AIB CODE

OF CONDUCT
Living Our Values

AIB Group p.lc.

 MESSAGE FROM OUR CEO 3
OVERVIEW & RESPONSIBILITIES 4
OUR VALUES 5
CONDUCT STANDARDS 6
SECTION 1a. CONDUCT STANDARDS 7
SECTION 1b. CONSUMER DUTY: APPLICABLE TO STAFF WHO 8

CONTENTS SERVICE UK CUSTOMERS

SECTION 1b. ADDITIONAL CONDUCT STANDARDS
SECTION 2. DOING THE RIGHT THING FOR OUR CUSTOMERS
SECTION 3. DOING THE RIGHT THING IN THE BUSINESS
9
10
11
SECTION 4. DOING THE RIGHT THING AS EMPLOYEES 13
SECTION 5. REASONABLE STEPS 15
SECTION 5. OUR DECISIONS – A GUIDING FRAMEWORK 16
PROMOTING SUSTAINABILITY & SUPPORTING OUR 17
COMMUNITIES
SPEAKING UP 18
GRIEVANCES & BREACHES OF OUR CODE 19
GOVERNANCE 20
RELATED READING 21
MESSAGE
FROM OUR CEO
Dear Colleagues,

Our Code of Conduct (“Our Code”) supports our Values and Every employee, regardless of location or role within the
helps us to deliver on our Purpose. It does this by setting Group, has an obligation to read our Code, understand it, and
out clear expectations for how we behave and how we do follow it every day. We should feel confident about our high
business. The Code guides our behaviours and emphasises ethical standards, our honesty, and our integrity. That
our commitment to acting ethically, honestly and with responsibility sits with each and every one of us. Our Code of
integrity while demonstrating trustworthiness. It asks us,
Conduct is a living document. The way that we behave and
individually and collectively, to do the right thing. By
following Our Code, we will deliver for our customers and conduct our business every day is how we bring it to life.
other stakeholders on a sustained basis.
We all have an obligation to comply with both the spirit and
letter of our Code and to help, support and trust others to do
the same. The Code cannot capture every possible situation
and it falls to us to exercise good judgement and to seek
guidance and support when needed. We all contribute to the
COLIN HUNT
Group’s culture and have a role to play to ensure our
AIB Chief Executive Officer
reputation is strengthened and not harmed by our conduct.
We have a responsibility to escalate concerns regarding
breaches of our Code or suspected or actual wrongdoing
initially through your People Leader or if you are not
comfortable raising it with your People Leader, through our
Speak Up processes. Speak Up is a core supporting pillar of
our Code. I can assure you all such cases will be taken
seriously, treated confidentially and investigated with the
utmost professionalism. Also, please remember that no one “Our Code of Conduct is a
in AIB has any authority to direct you to do something living document. The way that
unethical or illegal. we behave and conduct our
business every day is how we
bring it to life.”

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OVERVIEW RESPONSIBILITIES
PURPOSE PERSONAL RESPONSIBILITIES
Our Code of Conduct (‘Our Code’) is based on our Values that help us deliver Each of us has a personal responsibility to:
on our Purpose and meet our legal and regulatory obligations. Our Code • Understand and comply with Our Code and the policies and
sets out how we are expected to behave in a manner that is consistent with procedures that apply to our own role.
our Values and asks us, individually and collectively, to Do the Right Thing. It • Be accountable for our decisions and outcomes and hold others
is not meant to provide specific guidance on every situation. Our Code is our accountable.
overarching framework that informs our behaviours and decision making • Comply with relevant laws and regulations.
and encourages us to Speak Up when we see wrongdoing. Each of us has a • Consider AIB’s reputation, and any potential risks to our reputation, in our
responsibility to champion the behaviours outlined in our Code. We rely on daily conduct and approach to decision-making
each other to consistently apply the expected conduct standards and we • Seek help, guidance and advice when needed.
support and trust each other in Doing the Right Thing. • Escalate or report unacceptable conduct or suspected or actual
wrongdoing to your People Leader or through other appropriate channels
SCOPE – see the Speaking Up section of the Code. Each of us has a responsibility
Our Code, applies to all employees who are directly employed by Allied Irish to escalate concerns or issues and to do so honestly, fairly and
Banks p.l.c. (AIB), as well as agency staff, contractors, and Board members. professionally.
This includes, for example, AIB Group (UK) plc, EBS d.a.c. (incl. Haven) and • Complete relevant COMET and mandatory training in a timely manner
AIB Mortgage Bank. AIB Life Co., Payzone. and Goodbody Stockbrokers and complete the declaration of compliance with our Code as part of the
have their own Codes of Conduct which are aligned to the standards annual ASPIRE performance management process.
required in the AIB Code. All firms providing outsourced services to the • Be aware if your role is impacted by ROI Individual Accountability
Bank, must also agree to comply with this Code, or have an equally suitable Framework, Fitness & Probity Regime or UK Senior Managers and
proprietary Code, aligned to the required standard. Certification Regime, which Conduct Standards apply and the reasonable
steps you need to take.
In addition to our five Conduct Standards, all staff who service UK
customers must also adhere to the Consumer Duty-higher standard of care
that was introduced by the Financial Conduct Authority (FCA) in July 2023. PEOPLE LEADER RESPONSIBILITIES
Details of this Conduct Standard are outlined on page 8 of this document. People Leaders have additional responsibilities to support and embed the application
Additionally, for those staff impacted by the Consumer Duty regulations, all BREACHES OF THE CODE of our Code throughout the bank including:
references to ‘fair’ outcomes within this policy should be taken as ‘good’ Failure to comply with Our Code is taken seriously and
• Regularly communicating with your teams on the importance of
outcomes. investigated thoroughly. Findings of any wrongdoing or non-
understanding and complying with Our Code’s requirements.
compliance may lead to disciplinary action up to and including
• Acting as role models for and demonstrating commitment to our Code.
Our Additional Conduct Standards, apply to all ROI Pre-Approval Controlled role removal, dismissal, or in case of contract staff or suppliers,
• Encouraging staff to Speak Up and raise concerns about wrongdoing and
Function (PCF) role holders and those who may exercise a significant cancellation of contract.
supporting staff who raise genuine issues or concerns.
influence on the conduct of AIB’s affairs (i.e., CF1 role holders) and Senior • Ensuring concerns are resolved in a timely and fair manner and, if
Management Functions (SMFs). In addition, staff in scope of the ROI Individual Accountability
appropriate, are promptly escalated through appropriate channels.
Framework / Fitness & Probity Regime or UK Senior Managers
RAISING CONCERNS • Understand how the ROI Individual Accountability Framework / Fitness &
. and Certification Regime, who fail to comply with the applicable
Probity Regime or UK Seniors Managers and Certification Regime impacts
If you have a concern about wrongdoing in AIB, including a breach of Conduct Standards will also be assessed as to whether they are
your role and those in your area, ensuring awareness of their obligations.
our Code, you should report your concerns to your People Leader or to fit and proper to carry out their assigned role.
another appropriate person as set out in the Speak Up Policy.

