Compliance

Joint stock company “Raiffeisen Bank Aval”, as a member of the international Raiffeisen banking Group, pays significant attention to compliance with the requirements of legislation, normative legal acts, market rules and standards of fair competition, rules of conduct, avoiding conflict of interests.

The principles and values of the Raiffeisen Group

Raiffeisen Bank international AG (RBI) is part of the Austrian Raiffeisen banking group. The basic principles that have guided our Group come from the ideas Friedrich Wilhelm Raiffeisen (1818-1888), who believed that all economic activity should be aimed at the unity of society and self, as well as to ensure self-sufficient development.

RBI's and associated companies (Group RBI) are important participants of economic relations in Austria and in many countries where they conduct business. We – the supporters of the idea of sustainable corporate governance and adherence to the principles of social and environmental responsibility, which is the components of such management. Our role as a fair partner in the world of business is characterized by the responsibility before all stakeholders: first and foremost to our customers, suppliers, employees and shareholders, as well as to society as a whole.

the Code of conduct of the RBI Group defines the basic values of our Bank and forms the basis of corporate culture, which is the spirit of integrity. It is consistent with international practice and is based on the ethical principles but cannot cover every situation. Specific conditions can be specified in the relevant internal rules.

In the event of any dispute between local law and this Code should apply more strict rules, providing for more severe consequences. All administrative documents must comply with the principles defined in the Code. The code is intended to conform our behavior in business relations and ethics our high standards.

the Code of conduct of the Raiffeisen Bank international

Limitations in customer relations. Prohibited operations

Joint stock company “Raiffeisen Bank Aval”, as a member of the international Raiffeisen banking Group, pays significant attention to compliance with national and international standards of anti-fraud, corruption, legalization (laundering) of the incomes received by a criminal way, and terrorism financing.

Financial services of Raiffeisen Bank Aval can not be used to conduct/perform proscribed operations, particularly operations:

floor’connected with the acts prohibited/restricted in connection with the sanctions of Ukraine on the basis of the law of Ukraine «sanctions»;
directly or indirectly, floor’connected with the types of activities prohibited/restricted in accordance with decisions of competent international bodies and individual States (in particular,The UN Security Council and its committees, the EU, USA, etc.), the policy of the Bank and of the Raiffeisen Group;
directly or indirectly, floor’connected with the types of activities prohibited/restricted in accordance with decisions of competent international bodies and individual States (in particular the UN Security Council and its committees, the EU, USA, etc.), the policy of the Bank and of the Raiffeisen Group;
with signs of risky activities in the sphere of financial monitoring and/or can cause to violate the law or the implementation of risky activities.

In accordance with the legislation of Ukraine in its activities, the Bank adheres to the Ukraine sanctions imposed under the law of Ukraine «sanctions” with the aim of protecting national interests, national security, sovereignty and territorial integrity of Ukraine and anti-terrorist activities.

in Accordance with international legal Zobov’obligations of Ukraine, the Bank adheres to international sanctions of the Organization About’United Nations in accordance with the decisions of the UN Security Council and its committees. The policy of the Bank as a member of the Raiffeisen Group also includes the obligation’mandatory compliance with the sanctions imposed by the European Union and the United States of America (the part which adheres to Raiffeisen Bank international AG,controller of the international Raiffeisen banking Group).

Use of services of the Bank for the purpose of conducting prohibited transactions (including prohibited transactions on accounts, transfer funds without opening an account to conduct prohibited transactions, using their own or loan funds of the Bank for direct or indirect financing of prohibited transactions) is the reason for the failure in customer service, account closure or failure in the operation, the provision of credit, the occurrence of other consequences provided by the legislation of Ukraine or the agreements. The client must be able to prove the fact that its operations are not Yes prohibited transactions, including providing supporting documents.

