Mission and values
of Sberbank
(hereinafter, the Bank or Sber)
We give people confidence and security, and we make their lives better by helping their dreams and aspirations come true.
Our values
The guiding principles that help us make the right decisions in any situation.
I ama leader
- I take responsibility for myself and for what happens around me.
- I am honest with myself, my coworkers, and my customers.
- I improve myself, Sber, and our environment by doing everything the best I can.
We area team
- We are always ready to help each other, working together to achieve a common goal.
- We help our coworkers grow and develop.
- We are open, we respect our coworkers and trust each other.
All forthe customer
- All our activities revolve around our customers and serve their needs.
- We like to surprise and please our customers with the quality of our services and with our attitude.
- We exceed our customers’ expectations.
Address by Chairman of the Supervisory Board of Sberbank
Dear colleagues!
What is Sber’s Code of Corporate Ethics and Business Conduct? It’s not just a guidance of behavior for each employee of our rapidly growing company; it’s also a wise mentor, a fount of knowledge, and a code of honor. It’s a reference that must be consulted by every ecosystem employee in case of the slightest doubt in the correctness of their choice while making decisions.
Today, Sber is present in people’s lives not only as a financial institution – one of the largest and best in Russia and worldwide, – but also as an invisible assistant in all kinds of things they want, do, or aspire to. We improve the lives of more than a hundred million of our customers by helping them make their dreams – from basic to wildest – a reality.
Our customer relations are based on trust. And that trust is driven by the universal human values that we are guided by; globally accepted practices of ethical business conduct; a careful attitude towards what our customers want, and our unconditional aspiration to transform the notion of high-quality service by making life better.
All rules that serve as a basis for our relationship both with our customers and within our own company are described in this Sber Code of Corporate Ethics and Business Conduct.
The Code is our guiding light that helps us move forward and make the right decisions day after day, even in the most challenging situations.
Sber’s Supervisory Board fully supports every provision of this Code. We share a special responsibility to serve as a role model for adherence to the highest standards of corporate ethics in everything we do and in all decisions we make – standards that are a benchmark not only in the world of business, but in the world of universal human values too.
Best regards,
Аnton Siluanov
Address by CEO, Chairman of the Executive Board of Sberbank
Dear colleagues!
To be a part of the Sber team means taking part in the lives of millions of our customers one way or another, working with tens of thousands of our business partners and vendors, being accountable to this tremendous community, and making a difference in this world for the better.
We can only succeed in this daunting mission of ours if we move all together in one direction as we share our common values and follow common rules.
Sber’s Code of Corporate Ethics and Business Conduct is a document that sets the direction for our values and actions – what we aspire to, what we expect from every member of our team, and what may tarnish our company’s reputation or destroy relations with our customers and business partners and eventually have an impact on our team spirit.
Sber is a world-class company that adheres to the principles of utmost transparency and does not accept unfair practices of doing business. We strictly comply with the laws and do not tolerate any manifestations of corruption or violations of our Charter. We unconditionally respect the rights and freedoms of every person, and we are responsible and friendly to the greatest extent in all our actions that are always based on the principle of respect – for our customers and partners and for each other. As we use and implement state-of-the-art technology, we keep in mind all of the risks for the public that it may carry, and we therefore thoroughly calculate the implications of our every decision, with a focus not on financial gain, but on the benefits for society and for our country. We are concerned about the future of our planet and the world we will leave to the next generations.
The Code is premised on our timeless values. Please study this document carefully, keep in mind the main rules postulated in it, and consult it if you have any doubts in making a decision. If you don’t find an answer to your question about the ethical aspects of any actions, you can always count on Sber’s support by contacting our whistleblowing hotlines.
The Code places an additional responsibility on Sber’s executives: their task is to create and maintain an environment of trust in their respective teams so that every employee could realize their potential, openly express ideas or doubts, and contribute to our common cause.
Best regards,
Herman Gref
Code of Corporate Ethics and Business Conduct
About the Code of Ethics
Sber’s Code of Corporate Ethics and Business Conduct (hereinafter referred to as the Code of Ethics or the Code) serves several important purposes. Above all, it provides a common point of reference for everyone working at the Bank or related to it. It reflects the rules and standards of conduct adopted at Sber that are based, in their turn, on our own values and principles.
This is not just a rulebook, but also a toolkit that will help you understand our culture better. This document will help you select a strategy of conduct, make an informed decision in an ambiguous situation, or recognize in time any attitudes or actions that are not compliant with Sber’s ethical principles. Obviously, the Code cannot take into account every potential situation or scenario, so it also contains information about where to seek advice if you have any doubt about what to do in a particular situation or how to make a decision.
Like a user manual for a sophisticated mechanism, the Code should be always close at hand. Please remember that everything you do and every decision you make on a day-to-day basis will have an impact on the Bank’s reputation: they shape the way we are perceived from the outside – for example, by our customers, business partners or the government – and the way we perceive ourselves as part of our team. Self-review questions and practical Code application examples will help you better understand its individual provisions.
Code of Corporate Ethics and Business Conduct
The Code of Ethics is designed to guarantee an open, honest and fair approach in compliance with the Bank’s values for all the parties
1.1
About the Code of Ethics
Who is this Code intended for?
The Code of Ethics is intended for every member of the Sber team – for all of the Bank’s employees regardless of their position, length of employment or area of work – as well as for members of the Supervisory Board.
We expect a conduct that is compliant with the Bank’s ethical standard from our customers, business partners, vendors and counterparties, and we support and encourage fairness and transparency on their part.
As you engage any third parties in working with Sber, make sure that they have an appropriate reputation and share the standards and values set forth in the Code.
Sber operates in various jurisdictions and is subject to different national laws, customs and cultures.
The Code stipulates uniform principles of corporate ethics and business conduct for all Sber Group companies regardless of their business, size, or area of operation.
However, Group companies operating in different territories may adapt the Code in accordance with their local laws and cultures. Whether a Group company adopts this Code or develops its own, it is important that the conduct of every employee be based on Sber’s values, local laws, and rules adopted in the local business culture.
Q & A
Question
I am negotiating with a vendor and I know that cooperation with them will be good for the Bank and will bring us big benefits. However, the vendor’s representative suggests cutting certain bureaucratic corners to get started quicker. What should I do?
Answer
The legality of relations with our business partners, customers and vendors and compliance with the Bank’s policies should always take priority. Explain the rules adopted by the Bank to the vendor, and if you believe that their request goes beyond what is legal, report the problem to your supervisor and, if necessary, to a whistleblowing hotline.
1.2
About the Code of Ethics
The Code of Ethics
is our team’s compass
Employees’ responsibilities and the Bank’s expectations
Compliance with the Code provisions drives growth and brings success, enhances our reputation, and creates a better working environment at the Bank. The Code is more than just a collection of rules – it is a shared compass for our team’s conduct.
Self-check list
Even if you are reading the Code for the first time, ask yourself a few questions before you begin:
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Every member of the Bank’s team undertakes to:
Comply with requirements of the law
If you become aware of any breach of the legislation or if you are asked to commit an illegal act, report this as soon as possible to your immediate supervisor or to an existing whistleblowing hotline (for more details, see the Whistleblowing hotlines section)
Study the provisions of the Code of Ethics, be guided by them in their day-to-day work, and avoid inappropriate or improper conduct on or off the job
Take training courses in corporate ethics and conduct at the Bank
Assist the Bank with internal investigations and reviews of potential violations
Know and comply with internal policies and procedures in their areas of responsibility
Obviously, you are not required to remember the provisions of all of the Bank’s regulatory documents, but you must understand their underlying principles and know which document to consult if necessary
Seek help from their supervisor in case they have any questions about the Code application or any doubt about compliance with its ethical principles
If you contacted your immediate supervisor, but did not get an answer or resolution, see the Whistleblowing hotlines section for other ways to report the problem
1.3
About the Code of Ethics
The leader sets the tone for the team
Management’s responsibilities and the Bank’s expectations
Have I created an environment of trust in my team where any ethical issues, problems or mistakes can be discussed?
Clearly, ethical conduct within a team starts with the leader. But it is not enough just to comply with the Code provisions while leading a team. First of all, it is necessary to create and maintain an environment of trust and transparency where all team members can openly discuss any doubts or issues of ethical nature they might have and tell others about any problems or mistakes. Anyone can make a mistake, but it’s important to spot and correct it swiftly.
Managers at any level must:
01
Demonstrate adherence to the Bank’s ethical principles by personal example, by prioritizing them over commercial or financial results
02
Ensure that employees are made aware of and comply with the Code principles, and help employees understand the meaning and importance of ethical conduct
03
Create an environment of open communication in their team, where every employee would feel comfortable bringing up any issue for discussion
04
Support employees initiating a discussion of ethical issues
05
Avoid giving tasks that violate any laws or contradict the Code provisions, business ethics principles or any other rules of the Bank
06
Take urgent steps to remedy any violations, and report any ethical violations or conflicts to the competent units
07
Take into account employees’ compliance with the Bank’s ethical principles and their contribution to consolidating an environment of trust and transparency in the team for performance reviews
Q & A
Question
What is an environment of open communication in the team?
Answer
An environment of open communication is an atmosphere of trust, where employees can discuss any ethical or professional issues within the team and with the supervisor without fear of retribution. In such an environment, managers value employees’ opinion, respect it and take into account various positions, even those differing from their own. At the same time, transparency does not mean free disclosure of restricted information (bank secrets, trade secrets, insider information, personal data, etc.).
1.4
About the Code of Ethics
If something goes wrong
Whistleblowing
If you have any doubt about what to do in a particular situation, ask yourself the following questions.
If you answered ‘No’ to any of those questions, or if you are not sure if you made the right choice, please discuss a possible course of action with your supervisor whose task it is to provide you with support and qualified advice, or report the information to a whistleblowing hotline.
Self-check list
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Open communication and an environment of trust do not mean that anyone should turn a blind eye to violations. Some situations must be reported immediately to avoid reputational or financial losses, or to mitigate any consequences. Sber offers secure channels to report non-compliance with the Code or the law, or any other violations. Whistleblowing hotlines accept reports both from employees and anyone who believes that a violation needs to be reported.