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OUR VALUES
Our Values are how we will deliver on our purpose of Empowering People to Build a
Sustainable Future. They are the behaviours we will live; with each other and with our
customers. It takes investment of time and effort, and significant ongoing focus to
understand, embed and preserve a strong organisational culture. Our Values are at the
heart of our Conduct Standards and should be at the forefront of our mind when
carrying out our day-to-day roles.

Be One Team Own the Outcome Put Customers First

• Create Connections • Seek Excellence • Deliver Solutions

• Universally Include • Take Accountability • Share Insights

Drive Progress Show Respect Eliminate Complexity

At AIB our ambition is to build a culture where colleagues are:
• Deliver Sustainability • Empower Others • Actively Simplify

• Embrace Innovation • Speak Up • Be Decisive

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 SECTION
SECTION1 4

CONDUCT STANDARDS
Trust is the foundation of our business and is fundamental to maintaining the confidence of our
customers, regulators and other stakeholders.

We must demonstrate and evidence our trustworthiness through our Culture, Values
and Behaviours. Our Code sets out the expected conduct standards and behaviours
under three pillars. When we follow these principles we demonstrate trustworthiness:
• Doing the Right Thing for our Customers
• Doing the Right Thing in Business
• Doing the Right Thing as Employees

Our five* Conduct Standards also reflect the expectations of our regulators in the
jurisdictions in which we operate. They aim to provide a sense of shared values within our
organisation and empower staff to question and challenge how AIB goes about its
business. These conduct standards apply to ALL staff.

Further standards (known as Additional Conduct Standards) apply to certain senior

designated roles under the regulatory regimes. These are Pre-Approval Controlled
Functions (PCF) and Controlled Function 1s (CF1) in ROI and Senior Management
Functions (SMF) in the UK.

*Under the UK’s Financial Conduct Authority Regulation there is an additional standard applicable to UK staff and those who service UK Customers only. Details of this are available on page 8

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 SECTION 1a
The following table outlines the Conduct Standards applicable to ALL STAFF, together with AIB and the
regulator’s expectations and outlines how we should comply with each of the standards. Staff in Pre-
CONDUCT STANDARDS Approval Controlled Function roles (PCF), Controlled Function (CF) roles, Senior Management Functions
(SMF) and UK Certified Roles have an obligation to take steps to ensure that they can meet the Conduct
Standards, explained in more detail below (Reasonable Steps).

