Document Categorization: For Internal Use Only

Code of Conduct “Universal Bank” regarding banking secrecy, staff transactions, staff
conflict of interest etc.

“APPROVED”
Minutes of the Board Meeting
of PJSC Universal Bank
№ 43 , dated 31.10.2013

___________________________
Chairman of the Board
Miltiadis Papanikolaou

REGULATION

Name : Code of conduct “Universal Bank” regarding

banking secrecy, staff transactions, staff
conflict of interest etc.

Code : 05.26

Responsible Unit : Compliance Division

Applicable to : P.J.S.C. Universal Bank

Version : 3.0

Valid as of : 31.10.2013

Distribution : All units of P.J.S.C. Universal Bank

Created by: Approved by: Issued by:

Unit: Unit: Unit:

Compliance Division Human Resourses Division Organisation and planning
Unit
Head of Unit:
Head of Unit: O.Logvina Head of Unit:
O.Alekseeva Olena Ogiyenko

Date: 31.10.2013
Date: 31.10.2013 Date: 31.10.2013

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Code of Conduct “Universal Bank” regarding banking secrecy, staff transactions, staff
conflict of interest etc.

Table of Contents
1. Introduction
2. Scope
3. Handling of queries
4. Banking secrecy , commercial secrecy
5. Protection and use of the Bank’s assets
6. Conflict of interest
6.1. Staff accounts and investments
6.1.1. Staff Accounts
6.1.2. Managing third party’s accounts
6.1.3. Own Account Transactions
7. Abuse of confidential information
8. Staff transactions
9. Special staff rates
10. Client priority
11. Money laundering
12. Gambling
13. External employment- business activity
14. Charitable & social activities
15. Gifts and other benefits
16. Code of conduct monitoring
17. Definition and examples
18. Amendments table
19. Table of Controls and Approvals
20. Appendixes

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1. INTRODUCTION

The Bank based in Ukraine are subject to supervision by the relevant regulatory
authorities and are obliged to comply, at any point in time, with the regulatory
requirements in force. In this context, the Bank drafted the present Code of Conduct
(“CoC”), in order to secure full compliance with the regulatory framework in place as
well as the internationally recognized standards of banking ethics.

The Code of Conduct rules apply in addition to and are complementary to the
requirements of the legal framework and aim at setting minimum common internal rules
and principles of professional conduct and ethical behaviour to be followed by the Staff
of the Bank based in Ukraine during the performance of their duties.

These rules may be broadened or strengthened, in order to be in line with the demands of
particular laws and regulations, in accordance with the legal and regulatory framework in
place.

The present CoC stands as the Bank’s internal regulatory framework. Compliance with
the rules of the CoC is subject to monitoring by the relevant Compliance/Internal Audit
divisions of the Bank. Any identified violations of the provisions of this CoC may be
referred to the respective bodies of the Bank and could lead even to the discontinuation of
the employment contract with the Bank.

As a general principle, members of Staff must display diligence during the performance
of their duties and to protect and promote the interests of the Bank in any lawful way.

In performing their professional responsibilities, the members of Staff must act in an

honest, just, unprejudiced, responsible and professional manner in order to promote the
integrity of transactions and to secure the equal treatment of clients. In cases where a
member of staff faces difficulty in handling a specific situation during the performance of
his duties, it is recommended that he asks advice and/or instructions from his/her
supervisors/managers or directly from the Bank’s Compliance Division.

Every member of Staff must respect the Organization itself, its clients and the people
with which he cooperates. Any form of discrimination (e.g. due to nationality, origin,
family status, race, sex, religion, etc) or harassment, are considered unacceptable and are
not consistent with the Bank’s principles which aim to establish a dignified workplace.

Each Staff member of the Bank must sign a ‘Declaration of Receipt and Acceptance of
the Code of Conduct’ (Appendix 1) confirming receipt and acceptance of the terms of
this Code.

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2. SCOPE

The provisions of this Code apply to the “Staff” which is defined to include the
following:
a) all members of the Supervisory Board of the Bank,
b) all executives of the Bank,
c) all employees of the Bank, full time and part time employees,
d) all persons engaged by the Bank as contractors and
e) all persons engaged by the Bank in Advisory positions.

The rules of the CoC also apply to all immediate family members of the Staff. The
obligation to comply with the rules applies to all behaviour and/or actions which could be
linked directly to a member of Staff (e.g. transactions in securities, dissemination of false
or falsified information to third parties etc).