Sber ensures an independent and comprehensive review of all reports received at our whistleblowing hotlines, including anonymous ones, and provides protection to those who timely report violations and facilitate internal investigations or reviews.
Violations that must be reported immediately
Offering or accepting a bribe, mediation in bribery, promise to give a bribe, any other violations of the Bank Group’s Anti-Corruption Policy
Actions involving significant risks of loss of business reputation, infringement of customers’ and investors’ rights, transactions involving use of insider information, laundering of criminal proceeds and financing of terrorism
Violation of cybersecurity rules
Actions aimed at distorting any reports or statements
Violation of ethical standards resulting in actual or potential damage to an employee(s) or the Bank
Cases of fraud
The Bank does not apply any sanctions to whistleblowers: it does not reprimand, dismiss, or demote them or deprive them of bonuses. On the contrary, Sber encourages timely detection of problems or violations.
See the Whistleblowing hotlines section at the end of the Code for a list of whistleblowing hotlines and contacts
Code of Corporate Ethics and Business Conduct
Relationships within
the Bank
2.1
Relationships
within the Bank
within the Bank
Sber as an employer
Sber is a workplace where people matter. We strive to become the best employer that takes care of well-being of its employees, provides equal opportunities and creates conditions to unlock the potential of every team member.
Sber ensures strict compliance with employment laws.
We guarantee a fair wage in accordance with the results of personal performance assessment. Such assessment takes into account not only an employee’s performance, but also them sharing our core values: “I am a leader”, “We are a team”, “All for the customer”.
Relations between the Bank and our employees are built on the principle of a mutually beneficial partnership, where the employer provides employees with an opportunity to unlock their potential, and in return it expects an equivalent output, initiative and responsibility from them in benefiting from this opportunity.
Team spirit
We believe that team spirit requires ongoing improvement, as it depends on every team member. Some of the key principles underlying Sber’s team spirit are:
1
We create a productive work and business environment
2
We value teamwork where everyone’s voice will be heard
3
We respect the views of others and we share knowledge and resources to achieve stellar results, to ensure a high quality of operations, and to encourage personal and collective growth
4
Our team members treat each other as an internal customer and maintain a friendly and respectful style of communication, including when we deal with coworkers as Sber customers (e.g. when we call a contact center, visit a branch, etc.)
5
Our employees express their opinions openly, are not afraid of talking about their problems, and provide feedback in a constructive manner
6
We admit to our mistakes, learn our lessons, and resolve problems
7
We do not tolerate any bias, offensive or indecent conduct, or prejudice towards our employees, customers, counterparties or any other persons and companies related to the Bank
Taking care of our employees
We believe that happiness and well-being of our employees are fundamental to Sber’s success. We always take care of our employees’ satisfaction as internal customers, and expand our system of corporate benefits and social support. Among other things, this system includes a supplemental health insurance program, accident and critical illness insurance, a corporate pension program, and payments related to important live events.
Sber creates conditions for a healthy lifestyle and high-quality longevity of our employees, supports their efforts to improve their own health, and facilitates the establishment and dissemination of national standards and best practices in the field of public health as a whole.
We are not indifferent to harmony in our employees’ families. That’s why we support moms and dads who work at Sber: we create services helping them to find a better work-life balance and develop parenting competencies and family relations. We also implement programs aimed at comprehensive development of our employees’ children, at unlocking their potential and at their establishment as responsible and successful members of society.
Development and self-fulfillment
Continuous development is a prerequisite for our success, and we therefore pay much attention to professional and personal development of all our team members. Sber provides a wealth of opportunities for career growth, training and retraining of employees, and the development of their professional, leadership and management competencies, including through SberUniversity.
We provide equal opportunities and transparent career development rules for all employees depending on their skills, performance and sharing of Sber’s values.
Recognition
We encourage self-improvement and striving towards strong work performance. The Bank has a system in place for recognition of our employees’ achievements with various types of non-financial incentives, corporate awards and other motivational tools. We distinguish our best employees both for their professional achievements and for exemplary compliance with Sber’s values.
Occupational safety
Safe and comfortable workplace conditions are a priority for the Bank. We maintain those conditions at a high level and take systemic measures to assess and improve them.
However, it is important to keep in mind that workplace safety is guaranteed not only by measures taken by the Bank, but also by strict compliance with safety regulations by every employee.
Even the most important and urgent tasks in Sberbank should be performed only if labor protection requirements are met.
2.2
Relationships
within the Bank
within the Bank
Diversity
and inclusion
In our operations, we adhere to the international principles set forth in the following documents:
UN Universal Declaration of Human Rights
The ILO Declaration on Fundamental Principles and Rights at Work
The OECD Guidelines for Multinational Enterprises
The UN Global Compact
Our company’s obligations in the area of human rights are enshrined in the principles, areas and objectives of Sber’s ESG and Sustainable Development Policy
1
In its operations, Sber ensures a fair and equal treatment of everyone. A deep understanding of and strong support for the inclusion and diversity principles helps us be very sensitive to the needs of the public and of our customers
2
We believe that it is unacceptable to discriminate anyone on the grounds of age, sex, gender, ethnicity, race, political or religious views, health, social and economic status, or any other characteristics that are not related to their professional qualities and work performance
3
Any obscene, vulgar, rude, cruel, discriminatory, aggressive or offensive words, gestures or behavior are unacceptable in our team
4
We do not tolerate any psychological pressure or harassment, or sexually suggestive proposals to coworkers. We do not allow any comments about coworkers’ sexual lives, undesirable actions of a sexual nature, or discussion of inappropriate subjects with such innuendoes with coworkers both on the job and off
If you were subject to any form of discrimination, insults or harassment or witnessed such a situation, please report it to your immediate supervisor or a superior or to an HR business partner of your head branch/functional block, or contact the Corporate Ombudsman Service to enable the Bank to investigate the situation thoroughly and take steps to protect the employee’s honor and dignity.