1 2 3 4 5
BE OPEN & COOPERATIVE ACT IN THE BEST
CONDUCT ACT WITH HONESTY & ACT WITH DUE SKILL, CARE & OBSERVE PROPER STANDARDS
WITH THE CBI AND OTHER INTERESTS OF CUSTOMERS
STANDARDS INTERGRITY DILIGENCE OF MARKET CONDUCT
REGULATORS AND DEAL WITH AND TREAT THEM FAIRLY &
THEM IN GOOD FAITH PROFESSIONALLY

• We comply with all relevant laws, • We are competent and reliable in • We engage and proactively • We promote fair customer • We make ourselves aware of and
regulations, codes, standards and carrying out our duties in disclose information which the outcomes by always putting comply with the relevant market
group policies. compliance with our policies, regulator would reasonably their needs first in our advice code and stock exchange rules.
• We manage conflicts of interests procedures and controls. expect to receive. and in our decision-making.
• We comply with all relevant internal
in line with policy. • We accept responsibility for our • We maintain an open and • We consider our customers’ policies, controls and procedures to
• We only use AIB Group assets actions and never knowingly constructive dialogue with our needs and circumstances at all ensure our business is conducted in
including information technology mislead or provide false regulators and ensure all times when designing and line with these rules.
for legitimate business purposes. information to Customers. communications and responses offering our products and
• We are familiar with and stay up to
• We ensure that we have the to requests are timely and services, both digitally and in
• We always protect the date on the regulatory requirements
appropriate knowledge and skills accurate, attending meetings person.
confidentiality of information. and conduct risks associated with
to carry out our roles and aim to where required. • We provide customers with our roles.
AIB • We challenge things that do not improve our knowledge and skills
• We act with integrity in our information which is both
seem right and Speak Up if we continuously. • We act in a fair manner and do not
EXPECTATIONS suspect wrongdoing. engagement with the regulator accessible and transparent to
engage in any activity which may
• We ensure that we have and never knowingly provide support and enable them in
• We provide clear and accurate result in harm to AIB, our customers,
appropriate knowledge of the false or misleading information. making informed decisions.
information to Customers and other market participants or the
legal and regulatory framework in
never exert undue pressure or • We never destroy, hide or • We listen to and address financial system more broadly.
our jurisdiction.
influence on their decision- obscure information which our customer complaints quickly and
making process. • We use our knowledge base to regulator would reasonably fairly and escalate to Customer
make appropriate and well expect to receive. Care as appropriate ensuring the
• We promote open and honest thought-out decisions in line with customer is kept informed
communication, and honour our our policies and procedures. throughout.
commitments to our Customers,
Colleagues, the CBI and other • We provide sufficient clarity and
Regulators. oversight on delegated tasks.

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 SECTION 1b

CONSUMER DUTY: APPLICABLE TO The following table outlines the Consumer Duty’s Higher Standard of Care Conduct
STAFF WHO SERVICE UK CUSTOMERS Standard applicable to AIB UK STAFF AND THOSE WHO SERVICE UK CUSTOMERS,
together with AIB and the Financial Conduct Authority’s (FCA) expectations. It outlines how
6 we should comply with this standard. Staff in Senior Management Functions (SMF) ) and
UK Certified Roles also have an obligation to take steps to ensure that they can meet the
Conduct ACT TO DELIVER GOOD OUTCOMES FOR
Standard
Conduct Standard, explained in more detail below (Reasonable Steps).
RETAIL CUSTOMERS

• We ensure customer interests are central to our

Consumer Duty Explained
culture and purpose .

• We take proactive steps to deliver good customer

outcomes and avoid foreseeable harm. The FCA Consumer Duty-higher standard of care is now introduced in the UK. The UK’s Financial
Conduct Authority (‘FCA’) implemented its most recent consumer protection regulation Consumer
• We assess the suitability of our products, following Duty (‘the Duty’) across the UK in July 2023. It is considered by the FCA to be a “paradigm shift” in
due consideration to the target market, to deliver
good outcomes for customers. raising the standard of care provided to retail customers. Under the Duty we have an obligation to
ensure that not only do we deliver good customer outcomes, but we evidence, assess, and monitor
• We complete ongoing monitoring to ensure our
products and services continue to deliver good
these outcomes throughout the product lifecycle.
Customer outcomes.

AIB The overarching consumer principle requires us to ‘act to deliver good outcomes for retail
• We offer products and services that meet our
customer needs , provide ongoing fair value and help customers’. This is underpinned by three cross-cutting rules , we act in good faith, we avoid causing
Expectations customers achieve their financial objectives. foreseeable harm and we enable and support retail customers to pursue their financial objectives. In
addition, there are four outcomes which set out more detailed expectations for our conduct in the
• We communicate and engage with customers so
they can make effective, timely following key areas; governance of products and services, price and value, consumer understanding,
and informed decisions. and consumer support. This Code supports and reflects this higher standard of care.
• We provide support (pre- and post-sale )to our
customers as and when they need it .

• We monitor and review the outcomes our customers

are experiencing and act promptly to take action.
Further guidance on how to deliver good outcomes for our Customers is available under the Doing the Right
• We have a responsibility to ensure that our business Thing For Customers section of this document and on the FCA Website.
strategies lead to good customer outcomes.

• We act to avoid foreseeable harm, removing any Note: For all UK colleagues and those who service UK Customers, all references to ‘fair’ outcomes within this policy should be taken as
unreasonable barrier for our customers.
‘good’ outcomes as part of the Consumer Duty regulations.