Compliance with the provisions of the CoC also apply to any legal form/company on
which any member of Staff may have significant interests or influence (e.g. limited
liability companies, offshore companies etc).

3. HANDLING OF QUERIES

The Bank’s Compliance Division is responsible for handling all potential queries that
may arise and for training the members of Staff in the correct implementation of the CoC.
It is also responsible for its revision, whenever deemed necessary, in order to ensure its
full alignment with any changes in the legal/regulatory framework.

4. BANKING SECRECY, COMMERCIAL SECRECY

The Staff is strictly prohibited from disclosing to third parties any information they have
acquired during the performance of their duties (Commercial and Banking Secrecy). A
third party is any party not entitled to know the above information, including any member
of Staff who does not need this particular information for the performance of his/her
duties.

It is hereby clarified that inquiring or searching through client accounts and client data
stored in the Bank’s main or peripheral systems to which staff has access to, is unethical
and considered a violation of the present Code, when performed outside the context of
one’s business obligations.

All Staff must abide by the commercial and banking secrecy rules against any third party,
even after leaving the Bank.

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5. PROTECTION AND USE OF THE BANK’S ASSETS

All members of Staff must show the requisite due diligence for safeguarding the tangible
and intangible assets of the Bank in order to secure their integrity and proper professional
use. Assets include, but are not limited to, buildings and fixed assets (e.g. any type of
machinery, computers, desks, drawers, filling cabinets, lockers, archives and in general
any equipment used by staff in the performance of their daily duties), software,
communication networks, procedures, elements of corporate identity, information,
customer base, supplier information, reports, regulatory documents, files, supplies.

The Bank’s assets are provided to Staff for business purposes and should not be used for
personal benefit. Any concern regarding the proper use of the Bank assets must be
reported to one’s supervisor or to the Security Division.

The control functions of the Bank (Compliance/Internal Audit) are allowed access to such
assets within the scope of their activities.

6. CONFLICT OF INTEREST

The rules of conduct also aim to ensure the avoidance of situations that might cause
conflicts of interest. Members of Staff are obliged to identify and manage potential
conflict of interest situations.

Any conflict of interest situation will be assessed independently, in order to determine

whether it is important or substantial enough to be prohibited.

In case a member of Staff has any doubts in respect of handling a specific case and
particularly as to whether such case involves or not a conflict of interest, he/she must
contact the Bank’s Compliance Division. In the cases where the Bank’s Compliance
Division decides that there is indeed a conflict of interest, the person involved shall file
an application for approval with respect to the conflict of interest.

In cases where a member of Staff of the Bank based in Ukraine is called upon or
voluntarily decides to stand as a witness (e.g. in cases related to clients, other members of
Staff or even ex-staff members) in legal proceeding or out of court settlement
proceedings, in order to provide information in his/her capacity as a member of the Bank,
he/she must refrain from any action prior to informing and consulting with the Bank’s
Legal Division, Security Division or the Bank’s Compliance Division.

6.1. Staff accounts and investments

6.1.1. Staff Accounts

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It is recommended that all cash and investment accounts (deposits/securities) of the
members of Staff and their immediate relatives are held with the Bank. To ensure the
transparency of the transactions performed by the Staff, it is recommended that cash
transactions and particularly large cash sums to third parties are avoided. For instances
where large cash sums are being handled, it is recommended that such transactions are
performed via electronic money transfers.

Staff who keep cash and/or investment accounts with other credit or financial institutions,
must submit to the Audit/Compliance functions of the Bank, copies of the statements of
the transactions executed in the other financial institutions, if so required in the context of
an investigation.

All newcomers during the employment stage must inform the Bank’s Human Resources
and Compliance Divisions in writing about the loans they have with other banks
(Appendix 2)
Moreover, in case a member of staff during his/her employment with the Bank is granted
a loan(s) from another Bank(s), he/she is obliged to notify the Bank’s Human Resources
and Compliance Divisions.

6.1.2. Managing third party’s accounts

Bank Staff is allowed to hold authority/power of attorney to manage the accounts only of
their husbands/wives, relatives (blood relatives up to the 3th degree or relatives by
marriage up to the 2rd degree), as well as with persons with which they cohabit. If a
member of staff wishes to obtain authority/power of attorney to manage an account of a
person not falling under the above categories, prior permission by the Bank’s Compliance
Division is required. This may be obtained with the submission by the Staff member of
the relevant application form, after the written recommendation and approval of the
supervisor (Appendix 3).

