Eastern Bank Ltd.

Policy Number: eblHR- PMP-008

Title: KNOW CODE OF CONDUCT

Effective Date: 08 May, 2019 31 December, 2021
All employees of
Total no of Page: 7 Applicable for:
Eastern Bank Ltd.
Prepared by:

Anubhab Rahman
Head, Organization Development
Reviewed by:

Monjurul Alam
Head, Human Resources
Recommended by:

Ali Reza Iftekhar

Managing Director & CEO

Taking personal responsibility for our actions is critical to the success of EBL. People trust us
to deliver on our promise to do business ethically and serve with high quality financial product
and services. Our customers and employees expect us to operate in a safe and healthy
environment that allow them to remain safe in EBL.

8.1 Who is subject to this code?

This code of conduct outlines the values, ethical principles and expected behaviors for all EBL
employees. Each of us is expected to apply the Code of conduct and help others do the same.
Each of us need to remember that Our daily decisions and actions affect our Brand and our
colleagues, and can have an impact on the confidence placed on us by our stakeholders.
Adherence to this Code is a condition of employment in EBL. Failure to comply it may result
in disciplinary action up to and including immediate termination / dismissal.

8.2 Why Code of Conduct?

During our employment in EBL we need to ask ourselves the following questions before acting.
 Is my action legal?
 Is it in line with EBL values?
 It is not causing harm to others?
 Is it acceptable by EBL standard?
 It is not a breach of trust by myself with organization?
If any of the questions answered “No” then you need to refer this code of conduct before you
continue with your activity and refer the matter to your line manager and / or eblHR.
8.3 We respect:
 8.3.1 Ensuring equal opportunity: We are committed to equality of opportunity and
treatment in our employment practices. We don't discriminate on broad range of grounds,
including gender, sexual orientation, marital or civil partner status, gender reassignment,
race, religion or belief, color, nationality, ethnic or national origin, disability or age. Our
compensation and benefits policy is totally performance based. We treat people only on
their contribution to the Bank and rewards are fairly distributed.
 8.3.2 Diversity: We are committed to increasing the diversity of our talent pool going
forward and as part of initiatives in this area, we are updating our approach to recruitment
activities to ensure we attract a diverse range of candidates, as well as promoting diversity
through our internal training and development initiatives.
 8.3.3 Dignity & Fair Treatment: EBL employees must respect the dignity of colleagues
and all others they come into contact with as part of their jobs. EBL treats all employees
fairly and keep them informed about all the relevant changes with clear communication.
 8.3.4 Friends and Relatives; Co-Worker Relationships: Business and professional
relationships with relatives, spouses, significant others or close friends can lead to a
conflict of interest that can be difficult to resolve. If you are faced with the possibility of
such a business or personal relationship you should discuss the matter with your manager.
 8.3.5 Stakeholders: We should be respectful and responsible towards our stakeholders
at all time and everywhere we operate. We should show utmost integrity and honesty
towards our stakeholders when it comes to giving them service, protecting their
information, providing them with product knowledge, building relation, keeping their
privacy and any other related activities. We can only disclose the records if advised by the
court of law.
 8.3.6 Protection of Customer & Other Banks/NBFIs Privacy and Records: All the
Employees of the Bank should maintain books and records with integrity, reflected in the
accurate and timely manner of all transaction. We should not disclose any information of
the Bank’s plans, procedures, initiatives to anybody (including family, friends), unless
advised by the court of law, without proper authorization. We should observe customer’s
privacy at all circumstances an at all times. An employee of the Bank may have access to
information related to banks, customers, suppliers and current and former employees, as
well as system- and bank-related information while performing official tasks. We shall not
disclose/provide information of other institutions related to its performance, strategy,
system, policies etc. to third parties without prior approval of competent authority.
 8.3.7 Harassment, Discrimination and Bullying: EBL prohibits harassment and
bullying in any form – verbal, physical, or visual, as discussed in details in our People
Management policy. An EBL employee must not demonstrate unwelcome and unsolicited
behavior that a reasonable person would consider to be offensive, intimidating, humiliating
or threatening.
 8.3.8 Personal Questions: We believe asking personal questions may make employees
or customers uncomfortable. It is highly discouraged since others may feel troubled,
embarrassed, and disturbed due to such inquiries. We must not upset our fellow colleagues
or respectful customers by participating in such activities. We should not invade others
privacy by asking awkward questions. However, if such situation or need arises where a
customer or colleague want to share personal information, we should interact with utmost
integrity and respect. Strict actions will be taken upon such behaviour/activity.
 8.3.9 Speak up: EBL is committed to the highest standards of openness, probity and
accountability. We encourage colleagues to speak up if they suspect wrongdoing of any
kind. When making a report, this must be done in good faith and not for the purposes of
spreading false information or making a report with malicious intent. Please provide as
much information and be as specific as possible so we can follow up efficiently. It is our
 policy that retaliation is not permissible against any person raising a concern in good
faith. Please refer to EBL employee speak up policy for details. However, if an employee
does not speak up on occasions will be considered as the incident of concealment of facts
that might result in disciplinary action.