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 SECTION 1c

The following table outlines the Additional Conduct Standards applicable to ROI staff in Pre-Approval Controlled
ADDITIONAL CONDUCT Functions (PCFs) roles and Controlled Function 1s (CF1) and UK staff who are impacted by the Senior Managers
and Certification Regime, together with AIB and the regulators’ expectations for each of the standards.
STANDARDS Staff in PCF, CF1 and SMF roles have an obligation to take steps to ensure that they can meet the Additional
Conduct Standards, explained in more detail below (Reasonable Steps).

1 2 3 4
ADDITIONAL
CONDUCT BUSINESS IN ACCORDANCE DELEGATE TASKS APPROPRIATELY AND DISCLOSE INFORMATION PROMPTLY
CONDUCT CONTROL BUSINESS AREA EFFECTIVELY
WITH RULES AND REGULATIONS EFFECTIVELY AND APPROPRIATELY
STANDARDS

• We fully understand our business area and keep • We ensure our business area has up to date policies • We retain overall responsibility and • We act in an open and co-operative manner
ourselves informed of any developments (including and procedures to maintain operational accountability if we delegate tasks to with our regulators.
business and regulatory developments) which effectiveness of controls which include clear steps colleagues including colleagues operating in
impact it. for complying with relevant regulatory • We respond to any requests for information
different entities or branches. from our regulators in a timely fashion.
requirements.
• We actively participate in the collective decision-
• We ensure our colleagues are aware of the need to
• We exercise due and reasonable consideration • We promptly and appropriately disclose any
making process, provide rational challenge and
keep ourselves informed. comply with relevant regulatory requirements and when determining which colleague or information which our regulators would
have appropriate training to allow them to do so. colleagues we delegate tasks to. reasonably expect notice of regardless of
• We maintain effective frameworks, policies,
procedures and controls to identify and monitor • We proactively address any potential regulatory • We only delegate tasks to colleagues who have whether they have asked for it.
risks within our business area. breaches (by individuals, an AIB entity, or AIB Group sufficient knowledge, expertise, skills and • We maintain processes and controls to identify
as a whole), implement clear and comprehensive capacity to competently fulfil the task. potential issues within our area of responsibility
• We carefully consider any recommended system or
plans to investigate, and communicate to regulators
AIB control improvements.
as appropriate. • We give the delegate a clear understanding of and keep a record of all considerations taken in
• We ensure that policies and procedures are in what is expected of them and maintain respect of reporting those issues to our
EXPECTATIONS • We seek legal advice, as appropriate, if issues arise consistent oversight and distinct reporting regulators.
place to appropriately review the competence, in the course of our duties which raise questions of
knowledge, skills and performance of employees lines. • We promptly make enquiries about issues that
law or regulatory interpretation.
in our business area. • We ensure appropriate controls and systems come to our attention and ensure that relevant
• We ensure appropriate arrangements are in place
• We carefully review whether colleagues who to maintain compliance with regulatory are in place to mitigate any risks associated actions have been taken.
report to us should continue in their roles if their requirements when overseeing colleagues in with delegated tasks including appropriate
performance is deemed unsatisfactory, particularly temporary roles. systems to effectively escalate and address
in cases of potential non-adherence to applicable issues as necessary.
controls, rules and regulations. • We proactively and thoroughly remediate
regulatory breaches, assess any lessons learned,
• We ensure that reporting lines are clear and that and ensure necessary procedures are put in place
we communicate transparently. to prevent reoccurrence.
• We ensure efficient handover of roles and that we
engage in appropriate succession planning.

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 SECTION 2

DOING THE RIGHT THING FOR OUR CUSTOMERS

Our purpose is to empower people to build a sustainable future. We challenge ourselves to always make decisions based on the right thing to do for our
customers, always treating our customers fairly and with respect. We do so with competence, honesty and reliability.

We demonstrate and evidence our trustworthiness when we: We do this by taking the following actions:

• Listen to our customers to understand their needs, and take action • Acting with due skill, care and diligence. This requires us to perform our duties
to improve their journey with us. competently and reliably in compliance with policies, procedures and controls.

• Promote fair customer outcomes by always putting their needs first in our • Acting honestly, ethically and with integrity – core elements in generating
trustworthiness.
advice and in our decision making.
• Accepting responsibility for our actions, lack of action or errors.
• Design products and services that are suitable for our customers’ needs and
that align with our purpose of delivering sustainable outcomes. • Understanding our role, activities and responsibilities, and what reasonable steps
we may need to take in the course of our day-to-day role.
• Provide ongoing fair value and help our customers achieve their financial
WE ARE objectives. WE ARE • Holding ourselves and others accountable.
TRUSTWORTHY RESPONSIBLE
• Provide customers with information which is both accessible and • Continually improving our skills and knowledge to perform our job responsibilities.
transparent to support and enable them in making informed decisions.
• Applying prudent risk management in our decision making.
• Listen to and resolve customer complaints quickly and fairly, escalating to
Customer Care as appropriate. • Honouring our commitments to all our stakeholders.

