Anti-Corruption Policy Statement
1. Introduction
The Garanti BBVA and all Entities (hereinafter, Garanti BBVA) has a firm commitment to legality and ethical principles, especially evidenced in terms of anti-corruption. Garanti BBVA not only rejects categorically any corrupt practice but also expects from its employees and third parties, and assumes as its own, the commitment to participate actively in the eradication and pvention of corruption, both in public and in private sector. To that end, Garanti BBVA has in place several internal policies, procedures and controls that complement, develop and specify the principles and guidelines set out in section 4.3 of the Code of Conduct under the heading "Anti-corruption policy".
Garanti BBVA's Anti-Corruption policy conduct conforms at all times to the most rigorous national and international standards in the matter including the US Foreign Corrupt Practices Act (FCPA) and the UK Bribery Act (UKBA), taking into account the guidelines of international organizations for the pvention of corruption as well as those outlined by the International Organization for Standardization (ISO).
2. Scope of application
These principles and behavior patterns are applicable to all entities that are part of Garanti BBVA and will be mandatory for all its directors, managers and employees in all the activities they perform on behalf of Garanti BBVA. In addition, its scope of application may be extended to individuals or entities outside Garanti BBVA in circumstances where there is a commercial or professional link between them and Garanti BBVA or its business and when their performance entails a risk or gives rise to liability on the part of Garanti BBVA or might directly or indirectly affect its reputation or good name.
3. Key aspects on the pvention of corruption in Garanti BBVA
Garanti BBVA rejects, pvents and penalizes any corrupt practice and/or unfair behaviour aimed at obtaining unlawful, undue or improper advantages for the entity, its directors, managers or employees.
The following general principles for action must be followed:
(a) It is not permitted to give, promise, offer or accept gifts or personal benefits, directly or indirectly, that may be aimed at:
(i) Improperly obtaining or retaining any type of business, contract, interest or dishonest advantage in favour of Garanti BBVA or by Garanti BBVA; or
(ii) Influencing, with that purpose, those with decision-making power.
(b) It is not permitted to request or accept unjustified payments from third parties or payments that involve commissions or compensations different from those arising from Garanti BBVA's ordinary activity.
(c) It is not permitted to improperly favour other entities or individuals with whom Garanti BBVA maintains, or may maintain, contractual relationships.
(d) It is not permitted to use one's position within Garanti BBVA or one's personal relationship to seek to influence a public body, a public employee or an individual to engage in inappropriate conduct for the benefit of Garanti BBVA.
(e) Good judgment, diligence and caution must be exercised in any dealings with public employees or authorities, especially if such employees or authorities adopt, or have power to adopt, resolutions and decisions that directly or indirectly affect Garanti BBVA.
(f) Conflicts of interest must be avoided; and any actual or potential situation that may be perceived as such must be reported to the corresponding superior.
Likewise, specific principles for action must be followed and complied in relation to those activities and processes that involve a greater risk of corruption, such as, for example: giving or accepting gifts or personal benefits; organizing or attending promotional events; professional and travel expenses; donations and sponsorships; relationships with third parties (i.e. suppliers, agents, intermediaries and business partners); recruitment procedures or facilitation payments.
To promote compliance with the above general and specific principles for action, aside from its continuous monitoring and supervision, Garanti BBVA:
- Accounts, records and documents all transactions, income and expenses in an appropriate and accurate manner, without omitting, hiding or altering data or information in relation to them; so that the accounting and operational records reflect the true image and can be verified by the supervisory departments and by internal and external auditors.
- Promotes reporting of any suspicion or knowledge of corrupt practices, made in good faith and without fear of retaliation, through the whistleblowing channel;
- Has in place a disciplinary system that can lead to termination of the employment or commercial relationships, as appropriate, and in accordance with the applicable laws; and
- Ensures the authority and independence of Compliance, which has been entrusted by the Board of Directors with the duty of promoting and supervising that Garanti BBVA acts with integrity, particularly in field of the pvention of corruption.
All Garanti BBVA members undergo specific training courses in this field, adapted to their professional activities.