Our corporate governance policies
The ING Values and the ING Behaviours which are set out in the Orange Code and accompanied by our value statement: Integrity above all! are the cornerstone of our corporate culture.
They underlie the ING Bank Śląski Employee Business Ethics Standards that we created. These Standards specify behaviours and ways of conduct that are desirable and the ones that are unacceptable. They are presented in 10 points.
The document also describes the risk culture rules at the Bank as they are an important aspect affecting the decisions made by managers and employees and the risk that we take.
ING Bank Śląski also requires its business partners and external employees (that is all people who perform any activities for the Bank and/or on the Bank’s behalf, regardless of their form) to comply with the standards of ethical conduct and it is implemented by relevant provisions in contracts.
Ten principles of the Bank’s employees business ethics
- You know and understand the Bank rules, laws and regulations that are applicable in your daily work and act according to them.
- You create and maintain a safe working environment.
- You speak up and report suspected or actual criminal conduct, unethical conduct or other misconduct by or within the Bank.
- You apply a zero-tolerance approach to bribery and corruption.
- You protect personal data.
- You protect the Bank from being misused to facilitate financial economic crimes, tax offences, and environmental and social violations.
- You develop and provide products and services that are suited to our customers, in compliance with competition law.
- You treat all information with care.
- You identify conflicts of interest and take action.
- You refrain from any form of market abuse.
The purpose of the Whistleblowing Policy for Infringements of Law, Internal Regulations and Ethical Standards is to protect the Bank’s integrity and reputation, and to mitigate compliance risk which may result from the employees’ failure to react to infringements they observe. The Policy sets out how ING Bank Śląski enables employees to report suspected infringements of law, internal regulations of ING Bank Śląski and ethical standards that have not been otherwise disclosed or that require separate activities due to the confidentiality of the report, including but not limited to the following:
- mis-selling where selling practices and marketing activities are used to mislead clients or where material product information is misrepresented
- failure to comply with the rules of book-keeping and financial reporting
- actual- or potential breaches of anti-money laundering and terrorist financing regulations
- market abuse, including abuse relating to unlawful use or disclosure of confidential information and market manipulation relating to setting market reference rates
- unlawful use of the data of clients or business counterparties by employees
- undesired behaviour, such as discrimination, mobbing, harassment, sexual harassment, bullying, aggression, violence, intimidation, privacy violation
- theft and fraud, bribery or corruption.
Financial- and economic crime takes many forms, such as money laundering, corruption, terrorist financing, insider dealing and sanctions violations. It is one of our priorities to prevent situations where ING Bank Śląski is used in criminal activity because confidence in the Bank translates into confidence in the entire financial system. The KYC Policy sets out the requirements and internal controls to ensure that the Bank complies with the regulations that enable it to know its customers and business counterparties, mitigate the risk of financial-, economic-, fiscal- or environmental risks, and violation of social norms by our customers and business counterparties.
ING Bank Śląski takes great efforts to ensure high level of security for information processed at the Bank so that the clients have a firm belief that the Bank is a solid public trust organisation. The Bank strives to maintain the information risk below the limit defined by the risk appetite and not to allow any security incidents that might have a negative impact on the clients.
While establishing the provisions of its IT security standards, the Bank also takes into consideration regulatory requirements (including but not limited to Recommendation D on the management of information technology and ICT security in banks). The Bank also applies rules compliant with the Standard of Good Practice (SOGP) developed by the Information Security Forum (ISF). It relies on international standards and guidelines: ISO/IEC 27001, COBIT, and PCI DSS.
The security standards cover all areas that must be regulated with special focus on:
- cryptography
- security monitoring
- connections to/from the Bank’s infrastructure
- managing the security of third-party services
- security mechanisms’ testing
- identity and access management.
Corporate governance defines the operating rules of the Bank’s governing bodies and the functioning of its processes and systems. The Bank Management Board has accepted, and the Supervisory Board has approved: the Internal Governance Principles Policy of ING Bank Śląski and the Internal Governance Principles Policy of ING Bank Śląski Group.
1. The Internal Governance Principles Policy of ING Bank Śląski is a set of the most importance internal governance principles followed by the Bank. Those principles concern:
- the Bank’s governance system
- the organisational structure of the Bank
- the internal- and external relationships at the Bank, including the relationships with the shareholders and clients, and their organisation
- the functioning of internal supervision and key internal systems and functions
- the operating rules, the rights, the duties and responsibilities, as well as mutual relations of the Supervisory Board, the Management Board and the key function holders at the Bank
- the principles of the assessment of internal governance effective at the Bank.
The Bank’s internal governance relies on compliance, transparency and effectiveness. The assumptions are implemented by way of the principles set out in the Policy and by making the internal regulations on internal governance rely on a certain hierarchy. In order to ensure effectiveness of elements that comprise the internal governance of the Bank, the Policy indicates the tasks, the duties and the rights of the individual governing bodies and organisational units (that is the Management Board, the Supervisory Board, the General Meeting and other bodies/units) in regard to the implementation, the functioning, the assessment and the supervision of internal governance at the Bank, along with the assignment of responsibility for those tasks.
2. The Internal Governance Principles Policy of ING Bank Śląski Group sets out the most important principles of internal governance at ING Bank Śląski Group. The principles contained in the Policy are reflected in the internal regulations effective at the Bank and in the subsidiaries, and the Policy presents the basic principles of internal governance in one place. The Policy describes the goals of implementing the basic internal governance principles in the group of companies, as well as the general- and detailed principles relating to the role of ING Bank Śląski and its subsidiaries within the ING Bank Śląski Group.
