MOB Code of Conduct

CODE OF CONDUCT

PURPOSE

The purpose of this Code of Conduct is to:

By adopting, following and updating this Code of Conduct on a regular basis, together with the Bank’s corporate governance manual, MOB confirms its desire to demonstrably lead and promote good ethical behavior and corporate governance.

This Code of Conduct is reviewed and updated on an annual basis.

MOB’S ETHICAL PRINCIPLES

The Bank is committed to act ethically in all aspects of its business. The Bank’s ethical standards are based on the following principles;

Similarly, the Bank expects the same in its relationship with all those with whom it does business.

The Bank’s ethical standards focus on the following areas: employees, customers, relations with its business partners, government, society and the wider community. These ethical standards shall also apply to all business areas for all subsidiaries and dependent companies both within and outside of Myanmar.

All of the Bank’s ethical standards are based on:

The Bank’s business plan will include specific, measurable targets for improving ethical behavior.

ETHICAL STANDARDS FOR THE BANK’S RELATIONSHIP WITH ITS STAKEHOLDERS

1. EMPLOYEES, OFFICERS AND DIRECTORS

• The Bank is committed to treating all employees with dignity , trust and respect, and to building a long-term relationship based on Myanmar’s labor law and the respect of human rights. The Bank will not employ child labor.
• It is the Bank’s policy to provide for and regularly improve upon a healthy, safe and secure working environment for its employees.
• Conflicts of interests can, or appear to, compromise the judgment or objectivity of the Bank’s employees and officers. An appropriate conflict policy and disclosure there has been adopted by the Bank.
• The Bank’s is an equal opportunity employer. Its recruitment, promotion and compensation policy is based on merit and free of discrimination. Clear and transparent policies to this extent have been developed and put into practice.
• Any kind of discrimination or harassment at the workplace will not be tolerated and contrary behavior properly investigated and dealt with through the Bank’s human resources manager and/or MOB’s Board of Directors.
• Employees are recognized and rewarded for their performance based on performance objectives, and constructive and regular feedback, through face-to face meeting. The Bank has in place a program, accessible to all employees, which encourages individuals to formulate personal development plans and provides for coaching mentoring and formal skill-enhancing trainings.
• Under the authority of this Code, it is incumbent upon Employees to speak up or report any breaches identified or witnessed per the procedures under this Code.
• The company sanctions the illegal use of confidential and insider information by all officers and employees, and has developed a detailed procedure to effectively deal with this matter.
• A regular consultation process between the Bank’s employees and manages has been put in place to effectively deal with employment conditions and other issues that affect the employees work environment
• These principles do not limit the right of the company to enforce discipline or the discipline or issuers that affect the employees work environment.
• These principles do not limit the right of the company to enforce discipline or to terminate workers in accordance with Myanmar legislation.
• MOB directors and officers shall be of good reputation and good standing, shall not be individuals, or individuals representing a company or person that is deemed a ‘Restricted Person’ and small not have committed any crime or sanction able practice . (i.e practice that involve corruption, fraud, coercion ,collusion, or obstruction ) or representing a company or a person that has, such as practices that involve corruption, fraud, coercion, collusion, or obstruction. If a Director or officer ceases to meet such qualification, that person shall resign or be dismissed.

2. CUSTOMERS

Customer satisfaction is tantamount to the company. Safe and quality products and services, fair pricing and appropriate after-sales service shall define the Bank’s relations with its customers.

The company always seeks to deliver what it promises.

3. RELATIONS WITH ITS BUSINESS PARTNERS

• The Bank will put forth its best effort to only cooperate with business partners that share the same ethical standards as MOB.
• The Bank will respect the sanctity of contracts and business relations.
• The company is committed to complying fully with the Myanmar law on anti-money laundering and only conducts business with reputable suppliers, business customers and other partners who are involved in legitimate business activities and whose funds are derived from legitimate sources.

4. GOVERNMENT

• The Bank seeks to build and manage a sound relationship with governmental authorities on an arm’s length basis. No attempts to improperly influence governmental decisions shall be made, and the Bank will not offer, pay, solicit or accept bribes in any form or shape, either directly or indirectly, in its dealings with the government, administration or counts.Transparent procedures regarding transactions engaged in by the Bank with any government agency or official , or in dealings with any company owned or controlled by a government agency or official , shall be established to this end.
• The Bank will never make political contributions whether in cash or in kind.

5. SOCIETY, ENVIRONMENT AND THE WIDER COMMUNITY

• The Bank’s views itself as an integral part of the community in which it operates and is committed to a sound relationship built on respect, trust honesty and fairness.
• The preservation of the environment is of the utmost importance to the Bank. The company thus strives to minimize any disruption to the environment arising from its activities by reducing waste, emissions and discharges, and by using energy efficiently.
• Non-governmental organizations (NGOs) are a key element to any society and the company seeks to build constructive relationships with such organizations in building a better society and environment in an economically sustainable matter.

IMPLEMENTATION

1. MEANS TO OBTAIN ADVICE

Many business decisions involve ethical dilemmas and require complex judgments to make the right choice. In cases of uncertainty all officers and employees are expected to act responsibly and raise the ethical dilemma with their managers. Should this not lead to a satisfactory solution the ethical issue is to be raised with a designated officer to obtain clarification. All officers and employees have the right to make confidential reports directly to the designated officer who in turn shall decide whether to report the matter to the Board Audit Committee to recommend appropriate action against any director or employee who acts in a manner inconsistent with this code of conduct.

2. PROCESSES AND RESPONSIBILITY

Each individual is responsible for his or her ethical behavior. The Bank has implemented a procedure for all officers and employees to regularly state they understand and apply the provisions of this code of ethics. Adherence to this Code is further made obligatory as it is referenced in all employee contracts and linked to disciplinary procedures. A copy of conduct is given to every employee on his or her first working day.

Department heads are accountable to the CEO and / or executives for implementing this Code of Conduct within their departments, ensuring that all officers and employees understand it and for providing assurance on compliance. The CEO and / or executives are in turn accountable to the Board.

The principles and provisions in this code of ethics have been integrated into the Bank’s system of internal control. Rigorous and objective processes to measure performance, Identify gaps and implement measures to address ethical gaps are regularly reviewed and modified.

The Board’s Audit and Compliance Committee periodically reviews and updates compliance with these principles and formulates proposals for the board’s approval.

3. TRAINING PROGRAM

The Bank offers an introductory ethics-training course once per year for all view officers and employees. This course offers practical examples of this Code of Conduct in action. Periodic and specialized training courses are further offered to the Bank’s officers and employees, as well as to the Bank’s other stakeholder such suppliers and other business partners, as part of the Bank’s continuous professional education program.

4. ANONYMOUS REPORTING OF CONDUCT CONCERNS

The Board shall establish the following procedures to enable anyone who has a concern about MOB’s conduct, or any employee who has a complaint about the Company’s accounting, internal accounting controls or auditing matters, to communicate that concern directly to the Audit and Compliance Committee Chairman or other Audit and Compliance Committee member. Such communications may be confidential or anonymous, and may be e-mailed, submitted in writing or reported by phone to special address published on the Company’s website. All such communications shall be promptly reviewed by the Audit and Compliance Committee. The Audit and Compliance Committee may direct that certain matters be presented to the full board and may direct special treatment, including the retention of outside advisors or counsel, for any concern addressed to them. MOB further prohibits any director or employee from retaliating or taking any adverse action against anyone for raising or helping to resolve an integrity concern.

For reporting misconduct, staff may anonymously report incidents to the Chairman of the Board Audit & Compliance Committee via: speakup@mobmyanmar.com