Ethical Principles

1. General Rules

Ethical principles include the principles and the regulations about the working principles that must be obeyed by the employees of ING Bank A.Ş. and Subsidiaries while performing their jobs. All the subjects mentioned within the Ethical Principles and attributed to ING Bank A.Ş. and its employees shall also apply to the subsidiaries and their employees.

Objective and Scope: Purpose of such principles is to prevent any kind of dispute or conflict of interest that may arise between the employees, customers and the Bank.

The Principles of ING Bank: Our Bank’s principles which are on ground of the related provision of the Banking Law no 5411 are listed below. Attitudes and behaviors in opposition to these principles will be assessed within the scope of Disciplinary Regulations and will be regarded as disciplinary offense. We expect our employees to act in common sense and good faith in case of situations and conditions that are not included within the scope of such rules.

In line with the Ethical principles of our Bank our employees; 

1. Should act with integrity, openly and clearly, respectfully to each other and responsibly towards society and environment in all business relationships, as  thoroughly explained in ING’s Statement of Business Principles, 
2. Adopts objectiveness as a principle, and refrain from biased and discriminative actions against their customers and colleagues,
3. Should know and stick to all the laws, rules, regulations and other internal arrangements with all details, concerning their jobs. They shall not carry out financial or administrative transactions nor allow these to be carried out, nor give advice that would create an environment of non-obedience of Rules and Regulations in terms of ING Bank and its employees. They cannot violate the rules on behalf of the bank or customers even if they have been requested to do the opposite. Employees shall be  responsible for the security of ING property and of customers and colleagues,
4. Should by no means disclose non-public information to any third parties, other than the persons who need to know them, and should do no transactions in their own name or on the name of closely-related people using such information, as is specified in Working Principles Procedures in detail, and use such data for their personal interest.
5. Should follow and review the orders, regulations, procedures, transaction steps and other instructions on a daily basis, and act in accordance with them in their transactions and business,
6. Should use assets and resources of the bank with proper care and efficiency.
7. As far as banking products and services are concerned; must conduct potential customers, primarily to ING Bank,
8. Must be aware of their liability for explanation , regarding their duties of the services in their responsibility area and their limit of authority, 
9. Are liable for informing the Human Resources Strategic Business Partnership Group via their unit manager with  higher position, about any dispute arising from the problems with customers or third parties while performing their jobs in the bank and submitted to the jurisdiction. In the Whistle Blower Procedures published by Compliance Group, the principles about notification of the transactions/ practices contradicting with the laws and internal regulations, ING Business Principles, and Ethical principles of the Bank, encountered by our employees, receiving, preserving and managing the claims / complaints about contradictions with general, operational and financial regulations have been defined,
10. Should never express their political, social and religious views in a way that may disturb others,
11. Must not utter any kind of damaging statements against banks, financial institutions, customers, and business partners, on the media and/or social media with their own identities or hidden-fake identities,
12. Should always be in compliance with the work environment and dress plainly and smartly, as is explained in detail in the Working Principles Procedures. All of our employees are expected to take same level of care with their clothes and overall looks,
13. Should not act in contrast with the equality of women and men, the respect for genders, general ethics and ethical rules accepted in the society, 

It is the responsibility of their Unit Manager and the first line manager of their administrative chain to ensure that employees act in accordance with the rules, regulated with such principles.

2. Conflict of Interests

As is defined in detail in the Working Principles Procedures; it is forbidden for our employees to benefit themselves or others directly or indirectly, abusing their position and authorities or by any other means, promise real or legal persons to benefit them. No personal investments can they make with the stock certificates or other investment instruments of the firms whichcreate a conflict of interest with their roles and responsibilities in the Bank. Private transactions of employees with ING customers must be based on an objective agreement on terms of price and payment.

Employees must conduct their social affairs outside ING Bank A.Ş. without any probable conflicts of interest. 