The purposes of the Policy include but are not limited to the following:
- ensuring compliance of ING Bank Śląski S.A. Group operations with commonly applicable laws as well as recommendations, guidelines, requests and standpoints of the supervisory bodies (including in particular Recommendation Z and the Corporate Governance Rules for Supervised Institutions of the Polish Financial Supervision Authority)
- implementing and propagating good practices on internal governance
- ensuring effective implementation, verification, evaluation of and adaptation to the ever-changing economic- and legal situation of the group governance functioning at the ING Bank Śląski Group
- ensuring effective supervision over the implementation and functioning of the group governance at the Bank Group
- indicating the rights and duties of certain bodies and organisational units in regard to the implementation, verification, evaluation, adaptation of and supervision over the implementation and functioning of the group governance at ING Bank Śląski Group
- enhancing the effectiveness and transparency of the ING Bank Śląski Group
- ensuring that ING Bank Śląski Group has a transparent organisational structure that is adequate to the scale and nature of its operations and the risk it assumes.
The Labour By-law of ING Bank Śląski defines the organisation and the order of the process of work and the related rights and duties of the employer and of employees. While setting out the rights and the duties of the employer and of the employees in relation to the order in the work establishment, the Labour By-law should in particular specify:
- the organisation of work, the conditions for staying on the premises during- and after work, and the equipment for employees including tools and materials, work clothes and footwear, as well as personal protective equipment and personal hygiene products
- the working time systems and schedules and the adopted working time settlement periods
- the night time
- the date, place, time and frequency of remuneration payment
- the lists of types of work prohibited for adolescent and female employees
- the types of work and positions open to adolescent employees for the purpose of vocational training
- a list of light work that may be carried out by adolescent employees hired for purposes other than vocational training
- health and safety obligations and fire protection obligations, including the procedure for communicating occupational risks to employees connected with the work performed
- the adopted methods of confirmation of an employee's arrival and presence at work and justification of any absences from work.
The Labour By-law is defined by the employer in agreement with the in-house trade union organisation.
The ING Bank Śląski Group Remuneration Policy sets forth the key assumptions for shaping the principles of remuneration so as to attract and retain employees, by ensuring the remuneration that is competitive versus the market. The Policy also defines remuneration components.
The General Conditions of Remuneration at ING Bank Śląski set out the principles of remuneration and additional benefits related to work for the employees of ING Bank Śląski.
The ING Bank Śląski Employee Evaluation Bylaw (Step Up) sets out the terms and conditions of goal setting, their evaluation as well as the terms and conditions of bonus award to the employees of ING Bank Śląski.
The General Conditions of Assessment of Identified Staff of ING Bank Śląski set out the terms and conditions of goal setting, their evaluation as well as the terms and conditions of variable remuneration award.
The ING Bank Śląski Identified Staff Variable Remuneration Policy sets out the variable remuneration components that may be awarded to the Bank’s Identified Staff as well as the rules for remuneration disbursement.
The Diversity Declaration was adopted at ING Bank Śląski in 2016 as an expression of our openness and responsibility.
We promote diversity – not only because it's the right thing to do, but also because it ensures realization of our strategy and is the key to our success.
Experiences arising from differences related to gender, age, origin, sexual orientation, physical ability and religious beliefs help us to face challenges and solve problems in different ways.
Those differences will never be the basis for any decision regarding employment, promotion or dismissal. Diversity propels our business forward because adopting different perspectives drives innovation, growth, and leads to the right decisions and better performance. Diversity increases the pool of our potential candidates. It helps us attract and retain top talents. It also allows us to better understand different customer groups. We care about creating a friendly working environment. We want everyone to be able to express themselves. The declaration is a document binding on all ING Bank Śląski employees.
As an employer, ING Bank Śląski attaches great significance to shaping attitudes and sensitivity in professional situations. A policy aimed at ensuring a work environment that is free from undesirable phenomena, such as discrimination or workplace harassment, (hereinafter referred to as the Policy) is an expression of concern for a friendly and harmonious work environment.
The purpose of the Policy is to ensure conditions where discrimination, workplace harassment and other forms of improper relations in the employment relationship are effectively counteracted and where all the employees have a sense that they are treated with dignity and respect, with no improper relations in the employment relationship whatsoever being tolerated. Each employee of ING Bank Śląski is required to foster and promote the Policy and to refrain from any negative actions that would encroach upon another person’s dignity or that would disrupt interpersonal relations both at the workplace and in the social media.
Where behaviours that may bear the traits of the undesirable ones are reported, actions will be taken forthwith in order to eliminate and investigate them without any negative consequences being sustained by the reporting persons. The process has to be kept confidential end-to-end. Managers should make all efforts so that any conflicts, of a professional or personal nature, occurring in the work environment, are resolved by way of mediation, in a polite and respectful manner, without any detriment to the Bank’s interest or good. All employees of the Bank are required to satisfy and observe the requirements hereunder. The Policy is applied to all the human resources processes, most notably those relating to the terms and conditions of employment and remuneration, recruitment and selection, appraisal of a staff member’s competence and development, assessment of the job performance and dissolution of the employment contract. Each employee is required to acquaint himself/herself with the Policy. Each newly-employed staff member makes such a statement when starting their work for ING Bank Śląski.
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Our environmental policies
Our social policies
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