Similarly, in order for a member of Staff to give authority/power of attorney to a third

party (other than the relatives of the degree mentioned above), prior permission by the
Staff member’s supervisor and the Bank’s Compliance Division is required.

More specifically, with regards to stock exchange transactions, Staff members are strictly
prohibited from acting on behalf of clients as their authorized representatives.

6.1.3. Own Account Transactions

The Staff of the Bank are not allowed to perform any transactions on their own accounts
(examples include: opening of account, transfers between his/her own accounts and those
of third parties, liquidation of investment products, etc) as well as any transaction for
their own benefit, through the central or peripheral systems of the Bank to which they
have access in the context of their work.

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All such transactions have to take place through the official channels of transaction
performance (branch, ATM, phone banking, e-banking).

The prohibition applies to any transaction performed by a member of Staff in the

account(s) and/or portfolios of investment products to which he/she has authority/power
of attorney.

Moreover, the Staff of the Bank is prohibited from performing any transactions on their
own accounts on behalf and/or in favor of a customer (deposits, payments, transfers, cash
deposits or withdrawals, loan or loan interest repayments etc).

7. ABUSE OF CONFIDENTIAL INFORMATION

It is strictly prohibited for any member of Staff to use for his/her own benefit or for the
benefit of a direct family member privileged information in connection with financial
instruments or services offered which are not known to third parties and have not been
publicized. Moreover, in no case, shall such privileged information on a client be used
against another client or for own benefit. Such kind of information must not be
communicated to others, except in cases where it is required by the Regulators, in
accordance with the procedures in place.

It is also prohibited for Staff to participate directly or indirectly (through other persons) in
auctions for the sale of tangible or intangible property of the Bank’s debtors as well as in
any related activity which could have a negative impact or consequence to the integrity
and reputation of the Bank. Cases where the Bank itself invites staff to express interest to
participate in the purchase of assets, in accordance with the procedures of the relevant
Unit of the Bank are excluded from the prohibition. However, members of Staff working
in units managing the relevant assets as well as members of the Legal Collections Unit
and of the Non Performing Loans Unit must obtain prior approval from the management
of the Unit with simultaneous notification of the Bank’s Compliance Division.

Staff should under no circumstances proceed with executing transactions which are in
violation of the Capital Market regulations regarding market abuse (e.g. front running,
piggy backing, wash trades, painting the tape etc) or which would create doubts on the
transparency with regards to information related to issuers of securities listed in an
organised exchange or MTF.

Staff working in the investment banking sector and receiving information with regards to
the activity of issuers or potential issuers of securities in advance, is not allowed to use
any such privileged information for his/her own benefit and must, in every instance,
comply to the rules applying to the wider investment public. Such persons must inform
their supervisor and the Bank’s Compliance Division in writing, during the acceptance of

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the relevant investment banking mandate, of the number of securities by the respective
issuer they own, if any.

In addition, the members of Staff receiving confidential or other non-public material

information (which may for example lead to a business opportunity) in the context of
their work are prohibited from using such information themselves or through third
parties, for their own benefit, without informing the Bank in advance through the CEO
and the Bank’s Compliance Division.

Staff, whose subject of business activity is related to analyzing and reporting on securities
and/or making recommendations or offering advice on the investment strategy with
regards to specific securities, are not allowed to perform transactions for their own
benefit or for the benefit of any third party, during the period from the initiation of the
analysis, recommendation or proposal to its initial publication to the investment public.
Each analyst must inform in writing his/her supervisor, when taking on an assignment, on
the number of securities he/she owns in the company subject to the analysis, if any. At
the inception of such analysis/research, the Bank’s Compliance Division must be
informed with regard to the kick-off date as well as the persons involved in the process.

Staff receiving information regarding investment transactions of the Bank’s own portfolio
in the context of acting as a Market Operator/Market Maker, must not use such
information for his/her own benefit or for the benefit of an immediate family member or
any third party. In cases when such transactions may be performed, prior written approval
by the CEO or the Deputy CEO must be obtained and the Bank’s Compliance Division
must be also informed in writing.

The members of the Supervisory Board, the executives (e.g. General Managers, Deputy
General Managers, Assistant General Managers etc) as well as any member of Staff
which have access to or/and receive information with regards to the financial results, are
prohibited from buying or selling the listed shares of any derivative products thereof, for
the period starting 15 days before the date of reference of the quarterly financial results
till the date of announcement of such results, except in cases where they have received
prior written approval by the CEO or the CFO and their immediate supervisor.