Written authorization must be obtained from business line managers, Human Resources Strategic Business Partnership Group and Local Compliance Officer for the following outside positions; 

• Positions at public offices , or  positions on behalf of  public offices (both paid and unpaid );
• Paid positions/activities (e.g. administrator, lecturer);
• Paid or unpaid positions/duties involving accountancy responsibility or any other kind of responsibility (e.g. Treasurer or company director);
• Supervisory directorships or consultant work, (both paid and unpaid)
• Starting up or running one’s own business (with or without permission from local authority)

3. Gifts and Entertainments for Customers

“Gifts, Entertainment and Anti-Bribery Procedures” which was prepared by Compliance Risk management Group indicates regulations regarding protecting our employees from conflicts of interest on offering/providing gifts and entertainment, carrying out all direct or indirect relations with public officials without any (appearance of) connection to bribery actions and transactions (entertainment, gift, etc.) and ensuring accuracy and transparency of the books and records of our Bank. Employees have the obligation to comply with these regulations.

4. Corporate Payments And Political Donations

No corporate/personal payments can be made and no gifts or entertainments can be offered to any government official, political party, and employees of a political party or candidates in the elections under any circumstances to influence any decision about the continuation of the Bank’s activities or that may be for the benefit of the Bank. All political donations/contributions are totally forbidden.
Participation in political meetings or demonstrations, which may be perceived as the representation of the Bank, is forbidden.

5. Regulations About Borrowing

It is a principle that the Bank’s employees can only borrow from a bank/banks which have been established for the purpose of lending loans and money and which are authorized by the law. Related issues are explained in detail on the Working Principles Procedure.

6. Power of a Attorney Agreements With The Customers

Bank’s employees cannot undertake the role of acting as the trustee authorized to represent a customer legally or cannot be a power of attorney to a customer; cannot make him/her authorized for the transactions of customer’s accounts.

7. Rules Regulating The Flow of Information

According to Article 73 of the Banking Law, any information of the Bank is subject to the principle of confidentiality and it is forbidden to transfer such information to third parties or to merchandize it.
All information within the reach of  employees as a requirement of their job, which are about the activity field of ING, are confidential in principle and should be separated from public information.
Employees are responsible  for the secrecy and protection of the data. Employees may request information and provide information, within the limits of legislation, only to the people need to know them as a requirement of their business roles. 
In the event of absence and after working hours, all information must be closed down and securely saved. Information barriers must be formed in order to protect confidential information. 

8. Data Belonging to The Bank

Private commercial secrets, financial information, customer/employees information of the Bank and all information, materials, programs and documents, computers and telecommunication transactions hardware/software and all other regulations and applications compiled within the duration of office and all other works, agreements carried out and products developed by the employees during their recruitment  in the Bank are confidential and under the possession of the Bank. These kinds of documents, information or tools are definitely forbidden to be used for the situations other than those required by employees role in the Bank and those authorized. Patent rights of the inventions belong to the Bank.
Additionally, as is given in detail in the Clean Desk Procedures, our employees are obliged to comply with the rules about preventing the access to the confidential information and documents by unauthorized people through restriction of the access to such information and documents.

9. Information Systems

Any software developed in the Bank or purchased from outside cannot be used or copied by unauthorized or unpermitted people, no matter what its purpose may be (personal or business related). Unacceptable private usage of IT Systems, such as gambling or in any other way taking part in games of chance, playing or downloading games, visiting websites with a racist background, visiting websites with emotionally charged political content or any other websites with content which breaches the prevailing ethics and morals is strictly forbidden.

10. Confidentiality of Electronic Information or Other Information

It is a principle that employees shouldn’t use the equipment, systems or e-mail systems of the Bank for preparing, storing or sending personal or private information. However people that use them shall be deemed to be relinquishing the confidentiality of such information. Employees responsible for the audit or security of the Bank are entitled to examine such information. Additionally, the Bank’s employees are responsible for the protection and secrecy of the passwords which have been provided to them.

11. Employees Possessing Inside Information Executing Transactions

It is strictly forbidden for the employees who have confidential information to make any transactions on his or her own behalf, in any kind of financial instruments related to that confidential information or make any manipulative actions in the financial markets.