2.3
Relationships
within the Bank
within the Bank
Conflict of interest
A conflict of interest may arise in any area of activity and for various reasons. Examples include an employee taking part in the charter capital or a management body of another company, conducting entrepreneurial activity, or holding a side job in another organization. Conflicts of interest may also arise as a result of relatives working together at the Bank.
Occurrence of a conflict of interest as such does not represent a violation of Sber’s internal procedures, but it should be immediately reported to an immediate supervisor and/or compliance (even if the conflict is only potential) to enable the Bank to assess the situation and take appropriate steps.
Compliance officers will assess the situation and give recommendations to prevent or mitigate the risk of a conflict of interest. Sber expects our employees to strictly follow these recommendations.
We cannot allow our personal interests to compromise the objectivity and impartiality of our professional judgment or to contradict the interests of our customers or the Bank.
For more details about conflict of interest and how it may occur, see the Conflict of Interest Management Policy of Sberbank Group
Relatives working together
In most cases, Sber allows relatives to work together. But it is important for the Bank to be aware of such situations and to be able to assess the risk of a conflict of interest in advance.
Administrative or functional subordination of one relative to another is prohibited
Employees may not conduct inspections with regard to a relative working at another business unit, or with regard to business areas of a unit where a relative works
Work of members of a single family in business units that are independent of one another may be acceptable subject to adhering to recommendations of Compliance.
Please note that the restrictions apply not only to close relatives.
For a full list of persons that must be reported to Compliance if you work together with them, see the Conflict of Interest Management Policy of Sberbank Group
Work outside of the Bank, participation in the charter capital or management bodies of third parties
Have I disclosed information about my participation in the charter capital of third parties/management bodies of other entities?
How does my work outside of the Bank affect the performance of my job duties at the Bank?
The Bank recognizes the right of our employees to be engaged in entrepreneurial or any other economic activity in addition to their employment with us.
However, it is necessary to keep in mind and comply with the following rules:
Report this activity to Compliance, and make sure that they have approved it
Do not engage in any activity that became available to you due to your position at the Bank, including by virtue of the Bank’s business connections or capabilities
Work on your outside projects only on your own time (outside the office) and outside of the Bank’s premises
Make sure that this activity does not affect the performance of your job duties and does not damage the Bank’s image or interests
Do not promote your services on the Bank’s premises, and do not use your position or capabilities at the Bank to promote your services in the Bank
Strictly comply with the rules for protection of insider or any other non-public confidential information that becomes known to you in the course of performance of your job duties
Q & A
Question
While working in the field of information technology at the Bank, I’m planning to start a private IT business similar to what I am involved in at the Bank. May I do this?
Answer
Employees of the Bank are prohibited from engaging in any entrepreneurial activity that results or may result in a conflict of interest. To assess the risk of a conflict of interest, the Bank has a procedure for preliminary clearing of such activity with Compliance.
Code of Corporate Ethics and Business Conduct
Beyond Sber
3.1
Beyond Sber
Sber’s Ecosystem
Sber connects the needs of people, businesses and the country with its technologies and solutions, integrating all of its services into a single ecosystem. We build common processes, including financial, operational, technology, risk management, and team and culture management, to achieve maximum synergies.
Our objective is to surround our customers with convenient digital services for every occasion. We are not just a bank anymore, but a powerful technology company offering a whole universe of products and services. We are a huge ecosystem, with our customers at the center of it.
Integrating the needs of people, society and the state through technologies and solutions of Sber ecosystem
3.2
Beyond Sber
Customer relations
Customers are the foundation of our business
We aim for long-term relations with our customers, and we therefore take their needs into account as we develop any products, services or offerings.
It is important to us that every customer feel confident and taken care of, so we apply a custom approach to everyone.
Feedback from our customers is a source of our development and self-improvement.
While working with customer queries, we immediately take steps to resolve any problems quickly and to prevent similar situations from happening in the future. We greatly appreciate and thoroughly analyze feedback on our work, because it improves the quality of our products and services and helps us keep our customers’ trust and loyalty.
We expect professionalism and compliance with the highest service standards from all of the Bank’s employees:
Ethical offers and sales of products
Be careful when creating offers and selling Sber’s products and services.
Ask yourself questions from the checklist. If the answer is ‘No’ to at least one of those questions, you have to correct your course of action and consult with your supervisor if necessary.
Self-check list
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We adhere to the principle of zero tolerance for unfair practices of product and service sales.
