Compliance

Compliance with laws, internal regulations and market standards.

We ensure compliance of ING Bank Śląski S.A. ("the Bank") by building a corporate culture based on knowledge and obedience of laws, internal regulations, market standards and behaviors set out in the Orange Code.

Conflict of interest management      Zero tolerance approach to corruption

Conflicts of Interest Policy at ING Bank Śląski S.A.

Trust in the honest and efficient functioning of the financial- and capital markets is fundamental to the market integrity, which is why we have implemented the Conflicts of Interest Policy at ING (the Policy). The Policy has been developed with regard to the principles which, in the field of protection of confidential information, inside information and preventing conflicts of interest, result from the provisions of the generally applicable laws, including the laws of the European Parliament.

The Policy sets out the standards of conflict of interest management while providing financial services. The purpose of the Policy is to identify, assess, manage and mitigate or prevent actual- and potential conflicts of interest which may arise between the interests of the Bank and the private interests of the employees, including the members of the Bank’s senior management and Supervisory Board, the Bank clients, shareholders, material suppliers or business partners and between the Bank clients.

A description of the Conflicts of Interest Policy at ING Bank Śląski S.A.

Confidential Information

Non-public information concerning the Bank, its clients, suppliers or external entities, which is subject to a confidentiality clause (whether by contract or otherwise), which includes inter alia: commercial information; financial information; operating activities; (external and internal) business processes and methods; data, including market share data; information on staff, sales, business plans/ intentions, profits, losses or expenses, projections, computer software; other information of commercial value.

Inside information

(Confidential) Information, which according to Article 7 of the MAR Regulation:

  • is of a precise nature,
  • has not been made public,
  • relates, directly or indirectly to one or more issuers or to one or more financial instruments, and
  • if it were made public, would likely to have a significant effect on the price of those instruments or on the price of related derivatives of financial instruments.

Conflicts of interest

The contradiction within any of the Bank's activities relating to the customer, the Bank and/or employee(s).

A conflict of interest is when an employee or the Bank has a conflicting interest that may influence the motivation or decisions of that employee or the Bank, while maintaining the principle of acting in the best interests of the client.

A conflict of interest may occur in any situation where a Bank’s employee uses its role for personal or other benefit.

Zero tolerance towards corruption

We expect all ING employees, at every level of the organization, to act in accordance with our Orange Code values in every situation.

When it comes to corruption, we have a zero-tolerance policy. Any form of corruption (including attempting to do so) in business dealings or in connection with conducting transactions is prohibited. Regardless of whether they take place directly or indirectly and whether the Bank's customers or business partners are involved.

The principles of ING’s Anti-Bribery and Corruption Policy state

  1. All forms of corruption, including facilitation payments, are prohibited.
  2. Gifts, offers of entertainment or other benefits must be reasonable and proportionate, be within the established limits, have a justifiable and legitimate purpose, and must not create a conflict of interest or give the impression that such a conflict has occurred.
  3. Employees of the Bank and third parties acting for/on behalf of the Bank shall not be allowed to offer, give or accept, among other things:
    • cash and cash equivalents (including, but not limited to: gift cards, vouchers, etc.)
    • gifts sent from or to a private address
    • benefits in the form of payment of travel or lodging expenses.
  4. Relationships with public officials and state entities are subject to increased scrutiny and are subject to stricter rules.
  5. Employees and third parties working with the Bank are not allowed to make donations to political parties.
  6. The Bank's settlements with business partners must be fairly reflected in booking systems.
  7. All decisions regarding employment at the Bank shall be made on the basis of merit criteria and preceded by the application of appropriate candidate selection procedures.
  8. Questionable behavior must be questioned, and improper (suspicious) payments or actions - reported to management or through channels for anonymous reporting of violations of laws, regulations and ethical standards.

Facilitation Payments

Otherwise known as “payment in exchange for facilitation or expediting.”

A small payment to ensure or expedite the performance of a routine activity, most often by a public official.

Conflict of interest

The contradiction within any of the Bank's activities relating to the customer, the Bank and/or Employee(s).

A Conflict of Interest is when an Employee or the Bank has a conflicting interest that may influence the motivation or decisions of that Employee or the Bank, while maintaining the principle of acting in the best interests of the Client.

A Conflict of Interest may occur in any situation where a Bank’s Employee uses its role for personal or other benefit.

Bribery

Unacceptable actions involving the direct or indirect offering, obtaining or possibility of obtaining a benefit, or making a promise to offer a benefit in order to:

  • induce the person receiving the benefit to take actions contrary to the law, internal regulations or rules of professional ethics, including the omission or dishonest performance of official duties
  • or influence the content of decisions taken by public officials or induce such persons to take unlawful actions

Corruption

Corruption is dishonest or illegal behaviour, such as:

  • the crime of selling out
  • bribery
  • paid active patronage
  • paid passive patronage
  • abuse of office
  • abuse of trust
  • managerial bribery
  • corruption in connection with a public tender.

Corruption encompasses a wide range of illegal activities and can affect many different areas of social and economic life.

In ING, corruption is also understood as behavior that is not punishable under Polish law, but is contrary to ethical principles and consists of:

  • creating situations of socially harmful reciprocation
  • abuse of position
  • abuse of influence
  • abusing power to obtain undue benefits.

In ING's terms, these behaviors can also involve organizations (companies) and individuals. Obstructing the work of law enforcement or the judiciary in order to cover up corruption is also considered corruption.

Defined terms

Facilitation Payments

Otherwise known as “payment in exchange for facilitation or expediting.”

A small payment to ensure or expedite the performance of a routine activity, most often by a public official.
Conflict of interest

The contradiction within any of the Bank's activities relating to the customer, the Bank and/or Employee(s).

A Conflict of Interest is when an Employee or the Bank has a conflicting interest that may influence the motivation or decisions of that Employee or the Bank, while maintaining the principle of acting in the best interests of the Client.

A Conflict of Interest may occur in any situation where a Bank’s Employee uses its role for personal or other benefit.
Corruption

Corruption is dishonest or illegal behaviour, such as:

  • the crime of selling out
  • bribery
  • paid active patronage
  • paid passive patronage
  • abuse of office
  • abuse of trust
  • managerial bribery
  • corruption in connection with a public tender.

Corruption encompasses a wide range of illegal activities and can affect many different areas of social and economic life.

In ING, corruption is also understood as behavior that is not punishable under Polish law, but is contrary to ethical principles and consists of:

  • creating situations of socially harmful reciprocation
  • abuse of position
  • abuse of influence
  • abusing power to obtain undue benefits.

In ING's terms, these behaviors can also involve organizations (companies) and individuals. Obstructing the work of law enforcement or the judiciary in order to cover up corruption is also considered corruption.