The types of activities prohibited/restricted accordance with the decisions of competent international bodies (in particular the UN Security Council and its committees, the Council of the EU), policies of the Bank and of the Raiffeisen Group

1. Terrorism (financing of terrorism).

2. Trafficking of narcotic substances.

3. Prostitution.

4. Corruption and bribery (receiving/providing/the promise/demand of illegal benefit).

5. Legalization (laundering) of income obtained by criminal means.

6. Violations of human rights, in particular:

violation of the European Convention for the protection of human rights and osnovopolozhnikov from 04.11.1950 g.;
violations of labour legislation and legislation on socalization Ukraine;
violation of the relevant international UN treaties and acts minorityhealth on human rights issues;
the violation of the rights of local and indigenous communities.

the Bank may not be involved in operations in support of production/goods/services that can be used for demonstrations, political unrest and other human rights violations.

7. The activity, which results can be long-term negative impact on the environment, in particular: activities in the field of nuclear energy, activities that resulted in the destruction of tropical rain forests, pollution of the environment, water resources, and the like. The client's activity must not violate legislation of Ukraine and international treaties on the protection of the environment.

8. Activity stand ' is to carry out scientific research and development, floor’connected with military materials, their production, technical support, trade, including weapons, military hardware, which can be used for internal repression or aggression against foreign countries, the supply of war materials to States that have or are expected to, armed conflict or political unrest.

9. Activities, floor’connected with the development, production, maintenance, programming, manufacturing, mechanical and electronic devices for gambling, organization and marketing of gambling. Under the restriction fall Corporation (subsidiaries), which generate more than 20% of the total income from business in games of chance or have more than 20% of the total assets invested in the company's gaming business.

the Business relationship with the sub’objects of gambling business in Ukraine in accordance with the policy of the Raiffeisen Group are not supported. The Bank does not establish correspondent relationships with a “fictitious” by banks (shell banks).

Operations are prohibited or limited in accordance to international sanctions

Operations are prohibited or limited under international sanctions

According to the EU legislation, upholding the imposition of sanctions by the EU is required’obligatory for the Raiffeisen Group and all its subsidiary institutions, including the Bank. Also, the policy of the international Raiffeisen banking Group provides compliance with the US sanctions to prevent penalties (including secondary sanctions) from the United States to the entire Group.

International sanctions

Sanctions Of Ukraine

In order to protect the national interests, national security, sovereignty and territorial integrity of Ukraine, counteraction to terrorist activity, as well as to prevent the violation, restoration of violated rights, freedoms and legitimate interests of citizens of Ukraine, society and state in accordance with the Law of Ukraine "On sanctions" No. 1644- VII of August 14, 2014, Ukraine may apply special economic and other restrictive measures (sanctions).

Sanctions may be applied by Ukraine in relation to a foreign state, a foreign legal entity, a legal entity controlled by a foreign legal entity or non-resident natural person, foreigners, stateless persons, as well as subjects engaged in terrorist activities.

The application of sanctions does not exclude the application of other measures to protect national interests, national security, sovereignty and territorial integrity of Ukraine, its economic independence, rights, freedoms and legitimate interests of citizens of Ukraine, society and the state.

The legal basis for the application of sanctions is the Constitution of Ukraine, international treaties of Ukraine, the consent to be bound by the Verkhovna Rada of Ukraine, the laws of Ukraine, normative acts of the President of Ukraine, the Cabinet of Ministers of Ukraine, decisions of the National Security and Defense Council of Ukraine, relevant principles and norms of international law.

1. Decree of the President of Ukraine No 176/2018 dated June 21, 2018 "On Decision of the National Security and Defense Council of Ukraine dated June 21, 2018" On the Application and Amendment of Personal Special Economic and Other Restrictive Measures (Sanctions) ":

- Annex 1 "Physical persons subject to restrictive measures (sanctions)",

- Annex 2 "Legal entities subject to restrictive measures (sanctions)".