• Encouraging open, honest communication, and seeking different perspectives and

• Provide professional advice to a customer only if we are appropriately
views to limit bias.
qualified and specifically authorised to do so on behalf of AIB.
• Acting with due consideration for sustainability and the long-term impacts of our
• Support and protect our customers in vulnerable circumstances or in decisions.
financial difficulty.
• Ensuring we educate ourselves and are diligent in recognising, supporting and
• Keep our communications simple, clear and transparent. communicating effectively with customers in vulnerable circumstances to ensure
they receive as fair an outcome as other customers.

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 SECTION 3

DOING THE RIGHT THING IN BUSINESS

We value sustainable long-term relationships. We manage our business and
deliver outcomes through responsible business practices and prudent risk
• We never engage in any form of bribery or corruption.
management. Our long-term sustained commitment and performance help build
trust with our clients, in each other, and in our communities. BRIBERY, • We are alert to any indications of fraud and other financial crime, and we
CORRUPTION & escalate and report them promptly.
FRAUD
We do this through:
• Each of us is responsible for recognising and addressing risk in a prudent
• We comply with both the spirit and letter of all relevant laws, regulations, manner. We apply appropriate diligence in assessing risks in our decision
codes and AIB policies. If there is anything inconsistent between laws and making.
RISK
regulations and our policies, we apply the highest obligation. If in doubt,
you should escalate to your People Leader. • If, under the Individual Accountability Framework / Fitness and Probity
RISK Regime, we hold a Pre Approval Controlled Function or Controlled Function
COMPLIANCE WITH MANAGEMENT
APPLICABLE LAWS • We believe in open and fair competition. We engage in practices that are 1 role, or are subject to the UK Senior Managers and Certification Regime
AND REGULATIONS legal and ethical. We do not engage in anti-competitive practices and we do we should ensure that the relevant systems, controls and procedures are in
not engage in or permit market manipulation. place to monitor and identify risks in the area that we are responsible for.

• We are always open, constructive and co-operative with our regulators and
we respond promptly and accurately to regulatory requests for information. • We are entrusted with information from many sources in the course of our
business and this carries significant obligations of confidentiality and
security.

• We respect and protect the privacy and confidentiality of information in all

• We are committed to preventing the use of our products or systems to CONFIDENTIAL
INFORMATION its forms of our customers, our employees, our suppliers, AIB Group and
launder
. criminal proceeds, to finance terrorism, to evade taxation, or to
ANTI-MONEY third parties with whom we do business.
bypass applicable sanctions laws.
LAUNDERING
• Our duty of confidentiality obligation continues if we leave the AIB Group.

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 SECTION 3

DOING THE RIGHT THING IN BUSINESS

• We only use AIB Group assets, including information technology and
systems, for legitimate business purposes. • We do not undertake formal or informal lobbying activities to public officials
on behalf of AIB unless specifically authorised to do so in accordance with
• We protect assets to which we have access to in accordance with our
the Lobbying Policy. Lobbying includes attempting to influence legislation
AIB ASSETS policies. LOBBYING or government decisions.
• We maintain high standards of physical, information and digital security.

• Our judgement and decision making should be free from conflicts of interest
or undue influence of others. We must be alert to potential conflicts of • We recognise our colleagues’ right to freedom of association1 and to
interest, actual or perceived between our personal interests and the FREEDOM OF participate constructively in dialogue with trade unions recognised by AIB.
interests of AIB including our customers, shareholders and suppliers. Where ASSOCIATION
we cannot avoid such conflicts, we follow procedures outlined in our
Conflicts of Interest Policy some relevant examples include:

• We do not misuse information or inappropriately disclose inside information

for our own benefit or for the benefit of others including sending • While we may involve ourselves in political issues and campaigns as our
information to our personal email account. consciences and beliefs dictate, we are careful in ensuring that it does not
CONFLICT OF PARTICIPATING involve the use of any AIB resources, is undertaken outside of working
INTERESTS IN THE POLITICAL
• We do not offer, solicit or accept gifts or entertainments which might hours, and we do not represent our views as those of AIB.
PROCESS
influence or be seen to influence our business judgement.

• We do not let outside business activities interfere with the interests of AIB,
our customers or our ability to carry out our duties and responsibilities to
the bank - always seek prior approval from your People Leader.
• We maintain accurate and complete records and accounts of our dealings
• We do not deal with, access or process any banking transaction either for RECORDS & with customers and suppliers.
ourselves or for a person with whom we have a personal relationship. ACCOUNTS

1 As per ILO Convention C087 - Freedom of Association and Protection of the Right to Organise Convention, 1948 (No. 87).

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 SECTION 4

DOING THE RIGHT THING AS EMPLOYEES

Our success depends on ourselves, whether as an employee or a contractor, and how we work together. This requires trust and we build trustworthiness through our
own accountability and delivering on our responsibilities, through collaboration with our colleagues and treating each other with courtesy, respect and fairness. We
foster open and effective working relationships both within our teams and across different business areas, based on the Value that we are One Team. We value
diversity as a strength and do not tolerate any form of discrimination or harassment.

