Expobank CZ www.expobank.cz Expobank JSC BELGRAD www.expobank.rs AS Expobank www.expobank.eu

Compliance controlisintegrated in all business processes of the Bank and is aimed at:

  • prevention of abuses of office and corruption offenses;
  • prevention and settlement of the conflicts of interests arising in the course of the Bank’s activity;
  • counteracting money laundering and financingof terrorism;
  • adherence by the employees to corporate and ethical standards;
  • compliance with international standards and requirements in respect of foreign taxpayers;
  • compliance witheconomic sanctions and the restrictions set by the Russian Federation, international organizations and othercountries;
  • ensuring the rights of clients, includingin investment activities.

Compliance control is structuredas a systemthat involves all employes and management of the Bank.

Complianceis an integral part of corporate culture of Expobank LLC and representsanongoing identification of cases and facts of incompliance with laws and requirements, regulations and legal acts, market standards and internal documents of the Bank.

Conflict of interests management and anti-corruption policy
Financial monitoring
Information for foreign tax residents
Code of corporate ethics

Conflict of interests management and anti-corruption policy

In its activity Expobank LLC observes the requirements of the applicable Russian law and the international standards, adheres to the high standards of honest, fair and transparent business. Leading by their personal example of compliance with the anti-corruption standards of behavior, theBank represented by the Board of Directors, the Management Boardand the CEOensurecompliance with the anti-corruption rules and procedures established by the Policy at all levels of the Bank’s organizational structure.

The Bank adheres to the principle of rejection of corruption in any forms and manifestations (the principle of "zero tolerance"). The employees of the Bank in any circumstances may not, directly or indirectly, personally or viaany third parties, offer, provide, promise, solicitoraccept bribes or a remuneration to simplify anyadministrative, bureaucratic and other procedures / formalities in any form. The Bank’s employees should not allow situations where their personal interest or bias affects objectivity of professional judgments and contradicts the interests of the Bank’s clients.

The Bank expects its clients, counterparties and partners tocomply with the standards of the conflict of interestsmanagement and anti-corruption.


Financial monitoring

To meet the requirements of Federal Law № 115-FZ dated 07 August 2001 ‘On counteracting legalization (laundering) of proceeds from crime and financing of terrorism’Expobank LLC implements measures aimed at counteracting legalization (laundering) of proceeds from crime, financing of terrorism and financing of the weapons of mass destruction proliferation (AML/CFT/WMD).

The Bank has developed, approved and put into effect the Internal Control Rules for AML/CFT/WMD Purposes.

The Bank identifies clients, their representatives, beneficiaries, beneficial owners and conducts clientrisk assessments.

The Bank’s employees are trained in AML/CFT/WMD, with their knowledge subsequently checked.

Certain risk management measures are taken to prevent the Bank's involvement in any suspicious transactions ofthe clients.

The Bank has appointed a specialist responsible for the development and implementation of the Internal Control Rules for AML/CFT/WMD.

The Bank does not establish or maintain any relationships with non-resident banks that have no permanent corporate governance bodies in jurisdictions of their incorporation.

The Bank has no accounts opened withthe banks registered in the countries (territories) that, as may be known from the international sources, do not meet the common standards of AML/CFT/WMD.

Information for foreign tax residents

In accordance with Federal Law No.173-FZ ‘On specifics in conducting financial transactions with foreign nationals and legal entities, on amendments to the Russian administrative offences code and invalidation of certain provisions of Russian legislative acts’ dated 28.06.2014, subject to the Foreign Account Tax Compliance Act (hereinafter - FATCA) and in accordance with Federal Law No.340-FZ ‘On the amendments to Part 1 of the Tax Code of the Russian Federation pursuant to implementation of the international automatic exchange of information and documentation on international groups of companies’dated 27.11.2017, subject to theDecree of the Russian Government No.693 ‘On the implementation of the international automatic exchange of financial information with the competent authorities of foreign States (territories)’dated 16.06.2018, Expobank LLC is entitled to:

  • identifyforeign tax residents;
  • report the financial details of the identified foreign tax residents to Russian and foreign tax authorities.

Due tothe enactment of FATCA from 01.07.2014, Expobank LLC has registered with the electronic system of the Internal Revenue Service as a financial institution that complies with the requirements of FATCA (Participating Financial Institution not covered by an IGA). The Bank was assigned with the following Global Intermediary Identification Number (GIIN): HD7Z7S.99999.SL.643.

On 06.06.2017 Expobank LLC extended the agreement with the Internal Revenue Service with the preservation of the previously assigned financial institution status and GIIN.


Code of corporate ethics

The Code of corporate ethics of Expobank LLC is aimed to establish the Bank’s corporate values and define the relevant rules of business conduct accepted at the Bank. The standard norms of corporate and business ethics and the best Russian and foreign corporate governance practices are the basis for the Code.

Corporate ethics is a set of values, principles, ethical norms of conductsupported by the Bank that are accepted and shared by all employees, set the general tone for their activity and define coherence of actions of the management, structural units and employees, including those applicable in respect of the Bank’s clients and counterparties.