Reporting policy
at JSC Belagroprombank and the bank holding company

The reporting policy at JSC Belagroprombank and the banking holding company (hereinafter referred to as the Policy) has been developed in order to improve the quality of corporate governance, to ensure compliance with the legislation, the local legal regulatory acts of JSC Belagroprombank (hereinafter referred to as the Bank), the ethical standards (rules) and to establish a general reporting procedure.

High-quality implementation of the Policy is aimed at arrangement of an appropriate internal control system, timely detection and prevention of cases of involvement of employees and managers of all levels of the Bank and members of the bank holding company in illegal and (or) unethical behaviour. 

 
Illegal and (or) unethical behaviour means violations of legislation and (or) local legal acts of the Bank, corruption, fraud and other unlawful acts, ethical misconduct related to the performance of duties by employees (including management at any level) of the Bank, employees, managers and founders of the members of the banking holding company

In accordance with the Policy, employees and managers of all levels of the Bank, members of the bank holding company, customers or other persons may report (as well as anonymously) about illegal and (or) unethical behaviour via any of the communication channels operating in the Bank.

To ensure unimpeded and prompt reporting, the Bank has organized work via the following notification channels:

• dealing with appeals from individuals and legal entities in electronic or written form, as well as with comments and suggestions included in the books of comments and suggestions;
• management of citizen reception;
• the possibility of reporting (including anonymously) to the Bank’s internal control officer (the person substituting for him/her);
• handling appeals via electronic notification channels of the Bank's Contact Center;
• operating the Bank's employees hotline;
• direct reporting (including anonymously) to the Chairman of the Audit Committee under the Supervisory Board of the Bank (with regard to sending information about the facts of illegal and (or) unethical act related to the activities of the head of the Bank, managers and founders (participants, property owners) of members of the bank holding company).

Information related to the implementation of the Policy shall be communicated to the Bank's Supervisory Board for decision-making purposes.