Message from Management
OTP Group has become a dominant player on the financial and capital market not only in Hungary but also in the Central and Eastern Europe region, where OTP BANK Plc. as The Mother Bank is listed on the Budapest Stock Exchange.
The stability, the balanced structure of the operation and the wide range of services and products of OTP Group have led to its remarkable results, while the increasingly competitive environment and the diversity characteristic of a multinational group in terms of financial operations, levels of development and cultural aspects, are the source of the various challenges that the management teams and all the employees of otp group face equally.
OTP Financial Group is a universal financial services provider in Hungary, Romania, Montenegro, Croatia, Bulgaria, Russia, Ukraine, Slovakia and Serbia, for more than 13 million clients, through a territorial network of over 1500 units, ATMs and electronic channels.
OTP Leasing Romania IFN SA, subsidiary of OTP Bank Plc. and member of OTP Financial Group, the largest independent financial group in Central and Eastern Europe, is an integrated and self-financed financial services provider. With a defined approach of responsibility, commitment and professionalism, OTP Leasing Romania IFN SA is aware of the needs of its clients.
OTP Leasing Romania IFN SA, as a member of OTP financial group, follows the development in accordance with the strategic directions and guidelines established by the Group to which it belongs.
The most important factor behind the company’s success and achievements so far – the symbol of our future at the same time – is the good business relationships we have developed with our customers, which are based on sharing common values, the rules of conduct governing interhuman relations.
The success of OTP Leasing Romania IFN would not have been achieved without the dynamic work of our highly trained and creative employees, whose actions and behaviors are in line with our high ethical standards.
One of the essential requirements of OTP Leasing Romania IFN SA towards its employees is that they give a major importance to the moral and professional integrity and to strive to achieve high moral and professional standards during the daily activities.
The quality of the financial products and services offered is the result of the fulfillment of the stated mission of OTP Leasing Romania IFN SA, to have the courage to cultivate excellence, professionalism, to have an integrated ethical conduct both at the level of each employee and at the level of the organization.
The value of the shares is one of the most important factors in the operations of OTP Leasing Romania IFN SA, together with efforts to achieve the highest possible levels of profitability and efficiency, risk management and full compliance with internal and external regulations, i.e. effective implementation and performance of the work in accordance with the policies, working procedures, internal control system and code of ethics values.
As an institution based on ethics and compliance, OTP Leasing Romania IFN SA and its management are fully committed to ensuring compliance with specific non-bank financial legislation, avoiding and fighting conflicts of interest, preserving the confidentiality of customer data, including anti-corruption regulations.
OTP Leasing Romania IFN SA and its management adopted the principle of "zero tolerance" toward corruption, bribery and fraud, adopting a firm attitude against them.
At the same time, OTP Leasing Romania IFN SHOULD ensure that the principles of transparency and prudence are fully applied and respected in the course of its activities.
In this respect, we believe that ethical operating practices contribute significantly to the continuous improvement of performance, competitiveness of OTP Leasing Romania IFN SA and its recognition. We therefore apply all available means to maintain and raise our ethical standards in view of maintaining the company's reputation.
The effort of each employee of the company is based on taking responsibility, knowledge, taking ownership and respecting ethical values to ensure progress and stability of OTP Leasing Romania IFN SA.
#1. INTRODUCTION
OTP Leasing Romania IFN SA (hereinafter: The Company) adopted its Code of Ethics (hereinafter "the Code") with the aim of formulating clear and unambiguous guidelines and requirements for both the Company and its affiliates regarding ethical business relationships in order to protect the Company's values.
The Code has a broad spectrum and prohibits all forms of illegal activity.
The company has formed within the applicable regulatory framework, its corporate governance system with the aim of ensuring customer confidence and satisfaction, increasing the value of shares and social responsibility.
The Company gives everyone the opportunity to report breaches of the Code, whether personally, by telephone or email, and at the same time makes every effort to protect employees reporting breaches within the Company against discrimination and unequal treatment, Prohibiting retaliation measures or negative consequences against those who report in good faith actual or suspected breaches of the values and principles of the Code of Ethics.
The Company attaches great importance to ensuring employees become familiar with and aware of ethics rules by conducting training programs for each individual employee, conducting regular reviews and monitoring compliance.