12. Service Quality

Technological infrastructure, human resources and product segment structuring must be maintained throughout the Bank, in order to fulfill customer expectations and needs exceptionally; same level of service quality should be provided to the customers. Yet appropriate service differentiation can be provided for variety of customer segments and risk groups.

13. Security

In order to secure the Bank’s IT systems, operational structure, human resources and environmental factors, technical, strategic and legal precautions must be taken in to consideration on the highest level. Security measures must be reviewed and updated, if necessary, according to the changes and developments of electronic banking, digital channels and many areas. Customers have to be informed upon the updates on measures taken and required precautions.

14. Relations between the Bank and its Employees

All of the employees selected; must be chosen from the people who sustain the criteria mentioned in the 5411  Banking Law  and related legislation. It should be ensured that selected employees have required professional qualifications, training and ethical standards. Mandatory training and awareness must be provided to employees, for the requirements of the periodic conditions. Precautions must be taken for the employees to work in sanitary and safer environments.

15. Relations between Employees and Customers

Bank employees are responsible for building mutual trust on the highest level for sustaining relations with the customers on terms of knowledge and services provided. Required care must be provided on; clearness, openness and accuracy. Efficiency and timeliness must be maintained while providing banking products and services. Customer needs and financial situation should be well assessed. Product and service recommendations must be provided according to the assessment results.
Ethically there should not be any commercial, debit or credit, mutual account and/or guarantee relationships between the Bank’s customers and employees.  This kind of atmosphere must not be created at all.

16. Bank Employees' Rights

Employees must fully acquire their rights stemming from the provisions of laws and regulations which they are subject to. Entire ING Bank A.Ş. employees should have equal rights and opportunities in terms of training and education, performance evaluation, social rights, job security and hygiene.
Necessary precautions must be taken and implemented throughout the Bank in order to prevent any kind of harassment, including mobbing. If harassments were detected; required necessary actions, by the regulations, must be taken. 

17. Financial Information

All records of the Bank are kept in accordance with generally accepted accounting principles in a way that reflects the truth, fully and accurately. All transactions, controls, debts and receivables, earnings and expenditures should definitely be recorded and reported as required. No confidential or off the record contract or agreement can be made. No earning or goods can be obtained. Incorrect, fictive or deceptive records can’t be kept in any way. 

18. Information Documentation and Reporting

It is a principle that all information, documentation, papers and reporting required by the laws to be made periodically about the position of the Bank and compatibility of operations with the laws, etc. should be prepared accurately and without any flaws. It is definitely forbidden to hide such information and/or documentation from authorized bodies and auditors, or making changes or falsification on the information.

19. Media Research and Interview Requests

All kinds of interview and disclosure requests in the media (newspapers, journals, TV, etc.) should definitely be coordinated and responded to by Corporate Communications Group. Employees cannot make any explanations to printed, oral, social or visual media about the issues relating with the Bank, without permission of Corporate Communications Group and Compliance Risk Management Departments. Written approval of Human Resources Strategic Business Partnership Group is required for making a speech, presenting a notification or participating as a panelist in the meetings such as congress, conference, seminar etc. organized by others. Additionally, articles, letters or pictures using the titles of the Bank cannot be prepared without necessary approvals.

20. Customer Complaints

Ensuring that all complaints of our customers about Bank’s products and services are relayed on IRIS- Customer Solutions Center System is of great importance in order that the issue can be channeled to the related bodies rapidly and accurately. In addition, all kinds of critical and extraordinary complaints that may affect the prestige of the Bank should be conveyed to the managers of the related units without any delay. 
The relationships with the customers must be in compliance with “5 Golden Rules for Approaching the Customers” principle.

21. Customer Relationships Contradicting with Regulations

It is definitely forbidden to act as a mediator for the actions contradicting with the Regulations and help for money laundering actions.

22. Legal Investigations about Customers

Information about the customers required by authorized bodies can only be given within the knowledge of the related Business Unit and Legal Department.

