Compliance and Integrity

We, at NLB Banka sh.a. Prishtinë (hereinafter: NLB), believe that responsible corporate governance is much more than merely complying with laws, regulations, and standards. It is grounded in a reliable and comprehensive compliance program. Therefore, NLB is committed to ensuring high standards of compliance and integrity in every place where it operates.

At NLB, compliance is integrated into the Bank’s daily business operations, thereby contributing to strengthening the internal control environment, which ensures the effective management of compliance risks.

NLB has adopted clear rules and guidelines for its employees across various areas of activity. By ensuring legal compliance and adherence to other regulatory requirements, we make sure that NLB, its shareholders, clients, business partners, other stakeholders, and our employees are properly protected from the different risks associated with the field of compliance.

Therefore, we expect all Bank employees to follow our established compliance standards—acting transparently, responsibly, and ethically. The NLB Group Code of Ethics is a standardized document for all members of the NLB Group, which outlines our values and defines the standards of ethical business conduct. It serves as a guide for all our relationships, whether concerning clients, competitors, business partners, governmental authorities, regulators, shareholders, or internal relations among our employees. The Code of Ethics also forms the basis of our fundamental behavioral values and principles, providing clear guidance on the desired conduct for our employees. The aim of this approach is to ensure compliance with all applicable laws, regulations, and standards.

The Bank’s unit responsible for compliance and integrity is dedicated to the Bank’s continuous growth and development in the future as well. Therefore, we work constantly on strengthening the compliance function and ensuring that it is aligned with internationally recognized compliance management standards.

To promote responsible behavior among employees, we use various communication channels to discuss topics related to compliance and integrity, encourage open communication, and organize mandatory annual compliance training for all employees.

At NLB, the Compliance and Integrity Unit operates independently from the Bank’s business operations. The Compliance and Integrity Policy of NLB Banka sh.a. Prishtinë and the NLB Group serves as the foundation of the compliance and integrity program.

At NLB, continuous efforts are made to raise awareness among our employees in the business network and across other organizational units within the Bank regarding the fulfilment of legal and regulatory requirements, as well as good business practices. Therefore, the Compliance and Integrity Unit is responsible for:

Key Responsibilities of the Compliance and Integrity Unit

• Providing advice to various units within the Bank on applicable laws, directives, standards, and regulatory guidelines, as well as providing support in ensuring compliance. This also includes assisting in improving internal control mechanisms to prevent conflicts of interest, corruption and bribery, and misuse in the financial markets.
• Supervising operations and various business processes to assess potential compliance risks.
• Developing compliance principles, standards, and guidelines applicable to the Bank (related to the Code of Ethics, fraud prevention, internal regulations, rules, and standards).
• Identifying, assessing, and monitoring the management of compliance and integrity risks, among other responsibilities.

Banks and other financial institutions operate in strictly regulated environments; therefore, NLB continuously builds, strengthens, and supports a culture of compliance and due diligence. For us, it is essential that employees and decision-makers know and understand the purpose and objectives of the regulations. For this reason, systematic monitoring of changes in the legal and regulatory environment, as well as assessing their impact on the Bank, is an important part of its daily operations.

The NLB Group is deeply committed to compliance and integrity and maintains zero tolerance for any form of corruption, bribery, fraud, financial crime, or other harmful behavior.

As part of our compliance program framework, NLB has undertaken measures to ensure full compliance with all local and international laws regulating the fight against corruption and bribery. For all our employees and managers, accepting, offering, paying, or approving a bribe or any other form of corruption is strictly prohibited.

The NLB Group recognizes the importance of combating corruption and other financial crimes. Therefore, NLB Banka sh.a. Prishtinë and the other members of the NLB Group actively implement policies and procedures based on a zero‑tolerance approach toward any form of corruption, whether in the public or private sector. To this end, we have established rules, procedures, guidelines, and codes of conduct that are mandatory for all our employees, as well as for members of the governing bodies of NLB and other members of the NLB Group. We expect the same standards from our business partners, suppliers, and other third parties with whom we cooperate. NLB is committed to transparency, professionalism, and fairness in all business relationships; therefore, we avoid irregular advantages or any form of suspicious behavior from our employees or the third parties we conduct business with.

At NLB, in accordance with the Anti‑Corruption Policy, we combat corruption and bribery through:

Key Measures

• Appropriate measures focused on continuous training and awareness‑raising;
• Monitoring compliance and integrity risks, as well as monitoring the implementation of risk‑mitigation measures;
• Executing investigative procedures for all suspected harmful behaviors;
• Recording the acceptance of gifts, invitations, hospitality, and conflicts of interest;
• Using dedicated reporting channels for irregularities, enabling the reporting of suspected harmful conduct even anonymously.
  Reporting can be done through the following channels:
  telephone, e‑mail, direct reporting to the Compliance and Integrity Unit, or the Whistler application.

NLB is committed to offering only products and services that create value for our customers and shareholders, and that meet customer needs. The processes for approving new products include a preliminary review required to achieve these goals. We want to ensure that customers have full confidence in our products. Approval procedures for products and services are applied to all new product offerings, as well as to various existing products. Key control functions must be included in the product development and monitoring process, including the compliance function, as it is important that every product complies with regulatory requirements in areas such as consumer protection, personal data protection, and the prevention of money laundering and terrorist financing. The Committee for New and Existing Products at NLB is responsible for approving and monitoring products, while also focusing on product-related risks and how these risks are managed.

Policies, rules, standards, and procedures for the protection of personal data (e.g., confidential business information) are utilized in our daily activities in the field of data protection. In this way, we ensure compliance with relevant regulatory provisions that may vary significantly from one country to another. Preventive measures and thorough control within NLB regarding external providers and suppliers help prevent data loss or abuse and the violation of data protection regulations, including personal data protection. Every complaint is thoroughly investigated, and appropriate measures are taken to manage risks or prevent potential breaches. To this end, we continuously organize regular educational training to raise awareness for employee protection and to guarantee adherence to established information protection standards and the regulations and standards implemented by the Bank.

All significant violations or harmful behaviors (such as abuse, fraud, including suspicion of bribery or any other form of corruption) must be reported and addressed. NLB has created and maintains an environment that encourages employees to discuss various topics with their managers, employees in the compliance unit, the anti-money laundering and counter-terrorism financing unit, the legal office, or the human resources unit. Various reporting channels have been made available to employees, who can report their suspicions of harmful behavior; the Bank also enables them to report anonymously (where the whistleblower's identity is kept completely confidential). Our internal acts strictly regulate the protection of whistleblowers against retaliation and the assurance of anonymity!

NLB Group Anti-Corruption and Anti-Bribery Policy: