Compliance

Published: 19/3/2018 Modified: 18/8/2021

As the central bank of the Republic of Croatia and a member of the European System of Central Banks, the Croatian National Bank is committed to promoting integrity and the highest ethical standards. Ethical values paramount to its independent, professional and public role are set out in the Code of Conduct of the Employees of the Croatian National Bank. The purpose of the Code of Conduct is to create the preconditions for ethical behaviour and responsible business conduct and promote organisational culture values. Compliance with ethical principles and rules is a personal responsibility of all the staff members, including officials. The Bank promotes responsible conduct, professionalism, independence, impartiality and transparent conduct of all of its employees, while the ethical rules and principles also apply, as appropriate, to all external agents participating in the performance of activities connected with the Bank’s tasks. The Code of Conduct incorporates the provisions of the Guideline (EU) 2015/856 of the European Central Bank laying down the principles of an Ethics Framework for the Single Supervisory Mechanism (ECB/2015/12) containing ethics standards applying to all the central banks comprising the Single Supervisory Mechanism, including the Croatian National Bank.

In order to ensure appropriate and consistent application of ethical rules, compliance therewith should be supervised and monitored, by employing reliable mechanisms. Promoting employees’ compliance and supervising the implementation of the Code of Conduct is the responsibility of the Compliance Office, the Bank’s control function that reports directly to Governor. One of the core functions of the Compliance Office is its educational role, i.e. promoting ethical principles, providing assistance to employees in understanding the principles of ethical responsibility, thereby preventing potential unethical conduct in the future.

The core rules contained in the Code of Conduct concern avoidance of conflicts of interest, the prohibition on misusing inside information and the prohibition on receiving advantages.

Conflict of interest

Managing conflict of interest is at the core of ethical conduct.  The Code of Conduct lays down rules with the aim of preventing situations that may lead to conflict of interest and procedures in the event circumstances arise pointing to a real or possible conflict of interest. Any situation in which personal interests of employees affect or may affect the impartial and objective fulfilment of obligations arising from the employment relationship is considered a conflict of interest.

Inside information

The Bank’s employees are prohibited from misusing inside information they may become aware of in the performance of their work. The Bank’s employees that have access to inside information other than on a one-off basis (insiders) are subject to specific restrictions with regard to critical private financial transactions.

Prohibition on receiving advantages

The employees of the Croatian National Bank are prohibited from accepting any gifts, hospitality or other benefit of a financial or non-financial nature offered to them based on their position in the Bank. By way of exception, employees may accept gifts of small value, in accordance with the clear set of rules contained in the Code of Conduct.

In order to safeguard the objectivity and independence of the Bank’s employees and to avoid potential unpleasant situations, we hereby call on all the business partners to refrain from expressing their satisfaction with the Bank and its employees by offering gifts to the Bank’s employees.