#2. THE SCOPE OF THE CODE OF ETHICS
The guidelines and requirements set out in this Code specify the obligations of the members of the Management Board of OTP Leasing Romania IFN SA and of the members of the Board of Directors of OTP Leasing Romania IFN SA (hereinafter jointly referred to as the "management body"), of its employees (hereinafter jointly referred to as "employees") and of its agents.
For the meaning of the Code, "agents" include representatives, experts, intermediaries, consultants, agents, subcontractors, together with enterprises and individuals in a contractual relationship with the Company under civil law, as well as personnel in practice at the company's offices. The provisions of this Code shall be followed and respected by all the above mentioned persons and entities throughout their employment or contractual relations, whatever their nature, both during and outside working hours.
The management body, employees and agents who fulfill the contractual obligations for the Company and who, in the course of their activity, meet a wide range of clients or potential clients of the Company, provide services for them on behalf of the Company and appear before the public in the course of carrying out their contractual activities certainly as representatives of the Company, accept the Code by signing the declarations of adherence to the principles set forth in it.
The company claims from all its employees that, during the course of the business, and in some cases even outside the workplace, it has a behavior that meets the company's ethical standards.
With the help of the ethics reporting system (whistlerblower) it is achieved the identification of forms of unethical conduct, abuses against ethics, behavior contrary to that provided by legislation or internal regulations. The company identifies and evaluates the causes that allow these practices, paying special attention to the potential risks that may arise. In order to ensure an ethical functioning in business, it is necessary to carry out a global analysis of the information contained in the reports received through the ethics reporting system (whistleblower), the thorough assessment of the related risks and based on them the transmission of observations to the competent departments.
#3. VALUES
3.1. Protection of the Company's assets
The persons mentioned in section 2 of this Code are responsible for the protection of all tangible, financial and other assets of the Company, of its clients and agents, with whose management they have been entrusted. Information regarding the Company's assets, clients, agents and other third parties may be accessed and used only for authorized purposes and in accordance with applicable authorizations and conditions.
Improper management or unauthorized sharing with third parties of assets owned or used by the Company is a breach of obligations to the Company, resulting in damage to the Company's economic interests. Equally, negligence in connection with the wastage or unauthorized use of the Company's assets may also constitute a breach of its obligations to the Company.
For the purposes of this document, assets include cash, securities, physical goods (assets, stocks, equipment, etc.), services, business plans, information of and relating to customers, employees and agents, intellectual property and any other personal information, protected by copyright and confidential.
3.2. Protection of the Company's image and reputation
3.2.1. Conduct requirements
Employees should – both on-site and off-site – refrain from expressions that can have a negative impact on the company's reputation. The company expects its employees to behave, even outside the workplace, in accordance with and in a manner consistent with the company's ethics, Especially when their activities or themselves can be associated in any way with the Company, or when they appear to act or express opinions on behalf of the Company.
Employees may participate and express their opinions in any organization (political, religious or cultural) only as individuals and should refrain from referring to their association with the Company.
Employees will not exercise their right of expression in any way that may damage the company's image and reputation or legal business or organizational interests.
3.2.2. Social media
Employees should refrain, during their activities in social communication, from any expression that may have a negative impact on the Company's reputation. The Company expects its employees to behave — during their communications through social media as individual persons — in accordance with and in a manner that meets the Company's ethical requirements, Especially when their activities or themselves may be associated in any way with the Company, or when they appear to act or express opinions on behalf of the Company.
3.2.3. Political involvement
The Company recognizes the right of employees to take on roles in politics and public life, but such activities can only be performed outside the workplace. During their off-the-job political activities, employees should not abuse their positions within the Company and should refrain from behaviors that may have a negative impact on the Company's reputation.
Employees must inform the Company in writing before taking any position in any political or state organization. In the course of their business with the Company, employees must not abuse their functions or positions in the political or state organization.
Employees may provide support only to political organizations or persons who respect the prohibition mentioned in the chapter "Providing support" and will not use the Company's resources (human resources, facilities, other assets) in support of political events.