2. Decree of the President of Ukraine No.57 / 2018 dated 06 March 2018 "On the decision of the National Security and Defense Council of Ukraine dated March 1, 2018" On the application of personal special economic and other restrictive measures (sanctions) ":

- Annex "Legal entities subject to restrictive measures (sanctions)"

3. Decree of the President of Ukraine No. 133/2017 dated May 15, 2017. "On the decision of the National Security and Defense Council of Ukraine dated April 28, 2017" "On the application of personal special economic and other restrictive measures (sanctions)":

- Annex 1 "Physical persons subject to restrictive measures (sanctions)",

- Annex 2 "Legal entities subject to restrictive measures (sanctions)".

4. Decree of the President of Ukraine No. 254/2016 dated June 15, 2016. "On the decision of the National Security and Defense Council of Ukraine dated May 20, 2016" On the implementation of the resolution of the United Nations Security Council dated 20 July 2015 No. 2231 concerning the Joint Comprehensive Sectoral Plan of Action ":

- Annex 1 "List of individuals subject to restrictive measures (sanctions)",

- Annex 2 "List of legal entities subject to restrictive measures (sanctions)".

5. Law of Ukraine "On Sanctions"

6. Resolution of the Board of the National Bank of Ukraine dated October 1, 2015, No. 654 "On ensuring the implementation and monitoring of the effectiveness of personal special economic and other restrictive measures (sanctions)"

7. Law of Ukraine "On Sanctions"

8. Resolution of the Board of the National Bank of Ukraine dated October 1, 2015, No. 654 "On ensuring the implementation and monitoring of the effectiveness of personal special economic and other restrictive measures (sanctions)"

Risky activities

Signs of risk are determined by the National Bank of Ukraine, in particular, the following features are:

carrying out financial transactions by clients that do not have documentary confirmation of obvious economic expediency (meaning) and / or if the client has not provided documents (information) regarding his financial status, the content of the activity / financial transaction, his real financial capacity or in case of non-compliance of the client's financial transactions available to the Bank documents (information) concerning the financial status and / or content of the client's (social status) activity. Please note that the contract for the provision / receipt of financial assistance / loan is not a documented source of funds and can not be accepted by the Bank for a financial transaction;
conducting financial transactions, the nature or consequences of which give reason to believe that they can be associated with the withdrawal of capital, the legalization of criminal incomes, conversion (transfer) of cashless cash, the implementation of fictitious business, tax avoidance, etc. (in particular, related to the discrepancy of cash funds transfer, transfer of funds abroad, purchase and sale of securities, use of accounts of persons not intended, etc.);
initiation / execution of financial transactions using lost, stolen documents or those with signs of false, invalid (insignificant);
the execution of a financial transaction by a client who is a public figure, a person close to or related to a public figure without providing documentary evidence to the Bank regarding sources of origin of funds (assets, rights to such assets) sufficient to confirm his (her) real financial opportunities to conduct or initiate a financial transaction;
repeated execution by the client of financial transactions for the transfer of funds abroad as the implementation of advance payments (prepayment) for the execution of the foreign economic agreement (s) for which the counterparty (s) repeatedly violates the fulfillment / does not fulfill the conditions the corresponding (them) foreign economic (them) contract (s);
conducting financial transactions with clients, for which the Bank is not able to take adequate measures to establish their final beneficiary owner (s) [controller (s)] and / or for which there are reasons to believe that they use agents, nominee holders ( nominee owners) or intermediaries in order to conceal the final beneficiary owner (s) [controller (s)], incl. in this case, the Bank has established information about the final beneficiary owner (s), which does not correspond to the information specified in the Unified State Register of Legal Entities, individuals - entrepreneurs and public formations;
suspicion / assumptions based on the results of the analysis of the available information and indications that the financial transaction or its participants, their activities or sources of assets are related to the legalization (laundering) of the proceeds of crime or the financing of terrorism whether connected with the commission of another socially dangerous act defined by the Criminal Code of Ukraine as a crime or for which international sanctions are foreseen.

Signs of risky cash transactions