The application of the Code of Professional Conduct as a measure to promote transparency and to protect against corruption within the Group

The application of the Code of Professional Conduct as a measure to promote transparency and to protect against corruption within the Group

Eurobank S.A.

The Eurobank Group, consisting of Eurobank S.A. (Eurobank) and its subsidiaries, is a strong banking group active in six countries, with total assets of €67.7 billion and 11,394 employees. Eurobank Ergasias Services and Holdings S.A. (Eurobank Holdings) is the parent company of Eurobank Group. With a total network of 625 branches in Greece and abroad, Eurobank offers a comprehensive range of financial products and services to its retail and corporate customers. In Greece, Eurobank operations encompass a retail banking network, dedicated business centers, a Private Banking network and a dynamic digital presence. Eurobank also has presence in Bulgaria, Serbia, Cyprus, Luxembourg and United Kingdom (London). Eurobank’s philosophy focuses on providing quality services to its customers, paying attention to their particular and diverse needs. Beyond core business activity Eurobank, responding to the needs of today’s everchanging environment, consistently designs actions relating to social and environmental issues, adopting responsible practices that promote transparency and business ethics. Eurobank links its business decisions to environmental sustainability, social responsibility and corporate governance (ESG).


Objective Action

The strengthening of business ethics through an effective framework against bribery and corruption constitutes a competitive advantage, protects the Group’s reputation and increases shareholders’, employees’ and customers’ trust.

In this context, the Code of Professional Conduct (“CoC”) constitutes the central pillar, an “umbrella” instrument for policies and procedures, which allows staff to work with professional adequacy, efficiency, integrity, transparency and consistency.


Target Audience

All employees of the Eurobank Group, its subsidiaries around the world and their own subsidiaries, joint venture and any third party that obtains access to the records and premises of the Group and cooperates in any way with the Bank or another company of the Group on a contractual basis.



In the Bank, the CoC, as a stand-alone document, exists since 1997 while a stand-alone Guideline for bribery and corruption issues exists since 2010.

The Group's Code of Professional Conduct was last revised in 2017.

In 2018, the Anti-Bribery  and Corruption Framework was enhanced with the adoption of a corresponding Policy, while actions to develop further mechanisms to monitor compliance with the CoC, to prevent Anti-Bribery and Corruption and to strengthen procedures for identifying violations are ongoing and are actively supported by Group Compliance.


The primary commitment of the Group, is adherence to the highest ethical standards and zero tolerance towards cases of fraud, bribery, violation of legislation related to money-laundering and generally any actions that cause material and reputational damage to the Group, a commitment that obviously applies to all staff.

The CoC acts as a regulatory framework for the Group, is complementary and subsidiary to existing legislation and clearly reflects the value system that governs the Group’s activities: trust, understanding, dynamism, innovation, co-operation.

The central pillars of the CoC refer to the following:

  • cultivating a strong relationship of trust with clients;
  • providing financial security;
  • developing professional ethics;
  • acting with respect towards our colleagues;
  • protecting the Group and its reputation;
  • operating with social responsibility;

The pillar referring to the provision of financial security includes the prevention of instances of bribery and corruption and promotes integrity within the business environment.

The basic principles of Eurobank’s Anti-Bribery and Corruption Policy, which, together with the principles of the CoC, are in accordance with international best practices, include:

  • zero tolerance against any type of fraud, including bribery and corruption;
  • establishment of a framework for preventing and managing cases of bribery and corruption;
  • staff training;
  • risk assessment for bribery and corruption in the different operational areas;
  • implementation of a control program;
  • confidential reporting mechanisms for incidents of unethical conduct.

Every employee can report to the competent bodies of the Group facts or cases that constitute a violation of law or another form of illegal, prohibited or unethical conduct. The Group provides protection from retaliation and keeps confidential the identity of those who have submitted all the information they hold and which they consider to be accurate and true.

On an annual basis, all the employees confirm that they are aware of the terms of the CoC. The general issues developed in the CoC, and which are specified by Policies, Guidelines and Procedures issued by the relevant Units, are posted on the Intranet site or distributed by electronic mail or any other means in order to enhance the knowledge of employees with regard to the procedures in force.

The Group provides relevant induction and ongoing training programs for staff members.

Since 2008, Eurobank has signed the UN Global Compact, actively supporting and promoting the 10 Principles enshrined therein while on an annual basis, Eurobank publishes a report on the actions that fulfill its commitments to those principles.

In 2019, Eurobank adopted the enhanced Wolfsberg Group Correspondent Banking Due Diligence Questionnaire, which includes the measures taken by the Bank against bribery and corruption and is posted on the Bank’s website.


Impact on Society

Eurobank’s CoC, together with the policies and procedures included therein, constitutes an important asset for any staff member of the Group. The CoC establishes the framework within which all Eurobank staff can work on the basis of business ethics, professional adequacy, transparency and consistency. Furthermore, the CoC promotes staff awareness of anti-fraud and anti-corruption issues.

It is noteworthy that the number of queries regarding CoC-related matters submitted to Compliance is increasing year by year while more than 400 queries have been submitted during the period 2017-2019

Initiative Location

All Eurobank Group’s companies with a presence in six countries (Greece, Bulgaria, Serbia, Cyprus, Luxembourg, United Kingdom).

Working with Organization

Eurobank complies with the requirements of the regulatory authorities related to its activities (i.e. the Authority on Anti-Money Laundering, Data Protection Authority, etc.)

Moreover, in the context of staff training, Eurobank cooperates with the Association of Certified Fraud Examiners (ACFE), the Association of Certified Anti Money Laundering Specialists (ACAMS), the International Compliance Association (ICA), the National and Kapodistrian University of Athens, the Hellenic Banking Institute (ETI), as well as other organizations.


Workers Participation

Group Compliance is the owner of the Anti-Bribery and Corruption Policy and the CoC. On an annual basis, all employees confirm that they are aware of the terms of the CoC and participate in relevant induction and ongoing training programs. Moreover, all employees, as well as third parties, can submit a report regarding any incident of fraud that comes to their attention.


Benefits for Οrganization

The Group’s CoC constitutes the basic instrument for the prevention and deterrence of incidents of fraud and bribery and works as a protection measure for the Group and its reputation. The employees’commitment to the CoC contributes to the establishment and maintenance of relationships of trust with customers, as well as with all stakeholders (associates, suppliers, business operators, the state and regulatory bodies, as well as the society as a whole).

Connection with Global Goals

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