In addition to the prohibition related to the quarterly financial results, a corresponding

prohibition applies to the people that have access to the annual budget of the Bank the
period of prohibition being decided by the Finance Division.

8. STAFF TRANSACTIONS

It is recommended that all transactions orders are processed through the Bank. The Staff
must refrain from executing transactions in securities with a frequency such that may
impede the effective performance of their duties during working hours.

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Staff shall report in writing to the Bank’s Compliance Division the performance of
transactions in any type of shares (domestic or/and international), listed or not listed in a
regulated market, within 5 days from their execution and only if such transactions exceed
€5,000 in total transaction value during a one day period. As far as debt obligations of
domestic or international issuers are concerned (e.g. corporate bonds and notes,
government bonds etc), such transactions shall be reported only for buy/sell transactions
with total value greater or equal to €15,000 in total during the trading day.

Staff is not required to report to the Bank’s Compliance Division the cases where
transactions are performed, as good practice requires, through the Bank. In case such
transactions are performed through another Bank or Securities Company, the staff
member will make the announcement by filling in and sending to the Bank’s Compliance
Division the relevant form (Appendix 4).

Staff is encouraged to perform transactions in securities for standard

investment/transactional purposes while it is discouraged to perform any type of
transactions with the purpose of achieving short-term gains or/and even speculation. To
that effect, it is required that purchased financial instruments, which are traded in an
organized market or MTF, remain in the possession of the staff member at least for a 48-
hour period. This restriction applies also to transactions performed in the OTC Markets.
Bonds must remain in the possession of the Staff member for a period of at least three
months from the date of the transaction. The constraint regarding short-term gains also
includes foreign exchange transactions (for speculative purposes) and particularly when
linked to other investment products.

Moreover, it is recommended that continuous and repetitive intra-day transactions in

financial instruments are avoided, particularly short selling. In addition, transactions in
financial instruments with leverage are discouraged, except in cases where such
transactions are performed in the context of hedging long-term investment positions.

In general, acceptable Staff investment practice includes transactions which have a long-
term investment horizon or at least a medium term one (taking into account the market
conditions at the time). Staff investments must be consistent with the financial knowledge
of each Staff member and his/her financial position.

The Bank reserves the right to prohibit the performance of transactions on

margin/collateral by the members of Staff, in cases where the particular member of Staff
appears to be over-lended or in cases where it is obvious that such service is performed
for speculative purposes (taking advantage of market conditions or of conditions relating
to the particular traded instruments). The use of such service is recommended for
medium/long-term investment transactions. Moreover, in no instance shall a margin
account be used for intra-day transaction purposes.

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Staff must not perform any transactions in the name of the Bank, unless such transaction
is performed in the context of the staff’s duties or is based on the relevant authorization
given to them to perform the particular transactions.

9. SPECIAL STAFF RATES

The favourable terms that the Bank may offer to Staff for certain types of transactions
and accounts must not be abused.

For example, these special terms and accounts should not be used for the benefit of third
parties who are not entitled to them (e.g. related to the business activities of a relative or
other person).

10. CLIENT PRIORITY

One of the fundamental principles of the Bank is that it adopts procedures and policies
which secure before anything the interests of clients.

Staff is obliged to refrain from participating in any sale, loan or donation of assets or
services of the Bank either as a recipient of the asset/service or as an authorized person
for the execution of the transaction, with terms that are not available either to third parties
or to other members of Staff. The abovementioned actions are deemed acceptable only in
case of prior written approval by the CEO and Compliance Division.

Staff should avoid the copying of successful client trades for their own benefit or for the
benefit of any third party.

11. MONEY LAUNDERING

All laws and regulations on the detection and prevention of the legalisation of proceeds of
crime and terrorism financing (money laundering) must be fully adhered to. Staff should
not assist or collaborate with any client(s), or deliberately fail to report appropriately any
suspicious or unusual transactions which may involve legalisation of illegal proceeds and
financing of terrorism.

In addition, the Bank’s Compliance Division must be notified immediately either via
telephone or via the relevant system application (if any), of any reasonable grounds for
suspicion concerning a client or a transaction in relation to money laundering. The Bank
has issued in that respect relevant Rules and Procedures which are posted on the Bank’s
Intranet

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12. GAMBLING

Personal activities, which may lead to addictions and may as a result hinder the smooth
performance of the professional obligations of the members of Staff, must be avoided as
they are not considered acceptable and do not promote the principles of the Bank.

In particular, the systematic participation of Staff in gambling activities with the purpose
of obtaining a monetary benefit is prohibited and constitutes an offence subject to
administrative sanctions.

13. EXTERNAL EMPLOYMENT – BUSINESS ACTIVITY

The employee, for the duration of his employment by the Bank will not acquire interests,
nor take on obligations, nor engage in any relationship whether directly or indirectly,
whether for his/her own account or for the account of another natural or legal person, and
whether on a remunerated or a non-remunerated basis, in any business activity or venture,
without the prior written consent of the Bank.

The participation in any form, of the employee in companies that have a commercial or
other profit seeking activity or the parallel employment of any kind in companies that
have such an activity is also prohibited without the prior written approval by the Bank.
The participation of Bank employees in Boards of Directors/Supervisory Boards as well
as the acquisition of substantial financial or other interest in one of the suppliers, clients
or competitors is also prohibited without the prior written consent of the Bank.

For the granting of the relevant permissions, the decision rests:

a. For the executive members and the CEOs of the Bank with the Supervisory Board,
after the recommendation by the Bank’s Compliance Division.
b. For the employees, with the CEO, through the Bank’s Compliance Division, after
the written recommendation by the immediate supervisor has been obtained
(Appendix 5).

The obligation to obtain the abovementioned approvals does not apply to the employees’
immediate family members.

14. CHARITABLE & SOCIAL ACTIVITIES

As a general principle, the Bank encourages the participation of Staff in charitable and
social activities. However, these activities should not impact adversely on the Staff’s
regular business activity. Prior permission for such activities is not required.

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Similarly, no prior permission is required for the participation by a member of Staff in
politics, such as for example his/her participation in Local Authority Organizations or the
undertaking of specific duties in a political party; nevertheless, his/her immediate
supervisor must be informed as well as the Bank’s Compliance Division which checks, in
each case, whether the undertaking of such public position impedes on the performance
of the regular duties of the member of Staff and/or creates conflicts of interest.

15. GIFTS AND OTHER BENEFITS

Neither the Staff nor their family members may receive any gifts, discounts, benefits or
rewards, financial or of any other nature, from clients of the Bank and/or third parties, for
services rendered or to be rendered by them in their capacity as members of Staff of the
Bank directly or indirectly related to this capacity. Excluded are gifts for customary
and/or ceremonial reasons (e.g. beverages, books etc). The prohibition applies not only to
the actual acceptance of gifts or other benefits but also to any attempt of offer of gifts
(with the exception of the customary/ceremonial ones) or receivables or other rewards
(financial or material). Any attempted offerings (with the exception of the
customary/ceremonial ones) must be immediately reported to the head of the Unit, as
well as to the Bank’s Compliance Division.

More specifically, the members of Staff involved directly or indirectly in the execution of
transactions or in the reception/transmission of orders or the management of client assets
may not receive any additional rewards apart from the ones documented in the

Bank’s existing policies and procedures, as determined by the Human Resources Division
and that are linked to the regular performance of their duties.

16. CODE OF CONDUCT MONITORING

The Bank’s Compliance Division and the Audit functions of the Bank may monitor the
transactions of monetary and/or investment accounts, personal data available in the
electronic systems/applications, electronic mail system etc in the context of serving,
supporting and monitoring the present Code of Conduct, defending the Bank’s legitimate
interests and fulfilling of the relevant obligations arising from current legislation.

The persons performing such controls take the necessary organizational and technical
measures for the security of the data and its protection, in order to ensure a level of
security in accordance with the nature of the data being processed. Any provision of data
to legally authorized third parties (e.g. Public Prosecutors, National Bank of Ukraine, Tax
Authorities, and Capital Markets Commission etc) will be performed through means
offering a high level of security.

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17. DEFINITIONS AND EXAMPLES

Securities:
a) shares and titles equivalent to company shares, debt obligations and fixed income
obligation in general whether domestic or international (government and/or
corporate),
b) options, futures, swaps, forward rate agreements and all derivative contracts related to
securities or commodities, currencies, interest rates or other derivative products,
financial indices or other credit derivative products,
c) agreements or subscription rights or rights to buy or sell shares or bonds,
d) every other security offering the right to buy or sell transferable securities or that can
be cash settled in reference to securities, currencies, interest rates or returns,
commodities of other indices or underlyings,
e) every other asset defined as security by decision of the relevant Regulatory
Authorities.

Transactions in securities do not include transactions in products managed by

undertakings of collective investments (e.g. mutual funds) as well as money market
products (with maturity up to 12 months such as treasury bills, certificates of deposits
etc).

Immediate family member:

a) the spouse or a person with whom a cohabitation agreement has been concluded or
with whom he/she is simply cohabiting without marriage,
b) the dependent children,
c) all other relatives, who, on the date of the relevant transaction on his/her own
account, were living together with him/her under the same roof.

Persons holding inside/privileged information:

a) the persons/members of Staff that are members of the Supervisory Board,
Executives, Administrators of securities including the Managers of UCITS
(Undertakings for Collective Investment in Transferable Securities), Security
analysts, Market Makers and control functions of the Bank,
b) members of Staff that are informed on corporate actions of issuers of securities,
c) every member of the Bank Staff who, in the context of performing his/her
duties/tasks, receives privileged information regarding securities or the issuers
thereof.

Unit: the branch, the business banking centre, the private banking centre as well as all
other division of the Bank not included in the ones previously mentioned.

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Conflict of Interest: the situation that could arise in any area of activity of the Bank
and/or its subsidiaries which may benefit the interests of the Bank and/or its subsidiary
but at the same time prove to be harmful to the interests of a client of the Bank or its
subsidiary. A conflict of interest situation could also be identified in cases when the Bank
or its subsidiary acting for the benefit of one client’s interest is concurrently causing
material damage to the interest of another client.

Conflict of interest may arise either due to external employment or due to personal
activity whose actions or interests impede (or appear to impede) on the obligations of a
member of Staff to perform the duties he has undertaken in relation to the Bank
objectively and efficiently.

M.T.F.: Multilateral Trading Facility

Banking secrecy: Prohibition of the disclosure of information on the activity and

financial state of clients, which became known to the Bank and its employees in the
process of customer servicing and mutual relations with the client or with third parties
while providing the Bank’s services and disclosure of which can inflict financial or moral
harm to the client. Information about the clients of other banks, which became known to
the Bank from documents, agreements and operations of other clients of the bank, also
fall under banking secrecy.

Commercial secrecy: Prohibition of the disclosure of information on the Bank; this

includes information related to the technology of the Bank’s execution of transactions, to
the financeing mechanisms, and other activities of the Bank, the disclosure, outflow or
transmission of which can inflict harm to its interests, and reduce the competitiveness
level of the Bank’s services.

18. Amendments Table

Version Date Change Description
1.0 19.03.2009 First Version
2.0 05.04.2012 Second Version
3.0 31.10.2013 Third Version

19. Table of Controls and Approvals

Organizational Unit Name / Signature of Date

Authorized Personnel
Owner Compliance Division О. Alekseeva 31.10.2013

Approved HR Department O.Logvina 31.10.2013

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19.APPENDIXES
APPENDIX 1:

Declaration confirming acceptance of the terms of the Code of Conduct

_____, _______________20__,
(date, month, year)
___________________________
___________________________
___________________________
___________________________
(surname, name, patronymic name,
position)

To: Head of Human Resources Department

DECLARATION

I confirm that I have read the bank’s Code of Conduct regarding Banking Secrecy,
Staff transactions, Staff Conflict of Interest, etc. and I understand and accept its
contents.

__________________________

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APPENDIX 2
Date: ___.___.20__

To: Human Resources and Compliance Divisions

NOTIFICATION OF THE LOANS GRANTED FROM OTHER BANKS

NAME AND SURNAME: ________________________________________

CIF: ________________________
Division/Unit/Branch: ___________________________________

Notification

I hereby notify you that I have the following loans with other banks:

Bank: Starting Starting Current Current Purpose of Collateral

size of date of debt rates the loan
loan loan

APPLICANT

_________________
(Name and Signature)

_________________
(Date)

The Code of Conduct of “Public J.S.C.Universal Bank” 16 /22

 Document Categorization: For Internal Use Only

Code of Conduct “Universal Bank” regarding banking secrecy, staff transactions, staff conflict
of interest etc.