3.3 competence and honorability
3.3.1. Anti-corruption
For the purposes of this Code of Ethics, corrupt means obtaining personal advantages without right or illegally in return for money, property or other advantages. No employee or any other person acting on behalf of the Company shall ever offer, promise or pay or offer any other item of value or request or accept such object for the purpose of influencing public officials or other persons (or giving rise to the impression of such influence), or of obtaining an unfair advantage in business.
Value items include financial or other advantages such as — in addition to cash — gifts, credit/loan, guarantee, any offer in the course of granting a loan, discount, entertainment, services, benefits, providing a job, etc. They do not have a minimum amount or limit amount that should be exceeded in order for the respective payment made for the purposes listed above or the respective gift to be qualified illegal or in conflict with the Code, even if suspicion or appearance of suspicion can be avoided.
Gifts
Giving gifts is often part of the local culture and traditions. Giving gifts in business relationships and with customers can contribute to the reputation of the company and to the conclusion of good business relationships. Normal business gifts can be offered and accepted. The pecuniary value of these gifts must not exceed 250 lei. No gift of any kind – whatever value – should be accepted in the public place or in any other place or circumstances, including outside the company.
"No gifts will be accepted in the form of money regardless of the amount offered."
All forms of exchange of gifts at the company's expense, whether within an institution or between employees of different branches of the Group, are prohibited.Gifts may be offered by employees as natural persons at their own expense (e.g. on the occasion of the birth day of one of them).
The exception to this prohibition shall be gifts given in accordance with protocol rules, non-monetary gifts and benefits which are clearly not granted for the purpose of influencing the business relationship existing or to be created with the Company, or gifts based on business relationships, usually at senior management level.
An employee must not offer or accept gifts in circumstances that can be interpreted from the outside as being able to influence a business decision or as a case of bribery.
The company paid special attention in relation to gifts and invitations related to official bodies, international organizations and / or civil society.
An invitation can take a variety of forms, including organized events, hospitality, concerts or excursions. Launching or accepting an invitation can be a legitimate part of business operations, contribute to the company's reputation and good business relationships. Launching or accepting regular business invitations is allowed. These may include invitations to lunch or dinner, attending receptions or other types of entertainment such as hospitality or reimbursement of travel expenses. These costs must, however, always be kept within reasonable limits, where the term "reasonable limit" depends on the facts.
Business decisions should always be made in accordance with the interests of the Company and not based on the personal relationship the development of which has been facilitated by the granting of a gift or invitation. The primary objective is to protect and maintain the reputation and impeccable integrity of the company.
Payments targeting business relationships
Such payments relate to informal benefits aimed at facilitating and speeding up an action or procedure to which the person making the payment is otherwise entitled. The company rejects this practice and will not make such payment when requested.
Providing support
Employees of the Company may not provide, in connection with activities related to their employment relationships or positions held, financial or non-monetary support to any political party, organization or Member or representative of any of them. The company also agrees to be bound by this principle.
Donation
As part of its social responsibility, the Company provides donations to certain needy organizations and groups. Donations may be granted only in accordance with the applicable statutory and internal regulatory documents. Neither the Company nor any of its employees can directly or indirectly request or accept any amounts of money in exchange for a donation.
3.3.2. Conflicts of interest
The employees must avoid, according to the provisions of the statutory regulations and the applicable company normative documents, any real conflicts of interest and even the impression of their existence regarding their positions, activity and their own person.
They must refrain from any and all activities that are contrary to the interests of the Company and/or its clients and must make their decisions in an impartial and equidistant manner.
Employees must report any real or potential conflicts of interest in relation to themselves, relatives / affinities or to their own business interests or those of their relatives / affinities and to the interests of the Company or its clients.
With respect to positions held, work done and Company interests, employees should not demonstrate any attitude, hold any positions, conduct any activities that could lead to conflicts of interest and/or affect Company interests.
In order to provide services, the Company shall develop and maintain a conflict of interest policy in order to ensure that any conflicts of interest to the detriment of its customers are avoided, identified and managed.
The conflict of interest policy shall specify the circumstances that lead to or may lead to such conflicts of interest, which may have harmful consequences for the customer, and shall contain detailed measures and procedural rules to be applied in the management of existing conflicts of interest.