The Bank believes that misselling is unacceptable – we do not mislead our customers, we provide complete, understandable and reliable information about our products and services and any related risks, and we provide support and information for our customers at every step of product promotion, purchase and use.
3.3
Beyond Sber
Exchanging gifts
Sber recognizes the need for building solid and mutually beneficial business relations with our customers, counterparties and business partners, and considers it possible to receive and give corporate gifts that are compliant with established business practices and the Bank’s requirements. We acknowledge that business gifts are an established component of business relations.
However, we must keep in mind that they should in no event damage Sber’s business reputation, affect objective and impartial decision-making, or result in any obligations.
Any prohibited gifts, as well as gifts that are not compliant with the criteria set forth in the Bank’s regulations, must be declined in a polite manner.
For more details about the rules for handling gifts, see the Bank Group’s Anti-Corruption Policy
Q & A
Question
How should I react if I was offered a gift that is prohibited by the Bank’s internal regulations?
Answer
You should decline the gift and politely explain to the giver that the Bank’s internal regulations prohibit such gifts.
3.4
Beyond Sber
Fair competition
The Bank’s activities are based on the principles of equality, fairness, good faith and a respectful attitude towards not only our customers, business partners and counterparties, but also our competitors.
As we acknowledge the extent of our social responsibility, Sber does not allow unfair practices with regard to our competitors, and respects and complies with the rules of free and fair competition and competition laws in all countries where we operate.
As part of this approach, the Bank prohibits to:
discuss any information related to prices for intrabank services or establishment of prices for customer services with competitors (e.g. in the form of consultations, information exchange at business forums or conferences, or in any other form)
negotiate with competitors about imposing restrictions on any services to customers or about refusing to cooperate with specific customers or partners
negotiate or enter in agreements with competitors about customers, operation in certain territories, or division of markets
discuss competitive tenders with competitors or interfere with them in any other way (i.e. take part in any tender ‘collusion’)
disclose the Bank’s confidential information to competitors, including any information obtained from our customers or partners
approve any provisions that may curtail the commercial freedom of our partners without consultations with our relevant business units
3.5
Beyond Sber
Vendor relations
The Bank’s performance and reputation directly depend on the good faith of our vendors, the quality and safety of goods, works and services they supply, and their responsible attitude.
Sber strives to work with vendors that have an impeccable business reputation, adhere to the principles of strict compliance with applicable laws, business ethics and fair partnership, care about occupational health and safety of their employees, and demonstrate environmental awareness in everything they do.
The Bank selects business partners for providing services, performing work or supplying goods pursuant to the principles of equality, fairness and non-discrimination in accordance with the established procurement procedures. We acquire and use information about partners and competitors only in legitimate and ethical ways.
In selecting vendors, the Bank is guided by the standards set forth in procurement laws and by the Bank’s Procurement Regulation.
The Bank builds its cooperation with vendors on the basis of a fair and responsible partnership. The key principles of vendor selection include ensuring fair competition and providing equal opportunities for all potential vendors. Therefore, it is forbidden to create preferential conditions for participation in tenders or any other procurement procedures held by the Bank.
3.6
Beyond Sber
Shareholder relations
The Bank’s relations with our shareholders are based on the principles of protection of their interests, share ownership rights, and freedom to dispose of the shares at their own discretion. The Bank strives to create the most favorable conditions for exercise of these rights.
Sber sees our interaction with shareholders as a tool for achieving our goals of maintaining and expanding our equity, and therefore the development of a dialog with our shareholders is an important part of our day-to-day activities.
The corporate governance standards and practices followed by the Bank are stated in the Bank’s Corporate Governance Code
Code of Corporate Ethics and Business Conduct
Transparency and protection of boundaries
Sber strives to operate as transparently for the public as possible. We do not conceal any details of contracts from our customers, we do not hide our performance, and we interact within the Bank and with the outside world in an open manner.
At the same time, we do our best to protect our intellectual property and data in our possession (including personal data). We value our reputation and appreciate the freedom of decision-making.
4.1
Transparency
and protection of boundaries
and protection of boundaries
Information disclosure
We ensure the transparency of our operations by interacting with all stakeholders in an open manner, publishing reliable financial and non-financial accounts, and disclosing other information in accordance with legal requirements.
When disclosing information, we are guided by the principles of regularity, consistency, timeliness, accessibility, reliability, completeness and comparability of disclosed data.
As a public company, we fully comply with the requirements of regulators and stock exchanges in the territories where we operate, and publish additional information required by stakeholders in order to make investment or any other decisions and to acquire a full and objective understanding of the Bank’s operations.
For more details about the Bank’s approaches to information disclosure, see the Bank’s Information Policy
4.2
Transparency
and protection of boundaries
and protection of boundaries
Public communications
The Bank has appointed a team of spokespersons that represent us in the public arena. Therefore, when media representatives ask us to comment on a particular matter, we should refer them to an authorized unit – the Bank’s Press Service.
By giving any comments without approval from the Press Service, even if we are experts in the matter, we run the risk of inflicting a reputational damage upon the Bank. If you are required to speak in front of a large audience about any subject related to your work at the Bank, obtain an approval from your supervisor and the Press Service.