8.4 We are ethical

 8.4.1 Anti-Money Laundering: Money Laundering legislations criminalize money
laundering in respect of several crimes including drug trafficking, terrorism, theft, tax
evasion, fraud, handling of stolen goods, counterfeiting and blackmail etc. it is also an
offence to undertake and /or facilitate transactions with individuals and entities involved
in criminal activities. EBL will not do business with drug traffickers, money launderers and
other criminals.
 8.4.2 Prevent Money Laundering and Transaction Structuring: We must comply
with local laws, regulations on money laundering and prevent fraud. We are not allowed
to involve ourselves in any sort of money laundering activities and we must always keep
our eyes open to detect any fraudulent activities in the Bank. We should follow the Bank’s
prudent guidelines while dealing in transaction with the customers. Any suspicious
behavior of the customers, should be reported immediately. We have to know a customer’s
identity including their source of fund. We must examine the documents for their
authenticity before giving our decision.
 8.4.3 Signing a Contract: Each time we enter into a business contract on EBL's behalf,
there should be documentation recording that agreement, recommended/ approved by
the Legal Unit, Internal Control and Compliance Department. We cannot sign any contract
on behalf of EBL unless all of the following are met:
a) We are authorized to do so under our Signature Authority and Approval Policy. If we are
unsure whether we are authorized, ask line manager.
b) If we are using an approved EBL form contract, we don't need further Legal approval
unless we have made changes to the form contract or are using it for other than its
intended purpose
c) We have studied the contract, understood its terms and decided that entering into the
contract is in EBL's interest
All contracts at EBL should be in writing and should contain all of the relevant terms to
which the parties are agreeing - EBL does not permit "side agreements," oral or written.
 8.4.4 Bribery: All payments made by the business must be warranted, transparent and
proper. No payments may be made as a subterfuge for bribery. It is contrary to this code
to offer, promise, authorize, pay or give, either directly or indirectly, to any other person
(whether a government official or not) any financial or other advantage in order to secure
an improper advantage, to obtain or retain business, or direct business to any other person
or entity. Bribery is not at all acceptable and a punishable offense.
 8.4.5 Borrowings: An employee shall not borrow money from any customer or employee
of the Bank or from person(s) likely to have dealings with the Bank or from any other
money lenders.
We have to set our lifestyle in such a way that the need to borrow money from anyone.
 8.4.6 Avoid Conflicts of Interest: Employees must not use their position in the bank
for personal gain or to obtain benefits for themselves and members of their families or
friends. Employees who discharges citizenship responsibility through membership of public
decision making bodies (school boards, society, recreational bodies etc.) should be alert
to possible conflicts of interest and declare any such conflict.
 8.4.7 Reporting Financial/ Accounting or any other Irregularities: if there is any
Financial/ Accounting or any other Irregularities please refer to our Speak up policy.
 8.4.8 Third Parties and Suppliers: We choose our third parties carefully and take
appropriate measures to ensure they meet contractual requirements and follow the law,
 our Code, and our policies. We evaluate potential third parties based on legitimate
business criteria, such as: Safety, Needs, Cost, Quality, Services offered, Availability,
Reputation and integrity. We treat third parties fairly and with integrity, avoid conflicts of
interest, and even the appearance of impropriety. Just as it’s important to protect EBL
information, it's important we protect our third parties’ confidential information and let
them know that we expect them to protect ours.
 8.4.9 Outside employment: Employees are not allowed to be employed elsewhere while
they are with the Bank as full- time employees. We are full time employees of the bank
and are on duty for 24 hours. We are responsible to the office even we are not present at
the office. Our deeds and actions during our absence from office should not be such that
the action has an official impact. We may occasionally give services to Universities/
institutions but prior permission is required to avoid any unpleasant situation. We can
provide community services but should not charge remunerations. We are not allowed to
join the management of any company in order to avoid a conflict of interests.
 8.4.10 Speculation in Stocks: Employees and their dependents should not speculate/
trade in stocks, shares, securities or commodities of any description nor be connected with
the formation or management of a joint- stock company. We are not allowed to involve
ourselves in any business activities, such as trading of shares, securities and debentures.
We are allowed to invest our savings into shares and apply for IPO. We will not allow our
dependents to participate in any kind of speculative business.