3.4. Mutual respect
3.4.1. Discrimination
The company aims to create a working environment in which individual differences are accepted and appreciated. Positive or negative discrimination of any kind based on actual or presumed attributes (2) of a specific person - including, but not limited to, color, sex, nationality, age, race, sexual or ideological belief, sexual identity, ethnicity, language, religion, disability, genetic features, sexual orientation, political or other options, family situation or responsibility, social category, membership or trade union activity, and so on - is prohibited.
3.4.2 Harassment
The Company prohibits and does not tolerate any conduct based on intimidating employees, especially if by using it employees are required to perform actions that are not in compliance with Company regulatory documents or applicable legal regulations.
Any verbal, non-verbal or physical form of behavior that targets or leads to the injury of the dignity of the person concerned or that creates a humiliating and offensive environment, is forbidden.
3.5 Company commitments
3.5.1 Financial reporting
The Company shall prepare, present and publish its financial reports in accordance with generally accepted accounting principles and applicable legal regulations. The reports shall contain the financial position of the company and the results of its operations in all relevant aspects, thereby also ensuring that accurate information is provided to its investors.
3.5.2. Competition law
The Company's management is committed to and is interested in ensuring the functioning of free and fair market conditions that facilitate competition. The company refrains from any behavior that could lead to the restriction of competition in the market or to the abuse of its economic position in the market. Such conduct may include, among other things, entering into unfair economic competition (in a way that violates or endangers the legitimate interests of customers, competitors and / or partners); making or accepting proposals regarding the agreement on prices, the exchange of marketing information that affects the competition or divides the market and customers (cartel agreement); and discussing relevant issues from the perspective of restricting competition (e.g. prices, pricing policies, costs, marketing strategies) in meetings of professional organizations that represent commercial interests.
Employees must behave in their day-to-day activities involving their competitors and business partners, in full knowledge of their responsibilities under the conditions imposed by competition law.
3.5.3. Use of inside information
Certain employees of the Company may obtain, in the course of their daily activities, privileged information, which they must not use in any way. The company sanctions the use of privileged information.
The use of privileged information and the unfair handling of prices or installments are subject to the regulations formulated in the applicable legislative framework, including but not limited to: the Criminal Code, the Law on the Capital Market, the relevant legislation adopted by the European Union, as well as the internal normative documents of the Company.
In accordance with its internal regulatory documents, the Company takes all necessary measures to prevent and prohibit the use of inside information.
3.5.4. Confidentiality
One of the essential requirements for the contractual/business relationship between the Company and its clients is the strict protection of business secrets and confidential information relating to customers. The Company constantly maintains the confidentiality of data, information and documents related to its clients, as well as of the relationship between them and the company. The company's employees, as well as the staff who interact with the company and its clients and / or have access to information / documents about the company's clients, directly or indirectly, must comply with the obligation of confidentiality, even after the termination of the holding of those positions or of their labor or collaboration relationships.
Employees should refrain from formally or informally sharing any information relating to the activities of the Company, When this is not required for business relationships or employee tasks, and in cases involving persons who are not employees or business partners of the Company.
The protection and maintenance of secrets related to the activity, company and securities must take place in accordance with the relevant provisions of the Civil Code, the Criminal Code, the Law on credit institutions, financial institutions, investment companies, suppliers of goods exchange services and the norms regulating the activities they can perform, as well as the regulations on the capital market, along with the company's internal normative documents.
In accordance with the provisions of Law 93/ 08.04.2009 on non-banking financial institutions, with subsequent amendments, the Company's employees must protect and disclose information, data and documents from the sphere of professional secrecy. The obligation of confidentiality subsists even after the termination of the employment or collaboration relations, for an unlimited period of time.
3.5.5. Activities to combat money laundering and terrorist financing
Financial service providers play an intermediate or recipient role in the conduct of fast and secure money market operations for individuals and organizations, Therefore, there is a high risk that individuals will seek to place orders to trade carried out through the company for illegal purposes or involving assets derived from criminal activities. Preventing these acts and knowing the company's customers is extremely important not only for the company, but also in terms of the overall perception of the money and capital market. In this respect, any act that is potentially illegal may have unpredictable consequences for the company and the market in terms of both loss of reputation and potential financial losses.