When talking to media representatives, investors or analysts, or in any other public communications setting, authorized spokespersons are responsible for compliance with the Bank’s requirements and any laws, and for making sure that any communicated information is reliable and complete.
Q & A
Question
I have been recently invited by my university to speak about my career as part of an alumni relations program. May I talk about my employment at the Bank?
Answer
You may speak at any external events (such as conferences, forums, or round tables) about your work experience at the Bank only subject to prior approval from your immediate supervisor and the Bank’s Press Service.
Social media
We are happy when our employees take pride in their company and their work with us, and we therefore support our employees’ desire to repost publications from Sber’s official accounts and websites!
Q & A
Question
May I answer customers’ questions or complaints addressed at the Bank in social media in my own name?
Answer
No, you may not. Answers to any questions or comments in social media are prepared on the Bank’s behalf by authorized officers of the Bank and only from the Bank’s official accounts. If you are concerned about the Bank’s reputation or would like very much to help a customer, tag the Bank’s official account in your comment, and support will definitely notice the customer’s question and respond.
4.3
Transparency
and protection of boundaries
and protection of boundaries
Protection of confidential
information
Information is a key asset of Sber
As part of their job duties, employees may have access to confidential information (including personal data), trade or banking secrets.
We expect owners of non-public information at the Bank to treat it in an extremely responsible manner:
Never leave storage media unattended. When you leave your workplace even for a short period of time, make sure that no confidential files are left on your computer screen
Be especially careful with hard-copy materials – do not leave them on a printer, and never work with them in a public place, such as transportation or a coffee shop
Never use confidential information for personal purposes, never copy it or capture on photo or video
Never upload such information to cloud storage
Transmit confidential information only by secure channels and only on a need-to-know basis
Personal data
Enforcement of rights and freedoms of personal data subjects is our priority.
Sber processes personal data of our customers, employees and other subjects in strict adherence to the laws of the Russian Federation and in compliance with applicable international requirements and obligations, and only if there is a legal basis for that.
We follow the principle of minimization of personal data processing, and we process them only to the extent and within time limits required to achieve legitimate goals.
By setting high standards for personal data processing and protection – including within our own ecosystem – and for interaction with our partners, we contribute to fostering a culture of conscious treatment of personal data in our country.
The Bank expects former employees to maintain the confidentiality of restricted information obtained by them while employed by the Bank. In turn, the Bank will not require newly hired employees to disclose any sensitive/non-public information of organizations where they were employed before.
Cybersecurity
Cybersecurity is one of the priority areas for the Bank’s development. Faced with digital transformation and widespread cyber fraud, all team members must not only continuously improve their digital literacy, but also serve as knowledge ambassadors for our customers.
Mandatory knowledge and competencies in the field of cybersecurity include:
Security requires a proactive approach: we prefer not to resolve issues, but to avoid them in the first place. This means continuously applying and disseminating cybersecurity knowledge both at workplace and in everyday life, staying alert all the time, and never letting the guard down on data security matters.
Compliance with basic cybersecurity rules and principles will allow us to protect not only our customers’ money, but also the Bank’s business reputation.
In case of any suspicions of cybersecurity incidents, contact the Cybersecurity Support Center. For more details, see the Whistleblowing hotlines section
4.4
Transparency
and protection of boundaries
and protection of boundaries
Protection of assets
and intellectual property
Sber provides our employees with every opportunity to express their creativity and protect their ideas – which constitute Sber’s intellectual capital that propels the Bank forward.
Things like software code, design elements, algorithms and models, new devices and other unique ideas developed by our talented team represent the Bank’s intellectual property, a most valuable asset that needs to be carefully protected. Any use of our IP by Sber team members or any other people that we interact with should always be good-faith and lawful.
Sber’s intellectual assets may not be used by employees for their personal purposes.
Sber respects intellectual property rights of any person or company. We use intellectual property of others only lawfully, and we expect our employees, counterparties and business partners to always follow this principle in a responsible manner.
Bank’s intellectual property
Any ideas developed in Sber must remain in Sber, even after their creators leave the team. At the same time, Sber respects the rights of developers as authors, and guarantees that they will be protected.
Code of Corporate Ethics and Business Conduct
Sber and the state
5.1
Sber
and the state
and the state
Compliance with laws
We disapprove of unethical doing-business practices of any kind, and we expect all Sber team members to fully comply with laws of every country where we are present.
Anti-money laundering, combating the financing of terrorism and proliferation of weapons of mass destruction
Sber fully complies with the requirements set forth in anti-money laundering laws.
We make every effort to ensure that we only do business with reliable customers and counterparties whose activities are transparent.
In serving our customers, we make sure that the specifics of their business and the sources of their funds are easy to understand and make business sense, and the details of customers and related persons are timely updated.
Q & A
Question
A customer I work with has changed their line of business and is asking me how to avoid an anti-money laundering review of their transactions. May I help them?
Answer
The Bank’s employees are prohibited from informing customers of measures taken by the Bank to comply with the anti-money laundering law. You may invite the customer to read a safe conduct reminder posted on the Bank’s website.
Question
A customer has asked me to divide a large payment in favor of a single payee into several smaller transactions, since they are wary of control procedures.
