“APPROVED”
by the Review Board decision
of JSC “CREDITWEST BANK”

Minutes of the Review Board meeting
No. 6 dated March 15th, 2019

CODE OF CONDUCT (ETHICS)
JSC “CREDITWEST BANK”

2019

CONTENTS
1.	general provisions
2.	AIM AND OBJECTIVES OF THE CODE OF ETHICS
3.	CORPORATE VALUES AND COMPLIANCE WITH THEM
Prohibition of Illegal Activities
Financial and Statistics Statements………………………………………………………………….
Malfeasance, Economic Crime (Fraud)
Sanctions Policy and Legalization (Laundering) of Proceeds Received from Crime, Terrorism Financing and Financing of the Proliferation of Mass Destruction Weapons
Non-Competitive Practice…………………………………………………………………………..
4.	POLICY OF THE COMPLIANCE WITH RISK MANAGEMENT CULTURE
5.	REGULATIONS FOR PREVENTION OF CONSUMER RIGHTS INFRINGEMENT..............
6.	ACTION PROCEDURE OF THE MANAGEMENT AND OTHER EMPLOYEES OF THE BANK FOR PREVENTION OF A DAMAGE TO THE BANK’S PROPERTY…………………….
7.	PROHIBITION of THE official position use by the bank management and other employees of the BANK FOR OBTAINING unfair personal preferences OR GRANTING of SUCH preference to third PERSONs……………..
8.	REGULATIONS FOR PREVENTION OF CORRUPTION PRACTICES AND BRIBERY..
9.	GUARANTEES OF EQUAL RELATIONS BETWEEN THE BANK AND ITS CLIENTS, EMPLOYEES, SUPPLIERS AND COMPETITORS………………………………………………...
10.	RESTRICTIONS ON DONATIONS AND ACCEPTANCE OF GIFTS…………………....
11.	REQUIREMENTS FOR ACCEPTABLE PERSONAL CONDUCT OF THE BANK’S EMPLOYEES……………………………………………………………………………………...
12.	PRINCIPLES OF PROCESSING, STORAGE AND DISTRIBUTION OF CONFIDENTIAL AND INSIDER INFORMATION…………………………………………………………………
13.	NOTIFICATION OF ABUSIVE PRACTICE AND NEGLIGIBLE CONDUCT…………
14.	FINAL PROVISIONS

1.	GENERAL PROVISIONS

The Code of Conduct (Ethics) of JSC “CREDITWEST BANK” (hereinafter, referred to as the “Code of Ethics”) is developed to comply with international standards, the Basel Recommendations and is one of the elements of risk management and its minimization, designed to ensure introduction in JSC “CREDITWEST BANK” (hereinafter, the “Bank”) adoption policies and procedures for organizing a risk management system in accordance with and complying with the requirements of the “Regulations on the Organization of a Risk Management System in Banks and Banking Groups of Ukraine” that are approved by the National Bank of Ukraine Board Resolution No. 64 dated June 11th, 2018 with amendments and additions (hereinafter, the “Resolution No. 64”).

The Code of Ethics regulates the procedure of the Bank's management and other employees compliance with of the Bank's corporate values.

The main principles of development and implementation of the Code of Ethics are:
-	definition of corporate values of the Bank;
-	risk management of the Bank's activities;
-	ensuring the implementation by the Bank's employees (within the limits of their functional responsibilities defined in job descriptions, contracts, Internal Documents of the Bank, etc.) of official duties and avoiding interests conflict;
-	prevention in JSC “CREDITWEST BANK” operation of the legislation and regulatory acts of the National Bank of Ukraine violations.

The Bank's management and all Bank’s employees are required to be familiar with the content of the Code of Ethics and to comply with its requirements, in case of non-compliance, they are liable in accordance with the current legislation of Ukraine. The heads of structural units of the Bank are responsible for complying with the norms of this Code of Ethics by subordinate employees.

An important part of the Bank's risk management activities is awareness and regular training (at least once a year for existing employees and during the recruitment of new employees) of the Bank's employees on risk management culture and compliance with the Code of Ethics requirements.

