I. OPENING PROVISIONS
Code of Conduct of LIDER MKF. (hereinafter referred to as Code of Conduct) regulates fundamental principles and rules of good conduct of Foundation employees in their interpersonal relations, relations with clients, partners, citizens, work and working environment, as well as the rules and procedures for the establishment of Code violation by the Foundation employee, based on the complaints submitted by other employees, clients, partners, and other citizens.
II. FUNDAMENTAL PRINCIPLES
Fundamental principles of business conduct are based on the following ethical values:
- legitimacy of work and business
- prohibition of discrimination and preferential treatment
- professional conduct
- conscientiousness and responsibility
- mutual respect
- decency and patience.
All employees of the Foundation are obliged to respect the established values of the Foundation, without reserve or exception. Each action taken should be aligned with the mission and vision of the Foundation, when approaching «third parties», as well as in mutual communication.
MKF LIDER values are professionalism, transparency, fair relations, honesty, and trust.
Principle of legitimacy and legal security
Foundation employees are obliged to, in performing daily work and tasks, comply with relevant laws and other regulations of FB&H, Federal Banking Agency, and internal documents of Foundation.
In case of circumstances not regulated by this Code of Conduct and relevant Foundation documents, the employees should conduct consciously and following the highest standards of responsible conduct.
Principle of antidiscrimination and preferential treatment
During daily performance of entrusted tasks, Foundation employees should not, by any means, discriminate or privilege other persons on any grounds, especially based on origin, gender, social or financial status, employment, race, national and political affiliation, religious and sexual orientation or any other basis contrary to the Constitution of B&H and antidiscrimination Laws.
Principle of professionality
Foundation employees are expected to perform all their tasks responsibly, professionally, and ethically. Employees should follow the principles of impartiality, neutrality, rationality, correctness, dialogue, and tolerance.
Foundation employees are expected to strive upon achieving mutual goals and participate in the activities, aligned with their professional duties in LIDER MKF, not affecting the performance nor reputation of the Foundation.
Principle of equality and fairness
Each Foundation employee should conduct in accordance with the principle of equality and fairness, avoiding any sort of discrimination, maltreatment, disturbing, or exploitation.
Foundation employees must not misuse their authority and allow personal benefits and relations to cause situations that might affect the capability of objective judgment, as well as ethical and professional performance at work.
All Foundation employees should ensure equal conditions for performing professional duties, expressing intellectual abilities, and career development.
III. COOPERATION AND RELATIONS WITH OTHER EMPLOYEES OF THE FOUNDATION
Foundation employees should behave professionally, politely, and courteously, deal attentively with other employees, establishing honest, balanced, and fair relations in day-to-day work.
Managers (supervisors) at all levels are obliged to encourage employees to quality and efficient work, mutual appreciation, respect and cooperation, and appropriate relations with other employees.
Managers are obliged to monitor the performance of the employee on a regular basis, identify and streamline their potentials and abilities, as well as avoid possible incidents and conflicts.
Adequate communication is essential for the effective implementation of any business, particularly in relations with colleagues.
Employees are expected to communicate with others politely and professionally, in all circumstances of interpersonal relations and communication.
The service of all Foundation employees should be aligned with the highest ethical principles of business conduct, treating other employees accordingly, and respecting principles of business ethics and policy of Foundation.
IV. COOPERATION AND RELATIONSHIP OF FOUNDATION EMPLOYEES AND CLIENTS, BUSINESS PARTNERS, AND OTHER CITIZENS
Foundation employees should treat clients, business partners, and other citizens, professionally, fairly, and decently.
Foundation employees, while performing daily work, should apply expert knowledge in such a manner to assist clients, business partners, and citizens to exercise their rights, complying with the principle of legitimacy and the principle of protection of common interests.
At work and in public, Foundation employees need to keep a good reputation and encourage people’s trust in the Foundation business.
Foundation employees should avoid unprofessional behavior that might jeopardize Foundation interests or negatively affect the operation and business of the Foundation.
Any unacceptable behavior, harming the good image of the Foundation, is strictly forbidden. Unacceptable implies, but is not limited to:
- Primitive and any other form of inadequate behavior in dealing with clients, other third parties, representatives of state and other institutions;
- Business communication and representing the Foundation under the influence of alcohol
- Aggressive or any other form of inconvenient behavior in public, during the working hours, that could jeopardize the image of the Foundation
- Derogation or slandering of Foundation, its activities, or other employees, including public sharing of personal relations among Foundation employees
- Any other unacceptable behavior that might cause material or non-material damage, to the employees or persons tied to Foundation’s business activities.
While dealing with private matters, Foundation employees must not use official labels or authority related to employment in LIDER MKF.