What should I do?
What should I do?
Answer
Report to Compliance before executing the transaction, then do as advised by Compliance.
Combating illegal use of insider information and market manipulation
Sber values the high level of public trust in what we do, and therefore we promote a fair pricing of our shares, bonds and other financial instruments, and we pay close attention to compliance of the Bank’s activities with any laws, international standards and best practices in protection of insider information.
In the course of their employment, every member of our team may obtain insider information about the Bank or other organizations before it becomes public. Unauthorized or premature disclosure of this kind of information may have an impact on the market and damage the Bank, our customers, shareholders or partners.
Am I not disclosing significant information that I have access to at work and that is not yet known to the public?
Every member of the Sber team must keep in mind and comply with the following rules and restrictions:
Never conduct personal transactions with financial instruments of any entities in regard to which you have insider information, and never advise others to conduct such transactions
Never disclose insider information to anyone outside of the Bank, including your family members, before it is disclosed officially
Transfer insider information to other Bank employees only on a need-to-know basis and in accordance with the established regulations
Never take any actions aimed at manipulation of market prices, and never spread false information or rumors
Comply with Sber’s established rules and restrictions on personal transactions (deals) with financial instruments
Q & A
Question
While speaking with a customer, I learned some information that would help me make a profitable securities transaction before that information becomes public. What should I do?
Answer
You may not perform the transaction, because it could be regarded as a transaction made with the help of insider information and you will be prosecuted under applicable laws.
For more details about the Bank’s rules concerning protection of insider information, see the Sberbank Policy on Countering Illegitimate Use of Insider Information and Market Manipulation
Anti-corruption measures
Is a service offered to me by a Bank partner acceptable or is it a disguised remuneration?
The Bank adheres to the principle of zero tolerance for corruption in any forms or manifestations in our operations, and promotes an anti-corruption culture both among the general public and our employees. The Bank integrates anti-corruption principles into strategic and operational management at all levels of operations.
Sber team members are prohibited under any circumstances from promising, offering, giving, soliciting, or accepting bribes, either directly or indirectly, in person or through any third parties.
Sber also does not tolerate any other corrupt practices for simplification of administrative, bureaucratic or any other procedures.
The Bank expects our customers, counterparties, vendors and business partners to comply with the respective principles, requirements, restrictions, prohibitions and duties for the purpose of combating corruption.
Our common goal is to maintain a strong business reputation of the Bank.
Q & A
Question
What should I do if I witnessed a coworker violate the Bank’s anti-corruption requirements?
Answer
You should report this violation to the compliance hotline.
For more details about our anti-corruption principles and requirements, see the Bank Group’s Anti-Corruption Policy
Anti-fraud measures
Our commitment to doing business fairly and transparently serves as a basis for Sber’s positive image and reputation, and creates a safe, healthy and productive environment within the Bank. We believe that our adherence to the principle of zero tolerance for fraud helps us make a significant contribution to the development of culture in society at large.
We define fraud as any deliberate act or omission resulting in abuse of trust of Sber, our customers, counterparties or business partners.
Any deliberate violation of laws by a Bank employee will not only result in their personal liability, but will also compromise Sber’s reputation.
We expect our customers, counterparties and business partners to demonstrate an appropriate ethical conduct and maintain an anti-fraud culture.
An important part of our culture is voluntary reporting by employees of any actual or suspected violations of the law using whistleblowing hotlines existing in the Bank.
5.2
Sber
and the state
and the state
Government relations
The Bank’s relations with national and local government authorities, banking regulators and supervision bodies are based on the principles of legal compliance, transparency and cooperation.
The Bank’s employees must be polite and professional, express only the Bank’s official position, and never interfere with investigations, if any.
Code of Corporate Ethics and Business Conduct
Sber and society
6.1
Sber
and society
and society
Sustainable development
Sber is a responsible bank. Our strategy is driven by long-term value creation. In our day-to-day activities, we are guided by the seven principles stated in Sber’s ESG and Sustainable Development Policy.
For more details about our sustainable development and ESG principles, see the Sber ESG and Sustainable Development Policy
Areas of sustainable development
Charity and sponsorship
Sber supports charity and social initiatives that make people’s lives better. In particular, we facilitate projects aimed at the development of regions where we operate.
Our top priority is to support education and create conditions for developing an inclusive environment and creative abilities among children.
The Bank takes part in charity projects that support science, culture and healthcare. Taking care of war veterans takes a special part in our social policy.
As part of our sponsorship programs, we not only provide assistance to Russian and international business events, but we also help Russian theaters and museums, support art festivals, stage performances and concert programs, and take part in publication of books and improvement of public spaces.
The core principles of the Bank’s charity activities are stated in our Policy
Corporate volunteering
Sber supports volunteering by our employees based on the principles of voluntary participation and smart assistance. The Bank creates conditions for all corporate volunteers to participate in and implement social projects.
Promotion of financial literacy among the public is another important area reflecting the specifics of Sber’s activities – we launch and support educational projects carried out by our volunteer employees who help our customers better understand how financial products work, manage their finances competently, and protect themselves against fraud. Our financial literacy programs are primarily aimed at the most vulnerable audiences that require special social support (senior citizens, orphaned children, etc.).
Political participation
The Bank does not participate in activities of political parties or organizations, and does not promote or finance activities of any confessional groups aimed at propagation of religious views. Interaction with religious organizations may only take place for the purpose of preservation of cultural heritage.
Employees participating in political, religious or other public activities in their free time should act in such cases only in their capacity as private individuals and not as the Bank’s representatives.
6.3
Sber
and society
and society
Artificial intelligence
The Bank is keenly aware of the importance of new technologies, uses them in our operations, and actively promotes their development and implementation to increase the prosperity and quality of life of the public. Artificial intelligence (AI) is one of the technologies widely used by Sber. We are fully aware of the risks associated with the application of AI in the Bank’s operations, and therefore we treat the technology with utmost responsibility. Our goal is to use only secure AI systems that are trusted by our customers.
The Bank’s Executive Board has approved the Ethical Principles for the Development and Application of AI Technologies that are mandatory for all of the Bank’s employees.
These principles include:
In view of rapid development of AI technologies, the Bank continuously updates our corporate rules for ethical application of AI and takes part in establishment and development of AI application ethics nationally. Among other Russian technology companies, Sber has joined the AI Code of Ethics that establishes the ethical principles at the national level.
For more details about the rules of ethical AI application, see the Ethical Principles for the Development and Application of AI Technologies and the AI Code of Ethics
Code of Corporate Ethics and Business Conduct
Final provisions
Naturally, it’s impossible to foresee all potential situations that may occur in the course of our work. That’s why we urge you to be always guided by common sense and by the Bank’s existing rules, be responsible, and keep in mind the Bank’s mission and values. If in doubt, consult with your supervisor or coworkers, or contact our whistleblowing hotlines.
We believe that all team members strictly following the principles and standards stipulated in this Code will guarantee the Bank’s efficient performance, maintain and enhance our reputation, and promote the development of strong business relations with our customers, counterparties, business partners and other persons.
Please consult the following internal documents to better understand Sber’s principles and rules summarized in this Code of Ethics:
The Development Strategy
The Corporate Governance Code
The Book of Values
The Conflict of Interest Management Policy of Sberbank Group
The Anti-Corruption Policy of Sberbank Group
The Procedure for Working with Documents Containing Confidential Information
7.1
Final
provisions
provisions
Liability for violation
of the Code
It is necessary to keep in mind that adherence to the provisions of the Code will be taken into account for employee performance reviews and for making promotion decisions.
Depending on legal grounds, employees who do not comply with the Code provisions may be subject to disciplinary measures according to the procedure established in the employment laws and the Bank’s internal documents. A failure to comply with any laws, including in the field of anti-corruption measures or protection of insider information, as well as any breach of banking secrets, may result in liability, including criminal prosecution.
7.2
Final
provisions
provisions
Whistleblowing hotlines
Corruption, conflict of interest, insider information, market manipulation, pseudo trust management
If you become aware of any acts of corruption, violations related to conflict of interest, unlawful use of insider information, market manipulation or pseudo trust management of customer assets, you can contact the 24/7 Compliance Hotline.
Compliance Hotline
- ethics@sberbank.ruemail
- +7 495 665-86-09phone
- A feedback formfound on the Bank’s official website www.sberbank.com in the Compliance section
- Regular mailSberbank Compliance Division, 19 Vavilova St., Moscow 117997, Russia, with a Compliance Hotline mark on the envelope
Fraud, extortion, theft, leaking of banking information
If you witness any Sber employees engage in fraud, extortion or theft, or selling or transferring sensitive banking information, you can contact the 24/7 Trust Line of Internal Security.
The Trust Line of Internal Security
- hotlineuvb@sberbank.ruemail
- 8 800 555-13-35phone
Cybersecurity and confidential data
For clients
If you become a target of an attack by fraudsters by phone, SMS or email, report the incident in detail using the Report a Fraudster form in the Sberbank Online mobile app.
For employees
If you detect a violation of the cybersecurity rules, receive a suspicious email, learn about unauthorized access to or a leak of confidential information, or detect a network attack or a phishing website impersonating the Bank’s resources, report the incident immediately to the Cybersecurity Support Center.
Your cybersecurity section at the Bank’s official website www.sberbank.ru
Report fraud form in SberBank Online mobile app
Cybersecurity Support Center
- SCST@sberbank.ruemail
Team atmosphere, relations with supervisors and coworkers
If you face unethical treatment of yourself or a coworker by a supervisor or another coworker, report the incident to your superior (if possible under the circumstances) or to HR.
The Bank will use your report to investigate the situation thoroughly and take appropriate steps
Send a report to
- HR
- culture_code@sberbank.ruemail
Unresolved or controversial situations
If a matter you raised could not be settled through any of our whistleblowing channels, you can engage the corporate ombudsman in resolving the problem. The main task of this officer is to get to the bottom of the situation and resolve it in an objective manner. The Corporate Ombudsman Service reports directly to the CEO, Chairman of the Bank’s Executive Board and is tasked with resolving the most challenging problems and disputes that arise in the course of our operations. Reports may be anonymous.