The procedure of familiarization with the Code of Ethics and its training stipulates that all employees of the Bank are obliged to familiarize by putting their signatures and/or through reviewing by electronic mail of the Bank in case of:
1) approval, making amendments to the Code of Ethics on the day of approval / making the relevant amendments, but not later than 3 working days from the date of approval, making changes. The Compliance Management ensures training and awareness of the Bank's employees as to the compliance with the Code of Ethics.
2) the recruitment to the Bank – before the performance of official duties by employees, Human Resources Service provides familiarization with the Code of Ethics by signing of the Application-Agreement, which confirms the adoption of provisions of the Code of Ethics (Annex 1 to the Code of Ethics), which is stored in employee's personal case.

Definition of terms that are used in the Code of Ethics:

Management of the Bank are the persons specified in the first part of article 42 of the Law of Ukraine “On Banks and Banking Activities” with amendments and additions;

Corporate ethics is a culture of behavior of the Bank's employees, their convictions, traditions, the level of relationships between management and subordinates, between the Bank and clients (customers), partners, the state and society.
Duty of solicitous attitude is the duty of management and employees of the Bank to make decisions and act in the Bank’s interest on the basis of a comprehensive assessment of the available (provided) information. The duty of solicitous attitude means that the management and employees of the Bank:
1) act with awareness of their decisions and a sense of moral responsibility for their behavior;
2) are responsible for the performance of their official duties;
3) make decisions within the limits of their competence and on the basis of a comprehensive assessment of the available (provided) information;
4) adhere requirements of the legislation of Ukraine, Provisions of the Bank’s Charter and Internal Documents of the Bank;
5) ensure the preservation and transfer of property and documents of the Bank during the dismissal of employees from their positions.

Duty of loyalty is the duty of the Bank's management and employees to act in good faith in the Bank’s interests (and not in their own interests, in the interests of another person or group of persons that harms the interests of the Bank). The duty of loyalty means that the management and employees of the Bank:
1) disclose all existing and potential conflicts of interest as to themselves in the order established by Internal Documents;
2) do not use their official position in their own interests, damaging the interests of the Bank;
3) give preference to interests of the Bank, its depositors and creditors, and not the interests of the participants whom they represent, in resolving issues that do not match the interests of the Bank and the participants (applies to the members of the Bank’s Review Board – representatives of the participants);
4) refuse to participate in the decision-making, if the conflict of interests does not allow them fully perform their duties in the interests of the Bank, its depositors and participants.

Compliance is the Compliance Directorate that is subordinated to the Bank's Review Board and performs compliance functions (Compliance) in accordance with the Regulations on Compliance Directorate and Internal Documents of the Bank.

CCO – Chief Compliance Officer.
CRO – Chief Risk Officer.

Other terms, definitions and notions used in the Code of Ethics, but their definitions are not contained in the latter, shall be applied in the meanings specified by the current legislation of Ukraine and the normative and legal acts of the National Bank of Ukraine.

2.	AIM AND OBJECTIVES OF THE CODE OF ETHICS

The Code of Ethics is the main document that defines the standards of the Bank's activities and the conduct of employees, as well as liability for violating these norms.
Compliance with the standards of the Code of Ethics is a guarantee of the success of thigh quality services provided by the Bank, the responsibility of employees towards clients, partners and shareholders.
The Code of Ethics determines:
• ethical and professional standards of the Bank and ways of their observance;
• unified values, rules of business conduct and ethics, aimed at improving the efficiency and culture, financial stability of the Bank, strengthening of mutual trust among the participants of the banking services market;
• basic principles of a unified corporate culture, based on high ethical standards, maintaining of a climate of trust, mutual respect and decency in the team;
• ways of identifying and preventing potential risks, solving problems of ethical aspects;
• ways to increase and maintain trust to the Bank by the business community, and to strengthen the reputation of an open and honest market participant.

