Rules of the Code of Conduct for Banking Work

Please kindly remind of full compliance with the attached instructions as of its date, taking into account the organization of awareness sessions for all employees on the rules of the code of conduct for banking work to ensure its application and ensure commitment to it.

And accept our sincere respect,

Hassan Abdullah

Rules of Code of Conduct for Banking Work

Contents
Introduction.
First: General provisions
Second: Basic principles of the code of conduct for banking work.
1- Honesty, integrity, and compliance with applicable laws and regulations.
2- Working with efficiency, accuracy, and proficiency

• Dealing with stakeholders
  4- Maintaining the confidentiality of information 5- Unacceptable practices in the work environment.
  6- Accepting gifts.
• Combating money laundering and terrorist financing.
• Combating fraud crimes.
  9- Dealing with the media and social media
  10- Managing conflicts of interest.
  11- Preserving bank assets
  12- Reporting violations and illegal practices.
  Third: Rules of the code of conduct for banking work for senior officials.

Introduction
These instructions were prepared in accordance with the provisions of the Central Bank and Banking System Law issued by Law No. 194 of 2020, as well as the Corporate Governance and Internal Control Instructions for Banks issued on September 19, 2024, which included the need for banks to develop a code of conduct for banking work, and the instructions include the minimum basic standards that are required to be included in the code of conduct for banking work in order to establish sound ethical, moral, and professional standards, values, and principles that bank employees as well as senior officials must adhere to, and senior officials are defined in the scope of application of these instructions as the heads and members of boards of directors of banks and the executive directors responsible for the sectors executive, supporting sectors, and regulatory sectors in banks. First: General Provisions 1- Banks must develop a code of conduct for banking work and have it approved by the bank’s board of directors, and it must also be ensured that all employees as well as senior officials are informed of it and sign a pledge to abide by what is stated therein, in addition to providing specialized training programs to ensure commitment to applying the rules of this charter. 2- These instructions apply to all employees of banks operating in the Arab Republic of Egypt as well as senior officials on that the necessary disciplinary measures are taken against them in the event of a violation, and the instructions include the minimum of the rules that must be observed regarding the behavior of employees and their dealings inside and outside the bank in a way that may affect the bank’s reputation. 3- With regard to senior officials, banks must notify the Central Bank immediately of their violation of these instructions to assess the extent to which they continue to meet the standards of competence and technical eligibility after committing that violation, and to document the bank's decision taken in this regard. Second: The minimum of the basic principles of the code of conduct for banking work 1- Honesty, integrity, and compliance with applicable laws and regulations The following must be adhered to as a minimum:
Not engaging in fraudulent, unethical, or illegal practices.
1-1
2-1
Not violating any of the laws, regulatory controls, or internal policies and procedures of the bank.
1-3 Maintaining the confidentiality of accounts and data and not disclosing any confidential or internal information that is not publicly disclosed 1-4 to the public. Not providing false or misleading information to clients, the bank, or the Central Bank. 1-5 Disclosing any suspicion of conflict of interest (for example, disclosing contributions in companies related parties). 1-6 Not manipulating or falsifying documents. 7-1 Not misusing bank assets. 2- Working with efficiency, accuracy, and proficiency All tasks must be performed to the fullest and due care must be given to performing duties and responsibilities efficiently and accurately and making the necessary effort while adhering to work schedules, in a way that serves the interests of clients in particular and the sector banking in general, and in accordance with the ethical conduct that reflects on the confidence of clients in the bank.

• Dealing with stakeholders
  3-1 Dealing with colleagues and managers:
  3-1-1 Transactions must be characterized by a team spirit that achieves mutual respect while performing duties and cooperation with the highest professional standards of transparency and integrity, respect for privacy, the opinion of others, and refraining from practices that conflict with ethical behavior. 3-1-2 Cooperation with and respect for managers must be achieved in a way that achieves the public interest, and this includes performing the tasks assigned to them in a timely manner and with the required efficiency, if those tasks do not violate the employment contract or the laws or regulations or public morals, as well as following the development plan set by the manager to develop the skills and experiences professional. 3-1-3 Managers must treat their subordinates impartially and not discriminate between them except on the basis of competence, with the need to refrain from assigning them any tasks that violate the laws, instructions, policies, and procedures of internal work or assigning them personal matters. 3-1-4 Adherence to the correct methods and procedures followed in submitting complaints. 3-2 Dealing with stakeholders Transparency and credibility must be adhered to and the necessary advice and accurate information provided when dealing with owners interests (such as auditors, suppliers, any external party, etc.), with the need to adhere to policies internal to the bank regarding the management of conflicts of interest.
• Dealing with clients
  Emphasizing the need to comply with the instructions issued by the Central Bank regarding the protection of the rights of bank customers, and not engaging in any of the following practices, for example, but not limited to:

1-3-3 Providing inaccurate or insufficient information to any client about any of the products or services banking, or not informing him of essential information that may negatively affect his transactions or financial position, including not disclosing the risks of those products or services, as well as not disclosing details of fees and commissions related to those products. 2-3-3 Providing unsound advice to clients about any of their transactions or executing them without assessing the risks that may the client may be exposed to as a result of those transactions. -- Encouraging customers to obtain unsuitable banking products for them in order to achieve profits for the bank and favor personal interests over the needs and interests of clients. 3-3- Delaying or not responding to customer complaints in a proper manner in accordance with internal procedures in place. 3-4 Dealing with the Central Bank of Egypt Disclosure, transparency, and credibility must be observed when providing information and data to the Central Bank, and commitment not to provide any inaccurate or misleading information or data, or to conceal any information. Maintaining the confidentiality of information The confidentiality of information and data that are accessed must be maintained, not disclosed, and any protection must be provided documents relating to the bank, whether relating to the bank's activities, its employees, or one of its clients, and dealt with them confidentially and, in the event of disclosure of any of that information or data illegally, the necessary action will be taken immediately in this regard. Unacceptable practices in the work environment 5-1 Insider dealings and maintaining the confidentiality of information and data:
It is prohibited to misuse internal information or leak any information not allowed to be circulated in order to achieve any personal interest, whether directly or indirectly, inside or outside the bank. 5-2 Dealing on accounts 5-2-1 It is prohibited for any employee to accept powers of attorney from clients to deal on their accounts. 5-2-2 It is prohibited for any employee to deal on his personal account directly through the bank's systems - even if the nature of his work allows him to do so - whether carrying out transfers or any other transaction, provided that all transactions are carried out through another competent employee. 5-2-3- Not misusing the personal account. 5-3 Discrimination, injustice, and unethical practices:
5-2-1 A suitable work environment characterized by equality and non-discrimination must be provided, whether on the basis of (religion, or age, or gender, or health conditions, or family history, or personal appearance ... etc.) and without fear of exposure to injustice in all its forms, and not allowing any kind of harassment or mistreatment by all different administrative levels, directly or indirectly. 5-2-2 It is prohibited to commit all forms of abuse represented in verbal, moral, physical behavior or intimidation, or engaging in unethical and unacceptable practices. 5-2-3 It is prohibited to photograph or record conversations of employees of any kind without their knowledge or without their consent and prevent its circulation. 6- Accepting gifts 6-1 Each bank must have a policy that defines the recognized criteria for accepting gifts and the maximum limits thereof, so that it does not negatively affect the reputation of the bank and its employees. 6-2 It is prohibited to accept any gifts of value that exceed the maximum limits specified in the policy referred to above, or financial amounts or their equivalent of gold or valuables from external parties (banks - government agencies

• clients - suppliers) for any purpose.
• Combating money laundering and terrorist financing
  1-7
  Compliance with the laws and instructions related to combating money laundering and terrorist financing issued by the Central Bank and the Anti-Money Laundering and Terrorism Financing Unit, and avoiding involvement in any activities or transactions or crimes of money laundering and terrorist financing. 2-7 The necessary measures must be taken to discover any unusual activities or transactions that may involve suspicion of money laundering or terrorist financing, and reporting to the Anti-Money Laundering and Terrorism Financing Unit in accordance with legal requirements, and it is prohibited to disclose any internal reports or procedures taken in this regard, with considering informing the concerned department of the Central Bank in accordance with the procedures and controls in place.
• Combating fraud crimes
  Banks are committed to notifying the Central Administration for Combating Fraud Crimes at the Central Bank of all cases of fraud they have immediately upon their discovery and in accordance with the mechanism determined by the Central Bank in this regard, and ensuring that everything related to those cases is documented and collecting all relevant information and dealing with it in complete confidentiality.

9- Dealing with the media and social media
1-9
Communication with the media (whether printed, visual, electronic, or social networks) must be through the department concerned with this matter at the bank only, and it is prohibited to deal in the name of the bank without authorization to do so. 2-9 It is prohibited to exploit social media in a way that may be offensive to the bank or its employees or the sector banking as a whole, and it is prohibited to circulate or publish any internal documents or information specific to the bank or its employees (such as internal circulars, decisions, or internal policies through any external means. 10- Managing conflicts of interest 10-1 The bank must have a policy for managing conflicts of interest approved by the Board of Directors, including cases that may lead to a suspicion of conflict of interest, in accordance with the instructions on governance and control internal issued by the Central Bank. 10-2 Any suspicion of conflict of interest that may negatively affect the bank must be reported, and the procedures must be taken necessary in this regard. 3-10- It is prohibited to enter into a partnership or working relationship with a client. 10-4 It is prohibited to engage in any business, whether commercial or for the benefit of other parties, including providing advisory services, or holding any additional position in addition to the primary position at the bank unless after obtaining prior approval from the competent authority at the bank, provided that it does not conflict with any of the tasks assigned to the bank in compliance with the laws and regulations issued in this regard. 10-5 No employee exploiting his position to achieve personal purposes or interests. 11- Preserving bank assets The assets of the bank, including all fixed and current assets, documents, as well as intellectual property, must be preserved, and not misused for any unauthorized purpose, in addition to not using or achieving any benefit from any new or innovative products of the bank for personal purposes. 12- Reporting violations and illegal practices Banks should develop a policy approved by the Board of Directors - in accordance with the instructions on governance and control internal issued by the Central Bank - including a clear mechanism for reporting violations and illegal practices, provided that it includes the necessary measures to protect the المبلغ, and it is necessary to encourage reporting of any violations of the laws or regulations in force and accountability in case of deliberate failure to report.

Third: Additional rules specific to senior officials:
Senior officials must comply with the following to ensure the effective management of all bank business and activities that fall within the scope of their responsibilities:
Ensure that an impartial evaluation process is conducted for the performance of employees reporting to them, with follow-up evaluation of their performance and work to develop their skills and abilities so that they can continue in their jobs. If one of the senior officials becomes aware or receives information about a violation of the code of conduct by one of the employees, he must not cover it up and conduct a comprehensive investigation of the employee or the concerned working group as a whole to take the appropriate action. Encourage employees to adhere to both the conflict of interest management policy and the policy of reporting violations and practices illegal, and encourage them to report any cases in this regard, taking into account the fact that no negative action will be taken against any employee as a result of reporting any illegal practices as long as the reporting is done