23. Activities Contradicting with Competition Laws

Employees cannot participate in the agreements with customers that may influence pricing or marketing policies under any circumstances, or act in contradiction with Law on The Protection of Competition and related procedures of our Bank. During employment practices, it is necessary to refrain from unfair competition and damaging acts towards other banks. Necessary measures must be taken for the employees who have been employed on other banks previously, in order to to protect their secrecy on grounds of Banking Regulations. Advertisements and bulletins must be constituted  in compliance with general ethical rules and principles and there should not be any misleading information about ING Banks products and services, or inappropriate statements about rival banks

24. Legal Issues

Employees should immediately inform their managers and Human Resources Strategic Business Partnership Group, if they are involved in any legal or official investigation, arrested, interrogated, or condemned, whatever the reason may be (as the witness or accused).  Employees, if not mandatory by law, cannot act as a witness in the cases where prestige, persistence of the Bank and the works being executed may be affected, cannot sign any apology prepared over the request of third parties.

25. Combatting Proceeds of Crime and Terrorism Financing

As explained in detail in the Procedures about Combating Proceeds of Crime; in line with the Regulations of The Program of Compliance with the Liabilities about Laundering proceeds of Crime and Preventing Finance of Terrorism, Financial Economic Crimes Policy and its appendix Minimum standards Document which are in effect in ING Group, including our Bank; in relation to laundering proceeds of crime and financing terrorism along with UHRC and Export Policy; it is aimed to inform the Bank and employees of the Bank about their legal and administrative liabilities, determine the values and interests subject to laundering and prevent laundering of such values and interests by using the facilities of the Bank.

By arranging related corporate procedures, it is aimed to ensure that ING Bank A.Ş. can continue its banking activities in a safe environment and preserve its reputation and customer quality.
ING does not do business with people, institutions or businesses with any involvement in activities which are illegal. (Such as trade in narcotics, involvement in trafficking of human beings, illegal gambling dens, money laundering) For this reason, employees must not provide financial services for a customer; if this act could lead to the impression that the money (or monetary equivalent) involved in this could serve to an unacceptable purpose, has been acquired by criminal means or that the financial service could have the objective of evading taxation. ING has developed rules for the prevention of these activities.

26. Human Resources

All policies and practices about Bank’s employees (equality of opportunity, performance evaluation, salaries and benefits and other issues about employment) are developed by the Executive Vice President responsible for the management of Human Resources in accordance with legal regulations and the provisions in the regulations that regulate the business life. Disciplinary Regulations are implemented if employees act in contradiction with Ethical Principles, instructions of superiors, general behaviors and practices in the sector and the laws. If employees fail to notify related bodies about the actions contradicting with Ethical principles, rules and standards, it shall also be deemed to be violation of rules on its own. Such situations shall be subject to disciplinary penalties if they are detected.

27. Transfer of Authorities

Employees responsible for managing activities are obliged to make a job sharing among their subordinates and transfer their authorities only after being sure that the employees taking over the jobs have the competencies and experience needed for carrying out such jobs satisfyingly. 

28. Improving and Updating of Banking Ethics

The Bank is entitled to proclaim comments, demands and opinions in relation to “Code of Banking Ethics”, which was published by the Banks Association of Türkiye, to the board of directors of the relevant unions of institutions any time.

29. The Basis and Methodology for the Applications to the Banks Association of Türkiye

Employees and Customers of our Bank, if they have detected any kind of incidents against “Ethical Principles of Banking” which was published by the Banks Association of Türkiye, may make written applications to Banks Association of Türkiye, within a year following the day the incident takes place. Applications must be clearly and comprehensively supported in details by substantiated documents and information. The applications are evaluated and controlled by the Association in terms of features, information and documentation. Applications found eligible by the Association is escalated to the Ethics Committee. Also applications found eligible by the Ethics Committee are submitted to the Board of Directors of BAT. If the Board of Directors detect any non-compliance with the Ethical Rules, then those breaching the Ethical Rules are reported to the Banking Regulation and Supervision Agency and Article 81, Clause 3 of Banking Law 5411 is applied on to them.