3.	CORPORATE VALUES AND COMPLIANCE WITH THEM

OPENNESS
•	We are consistent and honest in our thoughts, words and actions;
•	We are open to communication, ready to hear and share a different point of view;
•	We are constantly looking for new opportunities for development and training.

TRUST AND PARTNERSHIP
•	We work to achieve common goals;
•	We aspire to mutually beneficial relations and mutual assistance;
•	We do not recognize uncompromisingness and are not guided by our own interests.

RESPONSIBILITY
•	We always adhere to the granted word;
•	We are responsible for our actions and for the joint result of the Bank team.

EFFECTIVENESS
•	We focus on the outcome, not on the process;
•	We aspire to achieve our goals, not to convince them to be inaccessible.

The observance of corporate values order is that:

1) the Bank’s Review Board:
• develops and promotes high ethical and professional standards, adheres to such standards and ensures their implementation and compliance with the Bank's management, executives of compliance divisions and other employees who contribute to minimization of the risk that the Bank faces in its activities;
• ensures the implementation of the Bank’s corporate culture, oriented on the rules of responsible and ethical behavior;
• determines the Bank's corporate values.

2) Management and employees of the Bank are obliged:
• to know rules and principles of the Code of Ethics and to observe them in the performance of their official duties and in dealing with colleagues, clients, and contractors;
• to perform qualitatively and competently their duties and other tasks assigned by the Bank;
• use their official position exclusively for the performance of their official duties and management orders provided on the basis and within the limits of their authority. In the performance of their official duties, management is obliged to act in favor of the Bank and clients and to set the Bank's interests above its own;
• management and employees of the Bank are committed to adhere to duties of solicitous attitude and loyalty to the Bank in accordance with the legislation of Ukraine;
• all Bank’s employees should avoid conflicts of interest and not create preconditions for their occurrence.

Prohibition of Illegal Activities

The management and employees of the Bank adhere to the requirements of the current legislation of Ukraine (tax, consumer protection, labor, antimonopoly legislation, legislation in the field of prevention and counteraction to the legalization (laundering) of proceeds received from crime, financing of terrorism and financing of the proliferation of mass destruction weapons, other laws, normative legal acts of the National Bank of Ukraine) and internal documents of the Bank.

Employees of the Bank are obliged to abstain from the execution of management decisions, if they violate requirements of the legislation of Ukraine or internal documents of the Bank, including this Code of Ethics and report on such cases to CCO in accordance with the procedure provided by this Code of Ethics.

Financial and Statistical Statements

The Bank takes all necessary measures to provide reliable financial and statistical statements, as well as observance of terms and methods of reporting.

The Bank complies with all requirements established by regulatory authorities, the current legislation on the formation of financial, statistical reports and accounting methods.

The Bank ensures the documentation of all transactions; timely, complete and accurate display in the accounting registers of all operations, formation and storage of primary documents, accounting registers, preventing the registration of false/forged documents of primary accounting and the implementation of false accounting entries, etc.

The Bank provides a storage place and observance of storage terms of electronic and paper documents (archives), taking into account requirements established by the current legislation of Ukraine.

Employees who are suspicious or have information about the unreliability of the data entered in the statistical or financial statements of the Bank must notify CCO, CRO and the Chairman of the Bank’s Management Board by means of bank e-mail.

Malfeasance, Economic Crime (Fraud)

Malfeasance is a crime committed by officials of the Bank using the rights and authority granted to them by law to the detriment of the Bank's interests or failure to perform or improperly fulfill their official duties, including stating by an official of knowingly false information in official documents, other falsification of documents, as well as drawing up and issue of knowingly false documents, taking possession of someone else's property or acquiring the proprietary right by deceit or abuse of trust (fraud), crimes related to inappropriate activities or failure to carry out proper actions for remuneration in the form of money, things, services of a material nature, and gaining property benefits.
The Bank adheres to the principle of zero tolerance to the facts of malfeasance, corruption, bribery, economic crimes, and fraud and fully supports the Bank's employees in counteracting to exposures of malfeasance, economic crimes and fraud.