APPENDIX 3

Date: ___.___.20__

To: Compliance Division

APPLICATION FOR APPROVAL

FOR AUTHORITY TO MANAGE AN ACCOUNT OF A THIRD PERSON

NAME AND SURNAME: ________________________________________

CIF: ________________________
Division/Unit/Branch/Company: ___________________________________
Account Number/Portfolio Account Number: ________________________

I hereby request permission to:

 obtain the authority to manage the account/portfolio of 

 give the authority to manage my account/portfolio to 
the following non relative:

Name: __________________________________________________________
Account Number: ___________________________________________________
Reason:

APPLICANT

..............................................
(Name and Signature)

The Code of Conduct of “Public J.S.C.Universal Bank” 17 /22

 Document Categorization: For Internal Use Only

Code of Conduct “Universal Bank” regarding banking secrecy, staff transactions, staff conflict
of interest etc.
SUPERVISOR’S RECOMMENDATION

.............................................. …………………………
(Name and Signature) (Date)

Staff members shall fill in and sign the request and submit it accordingly:
 Members of the Supervisory Board, Executives, consultants employed by the Bank to the
CEO (through the Head of the Compliance Division).
 Centralised Departments staff, to the Head of the relevant Business Sector or Unit or
Department, where they are employed.
 Employees of branches and business centres to their Manager.

The supervisor, after inserting his/her written recommendation, forwards the application to
the Bank’s Compliance Division, which is responsible for notifying the applicant about the
decision taken.

The Code of Conduct of “Public J.S.C.Universal Bank” 18 /22

 Document Categorization: For Internal Use Only

Code of Conduct “Universal Bank” regarding banking secrecy, staff transactions, staff conflict
of interest etc.
APPENDIX 4
Date: ___.___.20__

To: Compliance Division

NOTIFICATION OF TRANSACTIONS IN FINANCIAL INSTRUMENTS

NAME AND SURNAME: ________________________________________

CIF: ________________________
Division/Unit/Branch/Company: ___________________________________

Notification of Purchase or Sale

I hereby notify you that on ______________ and with value date ____________ I executed
the following:

PURCHASE SALE

Total Purchase/Sale Price: €________________

through:

Securities Firm: Bank:

of the following securities:

No. Description of Securities Name of Issuer

Number of Units Unit Price
(Share, Bond, etc.)

APPLICANT

_________________

The Code of Conduct of “Public J.S.C.Universal Bank” 19 /22

 Document Categorization: For Internal Use Only

Code of Conduct “Universal Bank” regarding banking secrecy, staff transactions, staff conflict
of interest etc.
(Name and Signature)

SUPERVISOR’S RECOMMENDATION/РЕКОМЕНДАЦІЯ КЕРІВНИКА

……………………….. ………………………..
(Name and Signature) (Date)
HR Division Recommendation

……………………….. ………………………..
(Name and Signature) (Date)
Compliance Division Recommendation

……………………….. ………………………..
((Name and Signature) (Date)
Chairman of the Management Board

……………………….. ………………………..
(Name and Signature) (Date)

_________________
(Date)

The Code of Conduct of “Public J.S.C.Universal Bank” 20 /22

 Document Categorization: For Internal Use Only

Code of Conduct “Universal Bank” regarding banking secrecy, staff transactions, staff
conflict of interest etc.
APPENDIX 5

Date: ___.___.20__

To: Compliance Division

APPLICATION FOR PERMISSION

FOR EXTERNAL EMPLOYMENT / BUSINESS ACTIVITIES

NAME AND SURNAME: ________________________________________

CIF: ________________________
Division/Unit/Branch/Company: ___________________________________

I hereby request permission to:

..………….………………………………………………………………………………
…………………………………………………………………………………………
……………………………………………………………………………………..……
Reason:

APPLICANT

...........................................
(Name and Signature)

SUPERVISOR’S RECOMMENDATION

……………………….. ………………………..
(Name and Signature) (Date)
Compliance Division
……………………….. ………………………..

The Code of Conduct of “Public J.S.C.Universal Bank” 21 /22

 Document Categorization: For Internal Use Only

Code of Conduct “Universal Bank” regarding banking secrecy, staff transactions, staff
conflict of interest etc.
(Name and Signature) (Date)
The application when filled in shall be submitted to the immediate supervisor of the member of Staff, who
after completing his/her recommendation, shall forward it to the Bank’s Compliance Division which will
inform the employee of the decision taken. The Compliance Division will also communicate the decision to
the employee’s immediate supervisor as well as the Human Resources Division.

The Code of Conduct of “Public J.S.C.Universal Bank” 22 /22