Description of the policy on exclusion of conflict of interests and conditions of its occurrence

In order to improve corporate governance and ensure financial reliability and the ability of the banking holding company to long-term existence as a profitable financial organization, JSC Belagroprombank (hereinafter referred to as the bank) has implemented a systematic approach to managing conflicts of interest and developed a Conflict of Interest Management Policy (hereinafter referred to as the Policy).

A conflict of interest is understood to mean a contradiction between the property and other interests of a bank and its shareholders (beneficiary owners and other owners), management bodies and their members, organizations that are part of a banking group, a banking holding company whose parent organization is this bank, divisions, employees, clients (counterparties), which may entail negative consequences for the bank and (or) its clients (counterparties).

The organization and functioning of conflict of interest management in the bank's activities, including a set of measures to identify and eliminate conflicts of interest, as well as the conditions for their occurrence, is one of the main tasks of the bank's corporate governance.

The objectives of conflict of interest management are:

improving corporate governance;
counteracting corruption;
protection of the rights and legitimate interests of shareholders, depositors, other clients and counterparties of the bank;
distribution of powers between the management bodies and officials of the bank.

Conflict of interest management in the bank is carried out by taking the following measures:

ensuring transparency of corporate governance of the bank;
creation of an effective internal control system, a risk management system, an internal audit system and a system of remuneration and compensation;
ensuring that the bank treats its clients and counterparties fairly in the context of consulting them, providing services or concluding transactions with them or on their behalf (excluding preference for the interests of one client (counterparty) over the interests of another client (counterparty), preference for the interests of an employee over the interests of a client (counterparty), including those related to the personal interest of the employee);
establishing the priority of collegial decision-making over individual decision-making, including the introduction of the practice of double control (compliance with the “four eyes” principle);
minimization of the facts of decision-making on individual conditions provided for banking operations and other activities;
ensuring the exclusion of conflicts of interest and the conditions for their occurrence when appointing persons accountable to the bank’s supervisory board;
eliminating the possibility of bank officials, members of its management bodies, and employees receiving material and/or personal benefits in connection with the performance of their official duties, personally or through third parties;
avoidance of inaction, refraining from actions (decision-making) that may lead to a conflict of interest;
compliance with the principle of restrictions on the joint work of relatives in one independent structural division of the central office of the bank, a structural division located outside the location of the bank and not having an independent balance sheet, with the exclusion of direct subordination or control of one of them to the other and ensuring constant control to prevent a conflict of interest and the conditions for its occurrence;
timely response to cases of negative or unreliable information appearing in the media and other sources, and investigations of such cases.

The measures aimed at managing conflicts of interest are not exhaustive. In each specific case, other measures may be used to resolve conflicts of interest.

The bank's audit committee shall, at least once a year, analyze and evaluate the bank's implementation of the Policy based on the reasoned opinion of the members of the audit committee and information provided by the official responsible for internal control in the bank, as part of management reporting on internal control issues, including compliance control.

The Bank's Supervisory Board reviews information on the results of the analysis and assessment of the implementation of the Policy.