Sanctions Policy and Legalization (Laundering) of Proceeds Received from Crime, Terrorism Financing and Financing of the Proliferation of Mass Destruction Weapons 

The Bank undertakes to take all necessary measures to prevent the implementation of financial transactions that have the purpose, promote or may help to avoid restrictions imposed by special economic and other restrictive measures (sanctions) established by Ukraine and / or recognized by Ukraine, international organizations and any other jurisdictions where the Bank operates.

Legalization (laundering) of proceeds received from crime include any actions connected with the commission of a financial transaction or a deal with assets obtained as a result of a crime, as well as the commission of actions aimed at concealing or disguising the illegal origin of such assets or their ownership, rights for such assets, sources of their origin, location, movement, change of their form (transformation), as well as the acquisition, possession or use of assets derived from the commission of a crime.

Each employee of the Bank is obliged to carry out the execution (within the limits of functional responsibilities specified in the employment contracts (job descriptions, contracts, etc.)) of the legislation and internal documents of the Bank of financial monitoring issues.

Consulting of clients and / or their representatives, including employees of the Bank by other employees, as to the avoidance of implementation of legislation on counteraction against legalization (laundering) of criminal proceeds, financing of terrorism and financing of weapons of mass destruction proliferation and internal documents of the Bank, is strictly prohibited. The Bank’s employees are not allowed to be involved in the legalization (laundering) of criminal incomes, financing of terrorism and financing of weapons of mass destruction proliferation by the management, Bank employees for the benefit of customers, third parties, personal interests, etc.

The Bank and the Bank's employees ensure a risk-oriented approach in their activities and undertake appropriate and effective measures aimed at minimizing of risks using bank services as to the legalization of criminal incomes / terrorism and other crimes financing.

Non-Competitive Practice

The Bank's relations with its competitors are based on the principles of mutual respect and honesty and compliance with the antimonopoly laws and business principles of competition.

The Bank and its employees do not form, distribute, or use confidential information about competitors and do not distribute knowingly false statements.

4.	POLICY OF THE COMPLIANCE WITH RISK MANAGEMENT CULTURE

The Bank has a risk management system that is correspondent with the Bank’s size, business model, and ensures the identification, measurement, monitoring, control and mitigation of all significant risks of the Bank.

The risk management culture is part of the overall corporate culture of the Bank.

Employees of the Bank depending on their official duties are the main component of the Bank's risk management system at its various lines of security, and they follow risk management strategies and policies.

The Bank provides training (at least once a year for existing co-workers and during the recruitment of new ones) on risk management culture and this Code of Ethics.

5.	REGULATIONS FOR PREVENTION OF CONSUMER RIGHTS INFRINGEMENT

The Bank and its employees ensure compliance with and strict fulfillment of requirements of the Law of Ukraine "On Protection of Consumer Rights" with amendments and additions as to the provision of services and products, including when developing new services.

It is possible to familiarize oneself with current and actual products, conditions and services of the Bank directly at the Bank and/or on the Bank's official website.

6.	ACTION PROCEDURE OF THE MANAGEMENT AND OTHER EMPLOYEES OF THE BANK FOR PREVENTION OF A DAMAGE TO THE BANK’S PROPERTY

All employees of the Bank take appropriate measures to protect the assets, property of the Bank, and ensure their effective and careful use.

All assets and property of the Bank are used by employees exclusively for official purposes within the framework of their functional duties; the acquisition of self-profit or benefit in favor of third parties is strictly prohibited.

All employees of the Bank are obliged to take responsibility for the preservation of the Bank's tangible and intangible assets in order to ensure their integrity and the possibility of proper professional use. The tangible and intangible assets of the Bank include, but are not limited to, the list of buildings and fixed assets (for example, any type of equipment, such as computers, desks, chests of drawers, cabinets, safes, archives and any equipment used by employees in the performance of their service responsibilities, software, communication networks, elements of the company style, client data base, reports, internal documents, etc.).