Foundation employees must not request gifts, encourage presentation nor accept gifts, that could directly or indirectly influence their impartiality, performance, and compliance with professional rules and obligations, neither for themselves nor for another person. Accepting gifts and other material or non-material presents from other parties, currently in or may enter into the business relationship with the Foundation, particularly accepting gifts or other presents from active or potential clients and suppliers of goods and services (e.g. personal purchase of goods and services without paying or under the special payment conditions), is strictly forbidden, with the exception of promotional material, souvenirs and other items common in normal business communication,.
V. ATTITUDE TOWARDS WORK AND WORKING ENVIRONMENT
During working hours, each employee is obliged to attentively follow and actively participate in the working process, identify work-related problems and duly inform all colleagues and direct supervisor. They are expected to perform actively, achieve agreed targets, work in a team, as well as show initiative in problem-solving.
Foundation employees should strive to achieve excellent results in each task they take, in compliance with Laws, other regulations, and official documents of the Foundation.
Foundation employees are obliged to perform professionally, attentively, honestly, and responsibly towards other employees, clients, business partners, and employers.
Foundation employees are obliged to observe fundamental principles of timely and efficient performance, precise work, accountability for their acts and work results, and to comply with the supervisor’s performance-related instructions.
All employees, while carrying out daily activities, should be dressed in accordance with the situation, particularly when speaking in public on behalf of the Foundation, attending very important meetings, all the time keeping in mind the good business image of the Foundation and possible negative consequences that might result. All employees are obliged to comply with guidelines of dress code during the working hours, communicated by the HR department.
VI. FOUNDATION PROPERTY MANAGEMENT
Foundation employees are obliged to handle Foundation property in a good manner and in accordance with ethical principles.
During everyday work and operation, Foundation property must be rationally used to achieve optimum business results.
It is the duty of each employee to safeguard and protect the entrusted property of the Foundation, avoiding situations that could endanger the totality, integrity, and safety of the property.
Foundation employees are not authorized to use assets and property for personal gain or unsuitable purposes.
Employees having access to confidential data related to Foundation property should never use them for personal gain, third party benefit, or in consulting the third parties
V. CONFIDENTIALITY AND PRIVACY IN BUSINESS, AND CONFIDENTIALITY OF DATA
Foundation employees are obliged to ensure confidentiality, privacy, and protection of business data, work, and performance-related documents, all in accordance with official documents of the Foundation regulating this matter.
Data received for usage or insight at work, have to be used and disposed of by the employees in accordance with Foundation official records.
Data and information should not be used for personal gain or in such a manner that could influence the reputation, results, performance, and market position of the Foundation.
Business secret implies to all data, that if published without authorization, jeopardize business interests or good image of Foundation, in particular:
- Data related to plans, projections, or other decisions and documents, that if announced in public could obstruct implementation or enable other companies or persons to endanger business interests or the image of Foundation
- Data related to personal income or other material or non-material benefits of employees, Board of Directors, and Audit Committee
- Data related to conditions of contracts or deals with other companies or persons, particularly if related to special benefits that Foundation acquires from supplier, commercial banks, creditors, donors, etc.
- Data used for consultancy services for other foundations or persons, especially to those in the same sector, including trainings, courses, preparation of documents or contracts originated in or financed by the
Foundation, without prior approval given by the Foundation.
Besides data considered to be a business secret, it is strictly forbidden to share in public personal data of employees, members of the Board of Directors, and Audit Committee without their agreement (with the exception of data related to certain projects such as CV, education data or professional competences), that could cause a material or non-material loss for a person in question ( i.e.: financial status, health condition, family situation, address or phone number).
Unauthorized sharing of information/data in public implies:
- Publishing/announcing data of persons not employed by Foundation, Board of Directors and Audit Committee without agreement of Executive Director or authorized persons
- Publishing/announcing data in media without the agreement of the Executive Director or authorized person
- Sharing personal data of employees or members of Board of Directors and Audit Committee, to any person, including employees, without prior agreement of person in question, except in case of legal requirement for data sharing (i.e.: in case of inspections, upon request of state institutions, on donor or creditor request etc.)
VI. CONFLICT OF INTEREST
Foundation employees should not take part in financial or any other activity that might negatively affect performance, interests, reputation, and wellbeing of Foundation, as well as in all other activities involving conflict of personal and business interest.
In case of reasonable doubt in the existence of the aforementioned situation, Foundation employees should, for such engagement, request written approval from the management of the Foundation.
Employee should not, during and after the working hours, conclude any business from the Employer’s area of work without prior agreement (competition with Employer).
Utilization of equipment, information, and other Foundation assets is allowed in interest and for the wellbeing of the Foundation only.