The management of the company is committed to and interested in ensuring that free and fair market conditions are in place to facilitate competition. The company shall refrain from any conduct which could lead to restrictions of competition on the market or abuse of its economic position in the market. In the course of their work, they must fully comply with the provisions laid down in the applicable legislation including, but not limited to: The law for preventing and punishing money laundering, as well as for putting in place measures to prevent and fight terrorist financing, the Penal Code, the recommendations of the national Bank of Romania, The provisions of the FATF (Financial Action Task force) and the Basel Committee on CompanY supervision, the relevant European Union regulations and the company's internal normative documents.
3.5.6. Safety and health at work
For its employees, the Company creates a healthy and modern working environment, in accordance with the relevant labor regulations and to ensure the protection of body integrity and health. The company provides its employees with training on safety and fire protection.
The use and/or use of alcohol, illegal substances, drugs and/or other hallucinogenic substances in the company's workplaces, and in other places and/or other work-related occasions for the company, and/or in the course of work-related activities is strictly prohibited, like presenting under their influence or carrying out activities classified as abuse (offering, handing over, traffic, etc.).
All employees must comply with occupational safety and health standards in accordance with the relevant safety, working and fire protection regulations.
The company permanently complies with the domestic and international legal regulations regarding the creation and maintenance of a safe and healthy working environment.
#4. REPORTING ETHICAL ISSUES, ADVISING
When they suspect or find out about possible situations of violation of the values formulated in the Code of Ethics or when they need advice or only for asking questions about how to proceed in a certain situation (ethical issues), the company's employees have available the following options for reporting / clarifying them, including a dedicated system of internal alerting (whistleblower), respectively:
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can submit a personal complaint, during the work schedule, or by a letter addressed to the Compliance Department of OTP Leasing Romania IFN SA (Str. Nicolae Caramfil Nr. 71-73, 5th floor, section 1, Bucharest);
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by e-mail to the address: [email protected].
Notifications, requests and investigations are permanently treated with confidentiality by the recipients, in compliance with the applicable legal regulations and internal rules, protecting the person who reported.
In case of a violation of the Code of Ethics, the procedures and sanctions are applied in accordance with the principles defined in the internal normative documents of the Company. The company institutes, in establishing an ethical violation, working procedures (procedural rules).
Ethics issues can be reported anonymously. In this case, it should be borne in mind that there will be no possibility of collecting additional information which may be necessary for the research and resolution of the problem, The Company therefore kindly recommends to the person making the announcement to provide some contact information – while still anonymous – to be able to request the necessary details.
Unfounded or malicious notifications (defamation) are undesirable and may have legal consequences.
#5. THE PROTECTION OF PERSONAL DATA
The processing of personal data will be done in accordance with the Legislation on the protection of personal data (all applicable laws and regulations in Romania, primary regulations such as, but not limited to: Regulation (EU) 2016/679 on the protection of individuals with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46 / EC (General Regulation on data protection - RGPD), Law no. 190/2018 on measures to implement the RGPD, Directive 2002/58 / EC on the processing of personal data and protection of confidentiality in the public communications sector (Directive on confidentiality and electronic communications) or secondary legislation, such as the Working Group Guidelines Art. 29 or other guidelines / decisions issued by the National Authority for Supervision and Protection of Personal Data).
According to the provisions of the GDPR, OTP Leasing Romania IFN SA can provide information on personal data processed and any other information stipulated by applicable laws, whenever an institution authorized under the law requests it.
The company ensures the security standards regarding the processing of personal data according to RGPD, by taking and applying all appropriate technical and operational measures to protect personal data against any accidental or illegal destruction, loss, modification, disclosure or unauthorized access and illegal processing.
Information about the processing and protection of personal data by OTP Leasing Romania IFN SA (purposes, recipients of data, rights of the data subject under the law: Right of access, right of rectification, right to erasure ("right to be forgotten"), right to restriction of processing, The right to data portability, the right to object, the right not to be subject to an individual decision, including profiling, etc.) can be found on the website of OTP Leasing IFN Romania SA, at www.otp-leasing.ro, Privacy section.