7.	PROHIBITION of THE official position use by the bank management and other employees of the BANK FOR OBTAINING unfair personal preferences OR GRANTING of SUCH preference to third PERSONs

The Bank's employees are obliged to put the Bank's interests above their own and not to use their official powers and related capabilities in order to obtain unfair personal benefits or in connection with the promise / offer of such benefits to other persons.

The Bank Employees should not have any financial interest in the organizations engaged in entrepreneurial activity, if such interest generates or may lead to a conflict of interests with the Bank. Such organizations include suppliers, competitors, counterparties and clients of the Bank, including their representatives.

It is not allowed to receive rewards, gifts, bribes and other tangible and intangible benefits from customers, suppliers, counteragents, etc., that may affect the objectivity of decision-making, influence honest and impartial performance of official duties by employees and management of the Bank.

8.	REGULATIONS FOR PREVENTION OF CORRUPTION PRACTICES AND BRIBERY

The Bank does not support and prohibits its employees to participate and promote corruption practices in all their forms and manifestations, including extortion and bribery. The Bank adheres to the principle of fair competition.

The Bank and its employees shall not accept, perform, be interested in or offer bribes/monetary benefits, including privileges, entertainment or services, or any material benefit from public authorities, contractors, officials, business partners, clients, third parties, etc., provided with the intent to gain certain benefits or personal benefits.

The Bank complies with the tender, tariff and pricing policy approved by the Bank, which makes rendering of unlawful advantages, impossible. The Bank excludes any offers, act of bribing, extortion and receipt of bribes both directly and through third parties/agents, as well as failure to take measures to prevent bribery and corruption.

9.	GUARANTEES OF EQUAL RELATIONS BETWEEN THE BANK AND ITS CLIENTS, EMPLOYEES, SUPPLIERS AND COMPETITORS

The Bank provides equal employment opportunities, including fair and open-minded approach to hiring, promotion, training, compensation, suspension and disciplinary liability for all persons, regardless of race, color, religion, gender, age, national origin, marital status, nationality, disability or any other status protected by the legislation.

The Bank strictly prohibits all forms of prosecution; the principle of providing by the Bank of equal opportunities expands on all its employees and it depends only on their professionalism and personal capacity.

The Bank respects and adheres to the confidentiality of its employees' data and strives to adhere to standards when storing their personal data.

The Bank collects and stores private and personal information that is permitted by the legislation and regulations of the National Bank of Ukraine and is necessary to ensure the effective operation of the Bank, obtained in order to prevent the occurrence and identification of a conflict of interests. All collected personal data is stored in accordance with the requirements of the legislation for the purpose of security and ensuring of confidentiality.

The Bank takes is concerned about its employees and provides openness, respect, trust and equal opportunities to its team. The basic rules of the Bank employees’ conduct are the respect for each other and teamwork. Relations between the Bank's employees, regardless of their position, should be based on the principles of mutual assistance and benevolence. In solving common issues, the attitude towards all Bank employees must be sustained regardless of personal sympathies or antipathies, and problems arising in the course of work should be openly discussed with colleagues and management, in order to find ways of their solving.

The Bank pays particular attention to the formation of the professionals’ team capable of solving complicated and complex problems. Each employee is a member of the team, each work is considered to be a contribution to the joint business; the Bank's success depends on the professionalism, integrity and quality of each employee's work.

The Bank's relations with clients, business partners, suppliers, competitors and representatives of state authorities are based on the principles of integrity, honesty, professionalism, mutual trust and respect, priority of the Bank’s and clients’ interests, respecting their consumer rights, inviolability of obligations, completeness of the necessary information disclosure in accordance with the procedure provided by the current legislation and the priority of negotiations before the trial.

10.	RESTRICTIONS ON DONATIONS AND ACCEPTANCE OF GIFTS

The Bank maintains partnerships with clients and contractors and allows the exchange of corporate gifts that correspond with business practices. The Bank understands that the exchange of hospitality invitations is a socially recognized component of business relations, but such cases should under no circumstances harm the Bank's business reputation and not induce unlawful actions and/or obtaining unlawful benefits and conflict of interests. In such cases, employees should be guided and adhere to the requirements of the Conflict of Interests Prevention Policy of JSC “CREDITWEST BANK”.