We do this through:
• We treat each other courteously and with care, respect, dignity and fairness • We use good judgement in the use of social media and comply with all
at all times – as we would like to be treated, and we hold each other to applicable policies.
high standards of personal behaviour. • We do not comment on behalf of AIB unless we are authorised to do so
• We proactively collaborate with colleagues and share knowledge, ideas SOCIAL and we ensure that our use of social media does not interfere with our
VALUE MEDIA
COLLEAGUES and skills. Effective collaboration enables better outcomes. work.

• We all have responsibilities to ensure that we provide a safe and secure • We will create an inclusive working environment and seek to prevent any
workplace where we contribute, develop, challenge and express ourselves form of harassment or bullying. We report and act on any allegations of
in a professional and respectful manner. harassment or bullying in the workplace.
• We uphold high standards of physical health & safety in our workplaces.
• We do not tolerate any behaviour that creates an intimidating, offensive, • We value and embrace diversity and oppose all forms of discrimination
WORK INCLUSION &
ENVIRONMENT hostile or disrespectful workplace including but not limited to, offensive DIVERSITY (race, ethnicity, age, colour, gender, sexual orientation, disability, creed
conduct, derogatory jokes or comments or unwanted sexual advances. We or any other classifications protected under applicable laws). Diversity
should always consider how others might react or perceive our words or draws on different experiences and perspectives, reduces the risk of
actions. groupthink, adds value, and contributes to better outcomes.

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 SECTION 4

DOING THE RIGHT THING AS EMPLOYEES

• We take personal accountability for our actions and outcomes and hold others
accountable. We challenge in a professional and respectful manner and are
open to being challenged ourselves.
• We represent AIB only when authorised, and we do not talk about AIB, our
customers or our colleagues directly with the media or through any social media
channel, unless authorised to do so.
• We do not tolerate deliberate misconduct or breach of our Code or policies - in
ourselves or in others and we escalate or Speak Up on such issues honestly, fairly and
professionally. We also recognise our responsibility to report wrongdoing or
suspicions of wrongdoing, and we respond and act on these reports. We respect and
protect the person who reports their suspicion to us.
• Any breaches of our Code/behavioural issues, including non-completion of
mandatory training are recorded in our ASPIRE performance management
ACCOUNTABILITY process.
• We claim, record and approve expenses appropriately and in line with policy.
• We each conduct our personal financial and tax affairs responsibly so as not to bring
ourselves or AIB into disrepute.
• We recognise the necessity for process discipline in following our policies,
procedures, controls and governance pathways. We are committed to
addressing errors, flaws or breaches in a timely manner, failing which we
ensure that they are escalated and reported so that they can be fixed.
• Where we delegate activities, we do so appropriately, providing effective
oversight and adequate support to our colleagues.
• We participate appropriately and actively in the collective decision-making
process, ensuring sufficient level of preparation and attendance, access to
relevant information and exercising sound judgement.
• We ensure key decisions are documented appropriately.
• We understand our role and the relevant Conduct Standards that apply to us.

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 SECTION 5

REASONABLE STEPS
Under IAF and UK SM&CR, a person performing Pre-Approval Controlled Function role, Controlled Function role, ) UK Certified Roles and/or is a Senior Management
Function in the UK, has a regulatory requirement to take reasonable steps to ensure that the Conduct Standards are met. Reasonable steps are “any steps that it is
reasonable in the circumstances for the person to take”. These steps should be considered and acted upon consistently.

Examples of Reasonable Steps

Below are some examples of the reasonable steps you may take when adhering to the Conduct Standards.
For further details please consult the Reasonable Steps Framework available on the HR Hub.

Additional

Standards
Conduct
All Controlled Function and UK Certified role holders :
Reasonable Steps

PCFs and CF1s (ROI) • Understand your own role and responsibilities.
SMFs (UK) • Ensure you have the appropriate knowledge and skills to carry out your role.

Conduct Standards
• Put the Customers interests first and at the centre of your approach, ensuring you deliver fair customer
outcomes.
• Undertake appropriate training throughout the year.
• Ensure issues are raised through the appropriate escalation channels.
All Controlled
Functions (ROI) and UK • Knowledge of key risks that may impact their role and business area.
Certified Staff
Pre-Approved Controlled Function (PCF), Controlled Function 1 (CF1) role holders and UK Senior
Management Function (SMFs):
• Ensure you have appropriate controls and processes in place, across your area of responsibility
• Understand your role in relation to effective collective decision making.
• Steps you have taken to assess, monitor and review the adequacy and effectives of the governance,
All Other operational and risk management arrangements in place.
Employees
• Ensure delegation is to an appropriate delegate with the required capacity, competence, knowledge,
seniority and skill.
• Steps undertaken to establish clear reporting lines in your Business Area.
• Review and challenge the relevancy, accuracy and completeness of information available to you.

