

A. Confidentiality of Stakeholder Information:
It is the duty and responsibility of the financial institution to protect the confidentiality of stakeholder information, and financial institution personnel must document important information for stakeholders. This information is important for maintaining the financial institution's ability to provide high-quality products and services. This information includes, without limitation, information about personal data, products and services, accounts, balances, transactions, and private information related to merger or acquisition operations and securities, as well as requests related to or plans to increase capital. Preserving stakeholder information is an individual and collective responsibility among financial institution personnel, according to the most stringent information security confidentiality standards. Stakeholder information must be treated with the highest degree of confidentiality, and the responsibility to preserve information confidentiality continues even after the end of the work/service of financial institution personnel. Sharing stakeholder information with anyone who does not have access to it from inside or outside the financial institution is prohibited.

B. Proprietary Information Confidentiality:
During work at the financial institution, financial institution personnel may present, develop, and/or access information, ideas, innovations, systems, mechanisms, technologies, policies, procedures, operations, computer programs, metals, operational processes, and results, profitability expectations, business plans, strategies, programs, employee information, reports, studies, records, data, lists, stakeholder information, trade secrets, and other information related to the financial institution or stakeholders or potential stakeholders or its products or services or any other parties affiliated with the financial institution, which are not available to the public. This information may be original or a copy of the original, electronic, stored, written, or any other type.

As a condition of employment/service, financial institution personnel must acknowledge or agree that proprietary information is the sole property of the financial institution and waive any rights or interests they have in it. It is also the duty of financial institution personnel to maintain proprietary information, and financial institution personnel are not allowed to use this information outside the business of the financial institution. Unauthorized use of proprietary information is prohibited. Financial institution personnel must not record any communications involving proprietary information through using devices or electronic devices or disclosing them to any unauthorized third party during their education and service period and after its completion. Financial institution personnel must take care that proprietary information is published or destroyed. In case of resignation from work, the financial institution personnel must delete/return all proprietary information in their possession, including information they keep in their devices and personal properties such as (electronic devices, home computers).

C. Confidentiality of Insider Information:

Financial institution personnel may sometimes be entrusted with insider information that is material. Possession of this type of information is allowed, but misuse is not permitted.

The definition of "Material Insider Information" is broad. Insider information is "material" if there is a high probability that a reasonable person would consider it important for making an investment/business decision, or if the dissemination of this information would affect the price of the company's securities in the market. Insider information may also be considered material if it relates to the future or potential or expected events, or if it is material only when combined with information available to the public. All information is "insider" unless it has been disclosed and sufficient time has passed for it to be absorbed. Examples of sufficient disclosure of information include: information submitted to securities markets and regulatory authorities (such as Tadawul and the Capital Market Authority) or issued in a press release or through meetings with media and public individuals. No financial institution personnel may discuss or pass insider information to any other employee unless the exchange of this information serves the purposes of the financial institution. Financial institution personnel must not trade directly or indirectly or through appointing others or arranging a trading transaction where one of the parties is a person who has a family, work, or contractual relationship with one of the financial institution personnel, or arrange for their agent or any other person acting on their behalf to trade shares or securities of one of the listed companies or give recommendations to do so based on insider information they accessed by virtue of their work/service in the financial institution. Financial institution personnel are not allowed to invest or make business decisions (unrelated to the work of the financial institution) based on information they acquired from the financial institution, as such work is considered a violation and is punishable by law. If any financial institution personnel believes that they have accessed insider information, they must not trade securities based on that information except after consulting the compliance administration. In case of trading or holding securities before joining the financial institution, the competent administration must be notified of this.

D. Exchange of Confidential Information on a Need-to-Know Basis:

Financial institution personnel must not disclose confidential information to other personnel or to supervisory and regulatory authorities or external lawyers and/or consultants, except after obtaining the required approvals and that the disclosure is in accordance with the following cases:

If the recipient has a legitimate need for that information and is authorized to obtain it, and that is related to the responsibilities of their work/service, in accordance with the instructions governing that.

That no harm will result from the disclosure of this information.

Employees of the financial institution must not provide any information about the financial institution to external parties unless they have the authority to do so. There may be exceptions for disclosing certain information if such disclosure is normal in the course of the financial institution's business, such as inquiries about financial solvency and/or if the information is requested by a supervisory or regulatory authority, or if disclosure is in the interest of the financial institution and its stakeholders. The following are examples of some cases subject to exceptions, but this exception will not be applied unless approval is obtained from the officials appointed in the financial institution:

Periodic public announcements mandated by regulatory authorities.
If the competent authorities request information for investigation purposes.

Regulatory and supervisory inquiries must be referred to the Compliance Department, and no employee is permitted to answer any regulatory/administrative inquiry or provide these authorities with any requested information except through the Compliance Department or if authorized to do so.