VII. USAGE OF COMPUTERS (hardware and software), INTERNET AND ELECTRONIC MAIL
While using hardware, employees should comply with the following rules:
- only the employees of the IT department are in charge of maintenance, installation and removal of computer equipment. No removal of computer equipment is allowed without prior request or approval by the authorized employee of the IT department
- liquid, magnets, and inflammable substances used in such a way to cause damage to equipment and/or data, are not allowed to be kept close to the computer equipment.
While using software, employees should comply with the following rules:
- installation and distribution of illegal software is strictly forbidden and is considered to be illegal activity. Foundation employees are obliged to use software, exclusively in line with the license agreement conditions. Unless mentioned otherwise by the license agreement, copying of licensed software, except used for generation of user data and storing done by authorized employees of IT department, is considered to be a violation of software manufacturer copyright
- employees must not copy software, unless the software manufacturer explicitly allowed it. The single exception is generating copies to produce user data by the authorized employees of the IT department,
- each employee intentionally producing copies of licensed software without authorization, will be accountable for such activity in line with Staff Policy
- employees are not allowed to install private software on computers owned by Foundation, without prior approval and assistance of authorized employees of IT department.
- transfer of viruses or other malicious codes to Foundation computers via USB memory sticks, CD / DVD optical media, floppy discs, or any other media is strictly forbidden.
With the objective of increasing productivity, faster and more efficient operations, Foundation allows the employees access to the information and data available on the internet. Internet access is allowed for business purposes only.
In order to use the internet safely, Foundation employees are obliged to comply with the following rules:
- Communication through the internet is allowed for business purposes only and under the condition it does not affect the productivity
- Web browser usage is allowed for the collection of data from web sites
- Users are not allowed to access contents that could be offensive or disturbing for other users. Such as i.e. contents promoting, supporting, or praising racial, national, gender or any other intolerance or hate, contents encouraging or supporting violence, drug addiction and other illegal activities, salacious contents, and all those detracting or jeopardizing dignity of a person or a group
- Each internet communication should indicate the name of the employee involved
- In order to secure and protect network and server resources, Foundation employees may use social networks for the purpose of technical and professional development, as well as accessing business, technical and other information related to their employment in LIDER MKF.
- In addition, social networks may be used in communication with other institutions of public administration, as well as with business partners. Social networks should not be used for private and personal purposes during working hours, since they may slow down and complicate work and affect business performance.
Taking into consideration business ethics, protocol insecurity, incidents, misunderstanding, and information disclosure, electronic mail usage is considered to be a risky activity, and in line with that Foundation employees are obliged to observe the following rules:
- User account for business purposes is open for each employee
- Private messages are allowed in reasonable amount and under the condition they do not obstruct regular business operation
- Foundation employees must be aware of the fact that messages they write represent them, but also LIDER MKF.
- Foundation employees bear full responsibility for the content of all texts, audio and video files, or pictures being shared or sent by electronic mail,
- Official e-mail addresses must not be used for sending insulting, scornful, or sexual harassment messages. It is also strictly forbidden to send any explicit contents supporting and encouraging racial, national, gender or any other intolerance or hate, contents encouraging violence, drug addiction, and other illegal activities, salacious content, and all those detracting or jeopardizing dignity of a person or a group
- Sending chain messages, burdening the network resources, and distracting personnel during working hours, is strictly forbidden, sending, printing, or distributing any kind of data owned by the Foundation or any other confidential information to unauthorized persons is strictly forbidden, sending or forwarding messages with personal information of other employee or client without approval from the Foundation is strictly forbidden, while sending messages, electronic mail system users should pay particular attention to the correct entry of electronic mail address of the recipient, text message of each electronic mail should contain the name of the sender, private electronic mail accounts are not allowed to be used in official purposes unless specifically approved by the IT department
- alternative internet connections are not allowed without prior approval of the IT department and without proper firewall protection or other corresponding security equipment or software
- employees are obliged to, based on the written request of an authorized employee of the IT department, hand over all requested access codes for information owned by Foundation or Foundation information system, in case if not possible for an authorized employee to change codes and/or in case of data loss risk,
only authorized employees of the IT department are allowed to access the electronic mail inbox of Foundation employees without prior approval, for the purpose of generating the user data, information system integrity maintaining or upon request by the employee supervisor, when such request is justified for that specific situation.
When using electronic mail, all users are reminded to comply with the following standards of professional communication through e-mail:
- All emails with inquiry, should be answered within 24 hours deadline, or the email sender informed about other reasonable deadlines.
- All emails containing business information are kept where appropriate. Deleting emails with useful information cause additional work for the others.