Employees of the Bank are not allowed to receive cash, any gifts, discounts, remunerations of a financial or other nature from customers or third parties for services rendered or that may be rendered, and  for the performance of their official duties. Exceptions make only gifts of a traditional nature and are associated with a solemn event or greetings, and do not require additional obligations the Bank’s employee side.

It is prohibited by the Bank to present gifts to public officers, officials of local governments, notaries, auditors, arbitration managers, officials of state enterprises, controlling bodies, etc.

The Bank employees should not call for the exchange of gifts, offer or accept gifts, participate in entertainment events of clients, partners, etc., with the involvement of such employees in the negotiation of loans, changes in tariffs, tenders, etc., if this may affect the bias of decision making, etc. It is forbidden to conceal gifts for themselves, for husband / wife, partner or close relatives or their value.

In case of doubt that the acceptance of a gift or service may lead to a possible conflict of interests and/or other risks (bribery, inappropriate behavior, corruption, risk activity, etc.), employees should report on such situation to their immediate supervisor and the Compliance Directorate/CCO in advance by means of banking e-mail or others.

11.	REQUIREMENTS FOR ACCEPTABLE PERSONAL CONDUCT OF THE BANK’S EMPLOYEES

The Bank’s management and all employees, while performing their official duties, are required to demonstrate acceptable behavior and prevent unacceptable behavior.

Acceptable conduct means compliance with the requirements of the Code of Ethics, current legislation of Ukraine and internal documents of the Bank, moral values and corporate values of integrity, openness, honesty, and loyalty to the Bank.

Under unacceptable conduct is meant violation of the rules of the Code of Ethics, current legislation of Ukraine and internal documents of the Bank, including, but not limited to: submission of inaccurate reporting, committing official crimes, fraud, violation of financial monitoring rules, non-competitive practices, corruption, violations of consumer rights, promotion of risk activity or inaction, decision-making leading to a conflict of interests, violation of labor discipline, corporate strategy and style, use of profanity, fulfillment of official duties in the state of narcotic and/or alcohol intoxication, personal relations of sexual character between employees of the Bank and others.

The mandatory rule of the Bank’s employees conduct is the respect for each other and teamwork. Relations between the Bank's employees, regardless of their position, should take place on the principles of mutual assistance and benevolence.

12.	PRINCIPLES OF PROCESSING, STORAGE AND DISTRIBUTION OF CONFIDENTIAL AND INSIDER INFORMATION

The Bank's employees use information constituting banking, commercial secrets, confidential and insider information exclusively in the interests of the Bank, in order to performance their official duties with the observance of requirements of the current legislation and internal documents of the Bank. Use by the Bank's employees of insider information is prohibited in order to achieve direct or indirect personal benefit in any form.

Employees of the Bank are obliged to take all necessary measures to prevent the unauthorized distribution or disclosure of information with restricted access.

Disclosure of confidential information and information constituting banking secrecy is carried out in accordance with clearly defined rules, which are become familiar to all Bank employees at the time of employment and during the subsequent periodic distance education using the Bank's information systems.

Employees who collect or process any personal data, responsible for the storage of personal data, and those who have been granted access to such information should use it only for purposes and within the limits specified for the storage and processing of personal data for each data file with the observance of requirements of the current legislation and internal documents of the Bank.

Employees of the Bank follow the provisions of internal documents on information security of the Bank.

The bank requires that employees do not leave open or accessible the restricted information; information and documents constituting bank secrecy; means of information protection and authorization in information systems of the Bank, etc.

Employees of the Bank are responsible for the use of the Bank's communication resources, including corporate e-mail and Internet, which are the property of the Bank and can be used exclusively for the performance of their official duties, without exposing the Bank to reputational risks and possible legal suits.	

It is strictly forbidden to carry out unauthorized connection of third-party devices (storage, processing or data transfer) to the elements of the Bank's computer network, peripheral equipment and electronic computers.