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 SECTION 5

OUR DECISIONS - A GUIDING FRAMEWORK

We are accountable for our decisions and their DOES IT CREATE VALUE FOR THE ARE WE DOING THE RIGHT THING?
outcomes. When faced with a challenging situation CUSTOMER, AIB & WIDER SOCIETY?
or decision, where we are uncertain of the Are we acting fairly and transparently?
What are the implications and who is Have we assessed all the options, risks and
appropriate course of action or where something impacted? impacts?
does not feel quite right, we should use the • Do we understand the risks? Have we sought different perspectives
questions in the framework to help guide us to to inform our decision? If time permits
• Are we balancing short and long-term
make better decisions. This is not a decision tree, implications?
this could be important particularly in a
remote working environment.
You are
and the questions are in no particular order. Some Have we sought help and guidance if responsible
of the questions may not apply or have less still unsure?
relevance to every decision we make. If in doubt, WOULD YOU FEEL COMFORTABLE for seeking
IF IT WAS MADE PUBLIC?
consult with your People Leader.
We are accountable for our decisions
IS THERE AN ACTUAL OR PERCEIVED advice and
and outcomes. CONFLICTS OF INTERESTS? guidance
Would we have a clear conscience in Are we avoiding any conflicts of
explaining the decision if it became interest? If we cannot, we must put when needed.
publicly available or if we had to steps in place to address them
IS IT IN THE CUSTOMER’S BEST INTEREST? transparently and in line with our
explain it to a family member, friend
or colleague?
Conflicts of Interest Policy. If in doubt,
Would the perception of our decision be
viewed as a fair outcome by our customers
Are we making this decision to fit in
or avoid conflict or are we being
consult with
or wider third parties?
Does it sustain long term relationships WOULD IT CAUSE HARM TO AIB’S
influenced based on the expectations
of our peers/People Leader?
your People
over short term gains? REPUTATION? Leader.
Are we acting with due skill, care and HAVE YOU TAKEN THE REASONABLE STEPS?
diligence and applying prudent risk For those of us impacted by the Fitness & Probity
management in our decision making? Regime in ROI (i.e., Pre-Approval Controlled
DOES IT COMPLY WITH RELEVANT LAWS,
Function and Controlled Function roles) or by the
REGULATIONS & OUR POLICIES? UK Senior Managers and Certification Regime
SUPPORTING INFORMATION (Senior Management Function), have we taken
Are we in compliance with both the spirit
and letter of the laws, regulations and • The IBCB have developed a complementary reasonable steps to avoid breach of the applicable
our policies including our Code of “DECIDE” framework to assist with ethical decision Conduct Standards from occurring or continuing?
making. Further info is available at • Have we referred to our Reasonable Steps
Conduct?
www.irishbankingcultureboard.ie Framework to seek help and guidance if still
unsure?

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 PROMOTING SUSTAINABILITY & SUPPORTING OUR COMMUNITIES
AIB’s purpose is empowering people to build a sustainable future, and sustainability is at the heart of
our Group strategy. We want to make a positive impact, creating long-term value in our business as well
as the economies and communities in which we live and work.

We do this through:
• Putting our customers first, always treating them fairly and with respect. HUMAN RIGHTS &
• Continuing to proactively contribute to a robust and sustainable future
economy and society
MODERN
• Lending responsibly and steering our portfolios towards net zero by 2040 SLAVERY
(Agriculture by 2050).
• Reaching net zero in own operations by 2030.
• Deploying our 2030 €30bn Climate Action Fund supporting our customers
in the transition to a low-carbon economy. AIB is committed to the protection and preservation of human rights. We published our Human Rights Commitment,
• Funding renewable energy and sustainable infrastructure projects. pledging to respect human rights in accordance with internationally accepted standards. We respect human rights in
accordance with internationally accepted standards; our Human Rights Commitment has been shaped by the UN
• Providing products and services to help make a positive environmental Guiding Principles on Business and Human Rights. Our commitment operates alongside our Code of Conduct and
impact. Responsible Supplier Code, and is aligned to the European Convention on Human Rights and the EU Charter of
Fundamental Rights. We actively avoid causing, financing or contributing to any business activity that is known to
• Ongoing education and support for our colleagues and wider customer breach human rights or fair practices, including taking steps to address any situations we become aware of where this
base to support the transition to a low carbon future. has occurred. Due diligence is undertaken so that the organisation has an adequate knowledge of its customers, thus
• Continuing to embed ESG capabilities and measures at the heart of our mitigating the risk of generating negative impacts on human rights caused by its products and/or services.
business. Our Responsible Supplier Code sets out our expectation that our suppliers must abide by all national and international
• Encouraging and supporting involvement in community, charitable and laws as applicable, including the International Bill of Human Rights and the International Labour Organisation
educational activities conventions. In line with our Responsible Supplier Code, we do not partner with or buy from organisations which we
know to breach human rights or fair practices. We report annually on our approaches to tackling modern slavery in our
Modern Slavery Statement. We ensure non-discrimination among our employees and customers due to gender, marital
status, family status, age disability, sexual orientation, race, religion; or on any other grounds where discrimination is
prohibited under local law.