Duties of Financial Institution Employees:

Employees of the financial institution are obligated to protect confidential information. In addition to the detailed requirements in the Information Security Policy prepared by the financial institution, employees must, at a minimum, adhere to the following:

Adhere to the Information Security Policy and its procedures, and relevant systems and instructions regarding confidentiality.
Do not access stakeholder or ownership information considered "non-public information" for purposes unrelated to their work; if they do access it, it must be within their authority and for work-related reasons.
Do not seek to obtain confidential information not required by their work.
Do not provide confidential information to any unauthorized person, inside or outside the financial institution, or facilitate their access to it.
Provide authorized persons with information within the required limits.
Store stakeholder, ownership, or other confidential information in a manner that allows only authorized employees to access it.
Do not leave any confidential information in accessible places such as offices or common areas.
Use marked envelopes, postal services, or email marked as confidential when exchanging confidential information within the financial institution.
Do not take copies of any document or text unrelated to their work without prior approval from the direct manager.
Do not enter safes, fortified rooms, or other restricted areas unless authorized to do so, or if related to work requirements.
Keep documents currently being worked on only on the desk, while other documents should be kept in drawers, preferably in locked places.
Turn off devices and lock drawers when leaving the office.
Destroy all documents that are no longer needed and contain sensitive or confidential information, while transactions and other documents should be placed in a file inside a locked cabinet.
Do not disclose any confidential information about the financial institution to anyone, including those in their office who do not need that information or employees who have no need for that information.
Take preventive measures to avoid unauthorized disclosure of confidential information.
Do not discuss sensitive matters or confidential information in public places such as elevators, corridors, or public transportation.
Maintain the confidentiality of the financial institution's information during their employment/service period and after its end, and not share such information with any other person, or collect, record, or publish it at any time or for any reason, except after obtaining written approval from the authorized management within the financial institution.
Do not enter the financial institution's buildings outside working hours without prior approval from the direct manager and the Security and Safety Department.
Value and acknowledge that any intellectual property created for the financial institution or arising from the use of the financial institution's resources belongs solely to the financial institution.
Maintain the confidentiality of fortified room numbers, technical system access codes, and all other secret numbers.
Strive to prevent the disclosure of confidential information, whether intentional or unintentional.
Adhere to obtaining prior approval from the authorized person to copy or possess any document or text outside the financial institution building to complete work outside the financial institution's premises.

The competent information security authority must be notified if any employee of the financial institution receives confidential information they do not need at the time. In addition to the duties mentioned above, employees are responsible for the following obligations:

Adhere to legal, regulatory, and other contractual requirements applicable to their field of work.
Maintain the functional identity and secret numbers of the financial institution's technical systems, taking into account periodic changes. Employees of the financial institution are responsible for any action performed under their functional identities, and Information Security Policies must be followed to prevent misuse of functional identity.
Do not tamper with the security protections of the financial institution's technical systems.
Take necessary steps to protect information stored in the financial institution's computers.
Adhere to additional security procedures to prevent the unintentional disclosure of confidential information for employees who possess laptops or who can access the financial institution's systems remotely, or those authorized to use any other portable devices to perform the financial institution's work.

H. Use of Insider Information and Market Manipulation

Employees of the financial institution must not perform any act, participate in, or encourage others in any behavior that may create an impression of any investment, price, or value of something through the use or leakage of insider information to obtain personal benefits for themselves or other parties.

I. Reporting Actual or Potential Violations

The financial institution must provide effective communication channels to receive reports of actual or potential violations. Any employee of the financial institution must report any suspicions they have regarding transactions conducted by other employees who have insider and confidential information, as well as report cases of fraud or attempted fraud, any loss of amounts or commercial papers, or any potential violations of systems, regulations, instructions, or the financial institution's policies. Additionally, report any unusual transactions that the employee believes, from their perspective, do not align with the financial status of stakeholders, through the various reporting lines provided by the financial institution. Reports of violations are handled with complete confidentiality, and the financial institution ensures appropriate protection for employees who report violations in good faith. The financial institution does not tolerate any form of retaliation against whistleblowers.

The financial institution must hold its employees accountable who willfully ignore reporting any acts or transactions that violate systems, regulations, instructions, and related policies.

J. Remuneration and Incentives

The financial institution may prevent its employees from receiving benefits outside the scope of the official employment contract concluded with them to motivate them to achieve the best results. According to the Remuneration and Incentives Policy prepared by the financial institution, the following must be considered:

Ensure sound and effective risk management through an effective management structure to define and share objectives with employees.
Ensure effective risk management of remuneration and incentives by establishing a policy that ensures remuneration and incentives are not concentrated among a limited group of employees.
Conformity with the financial institution's business strategy, core values and priorities, and long-term objectives.

Page Number	Issue Date	Version Number	Principles of Conduct and Work Ethics in Financial Institutions
13-14	August 2019	1.0

Fourth: Consequences of Non-Compliance with Principles of Conduct and Work Ethics

The financial institution must verify the implementation of the Conduct and Work Ethics Policy in the financial institution, monitor and control any violations of it, as well as develop and update it in accordance with these principles, and impose penalties for violations in accordance with relevant systems and instructions, and according to the work regulations and penalties specific to each financial institution.