Bank employees are not allowed to independently change their security settings of personal work computers and peripheral equipment. In order to prevent such attempts, for all employees of the bank, there is no possibility of receiving access administrative rights, only responsible administrators of information systems and networks have them.

Employees are strongly encouraged to refrain from categorical statements about the Bank, its activities and management in crowded places or in places where there are representatives of the press or other media (including non-working hours), use of the Bank's symbols in the state of alcohol intoxication, use of abusive vocabulary or in other cases that may adversely affect the reputation of the Bank and its shareholders, customers and employees.

Only authorized employees have the right to grant interviews, post publications in the media about the Bank and/or its activities, comment on any events or activities that are initiated or related to the Bank. Employees are not allowed to submit any comments concerning the Bank on their own behalf. Disclosed information, in accordance with the requirements of the current legislation, must be complete, accurate and published in compliance with legally established rules and terms.

The obligation to observe the information security regime is retained by the employee even after the termination of labor relations with the Bank in accordance with the obligations assumed by him in the course of employment.
	
13.	NOTIFICATION OF ABUSIVE PRACTICE AND NEGLIGIBLE CONDUCT

Employees of the Bank should immediately report any unlawful, inappropriate, unethical or indecent conduct, illegitimate accounting or auditing practices, misuse or manifestation of corruption and any other violation of the Code of Ethics, Ukrainian legislation, internal documents of the Bank, regardless of whether such violation has already occurred or may occur, as well as express anxiety, complaint, or ask questions related to these.

Such notice may be made both to the direct supervisor and to the Compliance Directorate/CCO verbally and/or in written, or by means of anonymous access to the Bank's website via the link https://www.creditwest.ua/uk/contact-us/compliance/. At that, in the case of a subordinate application of the subordinate to the head, the supervisor must inform of such facts the Compliance Directorate/CCO by means of e-banking or in another convenient way. Appeals are accepted and processed with confidentiality, in accordance with the procedure of confidential notification and informing about unacceptable conduct in the Bank (company)/breach of the Bank’s (company) activities/whistleblowing policy and/or non-compliance with the requirements of the current legislation, etc. (hereinafter the "Confidential Reporting Procedure"). The Confidential Reporting Procedure is defined in the Conflict of Interests Prevention Policy of JSC “CREDITWEST BANK”.

14.	FINAL PROVISIONS

Changes and amendments to the Code of Ethics are introduced in case of changes in the current legislation of Ukraine, on the results of inspections of the National Bank of Ukraine and/or internal audit of the Bank, at the request of the Bank's Review and/or the Bank's establishment of events that may affect risk management, including those made in order to improve.

The Code of Ethics shall be approved in accordance with the procedure established by the regulatory acts of the National Bank of Ukraine upon the submission of the CCO in a new wording.

In case of discrepancy of any part of the Code of Ethics with the current legislation of Ukraine, including the regulatory acts of the National Bank of Ukraine, in particular in connection with the adoption of new normative acts, the Code of Ethics will act only in the part that does not contradict the current legislation of Ukraine .

Annex 1
To the Code of Conduct (Ethics)
of JSC “CREDITWEST BANK”,
Minutes of the Review Board meeting
                                                              No. 6 dated March 15th, 2019

TO: Head of the Staff Department

__________________________________________
(Last name, first name, middle name,
__________________________________________
position, subdivision)
__________________________________________

Statement-consent on the Acceptance of the Code of Conduct (Ethics)
of JSC “CREDITWEST BANK” (hereinafter, the Code of Ethics)

By my signature, I, hereby, confirm that I have been familiarized with the Code of Ethics, all conditions and requirements of the Code of Ethics are completely understandable to me.

I am familiarized with the responsibility, determined by the current legislation of Ukraine for breach of the requirements of this Code of Ethics.

In performing my official duties, I undertake to comply with the requirements of the Ukrainian legislation and internal documents of the Bank, taking into account the requirements of the Code of Ethics in accordance with my official duties and the Regulations on the Subdivision.

I accept and undertake to comply with all terms of the Code of Ethics.

«___»_____________20__				_________________________
Signature, Last name and initials