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 SPEAKING UP

Every organisation faces the risk that something will go wrong either
accidentally or otherwise. It is very important that we hear about such
things, at an early stage, sowe can fix them.
Each of us has a direct responsibility to In certain roles namely, Pre-Approval
raise a concern if we believe something Controlled Functions (ROI) and Senior
may be wrong. Equally we have a Managers and Certification Regime (UK),
responsibility to listen and follow up on we may also have additional
such concerns. It’s really important that regulatory disclosure responsibilities.
we all can safely report these issues
without any adverse consequences, and We can also seek confidential advice
that we are confident that our concerns from our dedicated internal Speak Up
will be listened to and acted upon. team and/or Protect, an independent
external third party who provide
In the first instance we should feel free legal advice to AIB staff who wish
confident that we can raise issues to Speak Up.
confidentially with our People Leader or
with a more senior People Leader within We can read how to go about Speaking
our business area, without fear of Up, and what protection we will be
penalisation. But if we do not wish to provided, in our Speak Up Policy
report this way or believe that our report
of a concern is not being properly
investigated and actioned; then we
can raise our concern through the
confidential Speak up process.

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 GRIEVANCES BREACHES OF OUR CODE
If you feel that you have been personally mistreated or have been We will consider and investigate potential breaches. We take breaches seriously and any breaches may be
addressed under our disciplinary policy and procedures. This can include sanctions up to and including role removal,
subject to behaviours which you believe are contrary to our Code, you
or dismissal or the reduction or removal of renumeration. The Workforce Performance Team in HR provides advice
can raise your concerns either informally with your People Leader or and manages these processes and procedures.
more formally through AIB’s Grievance Policy.

Our Workforce Performance team are available at

workforce.performance@aib.ie if you have any queries on this.
• Breaches may be addressed under our disciplinary policy and
procedures and findings of any wrongdoing or non-compliance may
lead to disciplinary action up to and including dismissal, or in case of
contract staff or suppliers, cancellation of contract.
• Depending on the nature and severity of the breach AIB may also be
obligated to report this to the relevant regulator or law enforcement
authority.
• For Fitness & Probity and Senior Managers and Certification Regime
impacted staff, any disciplinary issue raised (including breaches of the
Code of Conduct), may also result in a Fitness & Probity Assessment i.e.,
to assess if the individual is fit and proper to continue in their Pre-
Approval Controlled Function and/or Controlled Function roles.

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16

GOVERNANCE

The Code is periodically reviewed by the AIB Group

Board and annually by the Group Conduct 1ST LINE OF 2ND LINE OF 3RD LINE OF ESCALATE
Committee and by the Board Audit Committee. An DEFENCE DEFENCE DEFENCE CONCERNS
annual report is provided to the AIB Group Board on
the awareness levels of the Code, aspects for review,
and any breaches which have been identified and PEOPLE LEADER EMAIL
RISK GROUP INTERNAL
action taken. WITH THE
FUNCTION AUDIT speakup@aib.ie
SUPPORT OF HR

The Three Lines of Defence Model is used to monitor and govern

compliance with the policies that underpin this Framework. Where Policy Implementation date: July 2012

there are concerns about suspected breaches of our Code or Last Review Date: July 2024
suspected wrongdoing, the Speak Up Channel can also be used to
Last Updated With Changes: July 2024
report concerns.
Policy is Reviewed: Annually or If changes required by legislation or the business.
All Code of Conduct breaches should be reported to your People
Leader or escalated to the Speak Up Team via speakup@aib.ie Next Review Date: 2025

Policy Owned by: Head of Group Accountability & Performance

ExCo Policy Sponsor: Chief People Officer

Approval Authority: Group Board Audit Committee

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 RELATED READING
Our Code of Conduct is a framework underpinned by a number of key
policies and processes across our Three Pillars. Further information on
some of these are provided below and the full suite can also be
accessed on the AIB Group intranet site.

The Code is also aligned to the Central Bank of Ireland’s Individual

Accountability Framework and the UK FCA’s Senior Managers and
Certification Regime.
Further information on this can be found on the Central Bank's Website
and the FCA Website.
Note: Some business segments have local policies and procedures
which support and expand on the relevant Group Policies, and
which should also be referred to as required. OUR OUR OUR
CUSTOMERS BUSINESS EMPLOYEES
› Regulatory Accountability Policy
› Conflicts of Interest › Regulatory Compliance
› Speak Up Policy
› Data Protection › Group Regulatory Compliance Risk Management Framework
› Anti-Bullying & Harassment Policy
› Anti-Bribery & Corruption › Group Conduct Risk Policy
(see section within the Financial Crime Policy) › Inclusion & Diversity Code
› Regulatory Compliance Risk Management Policy › Disciplinary Policy
› AIB Vulnerable Customer Guidelines
› Financial Crime Policy › Grievance Policy
› Reputational Risk Framework › Social Media Policy
› People, Property & Protection › Organisation of Working Time RoI

› Information Security › Recording of Working Time UK

› Annual Leave Policy
› Health & Safety Statement
› Sickness Absence Management Policy
› Conduct of Personal Financial Affairs
› Expenses Policy
› Group Dealing Code
› Aspire Performance Management
› Agile and Working From Home Policy
› Remuneration Policy

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