The Bank’s philosophy for corporate governance extends beyond prescribed mandates and obligations. The Bank has a Code of Conduct operating as its steward for ensuring observance of high standards of responsible banking business. The Code empowers and guides all employees and other persons to whom it may be applicable in certain instances. It is divided into three parts, namely, Ethical Standards, Disciplinary Action, and Procedure for Administrative Due Process.
Each copy of the Bank’s Code of Conduct distributed to employees is accompanied by two forms, i.e. copy of certification of compliance with the Code and Disclosure of Conflict of Interest, and a copy of problem escalation report form.
The Code provides a policy on the responsibility of employees for reporting actual or possible violation of a law, regulation, the Bank’s Code or any policy. Duty is also imposed upon those who are aware of any condition that creates undue material risk to the Bank to promptly report the same to his or her supervisor. Alternatively, he or she may report the infractions to the next higher in management, Operations Controller, Internal Audit Division and Human Resources Services Group. It also provides a policy for the protection of employees who report infractions or risks.
The Unit Compliance Officers and the Internal Audit Division conduct their fact-finding investigations for violation of the Code for cases falling within their respective jurisdictions. Investigation reports of these bodies, consisting of facts of the case, modifying circumstances, if any, provisions of the Code violated, decisions in previous administrative cases, and any applicable laws and jurisprudence, are submitted to the Discipline Committee.
The Discipline Committee, after determination that the investigation reports of the fact-finding bodies are complete, deliberates on the propriety of the offense established by the fact-finding bodies and the recommended disciplinary actions therefore. Should there be a need for further clarification, the Discipline Committee summons the employee concerned for clarificatory conference. The employee concerned may be accompanied by counsel or any Bank employee or union officer (for rank and file). The Discipline Committee thereafter submits its recommendation on the case to the center head of the employee involved.
Also embodied in the Code is the Bank’s policy that no employee will be retaliated against as a result of having made the report. Questions concerning protection for such an employee should be addressed to the appropriate Compliance Officer or the Human Resources Director.
Guided by its Code, the Bank has consistently conducted its business in accordance with its pledged values to its other stakeholders, thereby creating goodwill in the industry.