- When sending internal inquiries/requests, emails should be copied to the direct supervisor, as well as the direct supervisor of the email recipient. For example: A loan officer sending an inquiry to Finance Officer, should copy the email (CC) to his/her Branch manager, as well as the Manager of finance and accounting.
- The main goal of this is to ensure an effective and efficient communication chain among employees.
- During absence (sick leave, vacation, etc.), all employees using official email, are obliged to, in cooperation with IT department, generate automatic message on his/her email account informing email senders of their absence (out of office reply).
VIII. REPORTING PROCEDURE FOR CODE OF CONDUCT VIOLATION
HR department personnel is responsible for the implementation and monitoring of this Code of Conduct.
Responsibility of HR department is (but not limited) to:
- follow-up the implementation of the Code of conduct
- promote ethical behavior in interpersonal relations among employees, employees and clients, business partners, and other citizens
- advise employees on ethical conduct
- receive complaints of employees, clients, suppliers, citizens, and others, related to improper conduct of Foundation employees.
- carry out the inquiry procedure to establish the complaint groundedness,
- keep recors of complaints received,
- report, to the Foundation management, once a year or more often if necessary, on the implementation of the Code of conduct and status of complaints filed.
Complaints on possible violation and inobservance of this Code of Conduct may be reported in:
– writing, mailing, via LIDER MKF WEB site, or via email
– person, in verbal form along with signing the statement compiled by authorized personnel of the HR department.
Complaints could be filed anonimously, but it has to be documented in accordance with provisions of this Code.
Complaint has to be understandable and must contain necessary elements for appropriate reaction. Complain should contain data on the relevant employee, facts, and evidence supporting these facts.
In case if the complaint is not understandable or contains insufficient data to conduct the procedure, it will not be taken into consideration. HR department will inform the Foundation management about this complaint, which will make a final decision on complaint rejection.
Procedure for complaint grounds inquiry
HR staff is obliged to, within a reasonable deadline, at latest in 15 (fifteen) days from the day of receipt of complaint or full documentation, conduct the procedure of complaint grounds inquiry and submit written report to the Foundation management.
During the mentioned inquiry, HR staff independently analize the evidence, acquire complainant written statements, statements of competent organizational units, and undertake other actions required in the facts establishing process.
Reporting to Foundation management, mentioned in the paragraph 1. of this article contains the following:
– names of employees or other persons who filed the complaint
– statement of person being the subject of the complaint
– opinion of the authorized person from HR department about the complaint, with regards to possible elements of violation of Code of conduct
– HR department’s recommendation of appropriate measures.
During the inquiry procedure, the HR department is obliged to guaranty full confidentiality of procedure and privacy protection of each person involved, as well as full integrity and protection from any kind of maltreatment.
Protection mentioned in the previous paragraph will be exceptionally excluded if the person filing a complaint, intentionally and consciously reveals and reports truthless facts.
All LIDER MKF employees are obliged to cooperate with HR staff, respond to their requests and provide all data relevant for facts finding.
Disabling the HR department in conducting inquiry procedures to establish the grounds of complaint is considered to be a breach of employment obligations.
Management decisions related to complaints on violations of Code of Conduct
Foundation management is obliged to, within the 8 days from the day of submission of the HR department report, review the report and start the procedure as defined by Law or Fondation Staff Policy, and inform the HR department of the decision.
Foundation management may:
- decide to reject the complaint for the reasons mentioned in the Article 27. paragraph 3. and 4. of this Code
- decide to reject the complaint as groundless.
In case if the violence of the Code of Conduct by the employee is proven, Foundation management will proceed in accordance with guidelines with regards to disciplinary measures.
Disciplinary measures related to Code of Conduct may include the following:
1. Verbal or written warning,
2. Termination of existing Employment Contract and offering amended Employment Contract
3. Regular or abrupt termination of Employment Contract
In case of decisions number 2. and 3. from the previous paragraph prior to a decision on termination of employment, the authorized organizational unit of the Foundation will conduct the procedure provided by the Law and Foundation Staff Policy.
A person filing a complaint, unless anonymus, will be informed about facts finding, and measures undertaken with regards to a submitted complaint by the HR department within the appropriate deadline (not longer than 30 days from the day of finalizing the fact and information finding proces).
If the complaint submitted refers to improper conduct of HR staff, Foundation management will upon receipt of such complaint, appoint another person to process this complaint on behalf of the Foundation.
IX. FINAL PROVISIONS
This Code of Conduct will be published on the MKF LIDER internet site and forwarded to all Foundation employees by email, who will by signing confirm their support to this Code of Conduct.
This Code of Conduct enters into force and application on the date of issue.