8.5 We do what is right

 8.5.1 Dealing with government/ regulatory officials: All employees must deal with
the government and regulatory officials with proper respect. Government and regulatory
officers mean Ministry of Finance, Bangladesh Bank, National Board of Revenue,
Bangladesh Security and Exchange Commission, Bangladesh Investment Development
Authority and Comptroller and Auditor General of Bangladesh. If they are asking for any
information then any employee should provide the information based on their job scope
and authority; obviously in consultation with their line manager(s) and concerned
authority.
 8.5.2 Participation in Political Activities and External Pressure/Approach to
Member of Parliament, Political Leader, Board Members, etc.: An employee shall
not directly or indirectly participate in any political activities during employment with the
Bank. We should not donate any fund to political parties. We should not write or distribute
political leaflet. We should not attend any political meeting even during holidays. Such
activities may give rise to conflicts of interest.
No employee shall directly or indirectly approach any member of the Parliament or use
any political or other type of influence or attempt to bring any influence of the Board of
Directors of his/her organization for his/her employment, increment, promotion, transfer,
or any other personal gain.
 8.5.3 Representation to Directors: An employee shall not make any personal
representation to directors of the Bank. All representations must be addressed to the
Managing Director through proper channel. We are not allowed to write any letter or
appeal to the Directors of the Bank as long as we remain an employee of the Bank. We
can write letters to our superiors; if we do not receive satisfactory results, we can apply
to the Managing Director and his decision would be treated as final.
 8.5.4 Discloser of relationship; Employment of relatives/ conflict of
responsibilities: If an employee of the Bank has authority to sanction loan and/or
recommending power, if they have any direct relationship with any borrower of the Bank
or the employee is otherwise interested in any loan/advance and other facility, etc. given
by the Bank, the employee must disclose the information.
 EBL rejects candidates on grounds of their relation to a current employee which may have
a negative impact on productivity and trigger accusations of nepotism and favouritism.
The word “relative” refers to any person who has a relation by blood or marriage within
the 1st degree with our employee that includes parents, step-parents, grandparents, in-
laws, spouses, children, step-children, adoptive children, grandchildren, siblings, uncles,
aunts, nieces and nephews. However, people may become legal partners after joining in
EBL – HR will ensure that they will not work in same reporting line. New recruits should
disclose whether they have any relatives in the Bank and existing employees should notify
HR if they plan to marry a fellow employee.
 8.5.5 Alcoholism: An employee must not consume alcoholic drinks during office hours.
It is also expected that our employees will refrain from damaging the bank’s image/
reputation when they engage themselves in social activities. We will abide by the country’s
laws regarding the consumption of alcoholic products.
 8.5.6 Drug Addiction: An employee must not contemplate experimenting with drugs.
Any evidence of Drug abuse of the employee’s part will result in prosecution. We will abide
by the country’s laws concerned with the consumption of Drugs.
 8.5.7 Non Smoking Workplace and Vehicle Pool: EBL is a non-smoking workplace.
Smoking in the premises will be a breach of conduct and the employee will be dealt
accordingly. Employees are not allowed to smoke inside the pool vehicles. We will
discourage our customers to smoke inside the branches, or any part of the EBL Head office
premises. We will abide by the country’s laws regarding smoking.
 8.5.8 Accepting Gifts, Entertainment, and Other Business Courtesies: As a rule,
gifts or services offered to an employee representing EBL should never exceed 2000 taka
after a reasonable frequency. Apart from branded corporate gift items used for
promotional purpose. Always remember that:
a) Gifts should never be accepted secretly.
b) Money should never be accepted as a gift.
c) Never accept gifts from stakeholders relating to business (i.e. customers, vendors).
d) Entertainment such as dinner invitations should never be extravagant and should
always have acceptable business purpose.
e) Voyages and business trips should always have a legitimate business purpose and
should never be accepted secretly.
f) It is not allowed to accept gifts given with the purpose of influencing upon a decision.
 8.5.9 Habitual Lateness: Habitual lateness is not acceptable in EBL and it is considered
to be an offense. Habitually late people are considered to be non-performer also. Line
managers should instantly talk to the concerned employee and counsel them for remedial
action. If the employee continues to be late at office that will warrant immediate
disciplinary action.
 8.5.10 Unauthorized Absence: Unauthorized absence should be notified to eblHR after
3 days of absence. Unauthorized absence is a terminable offense.
 8.5.11 Procrastination: Procrastination is defined as the habitual/intentional delay of
starting or finishing a task despite its negative consequences. People should be aware
about the degree of urgency and importance of their job. Procrastination might be
interpreted as inefficiency at many cases which might result in poor performance. So,
procrastination must be avoided unless it is at decision making level which might help the
decision making process.
 8.5.12 Concealment of fact: Wilful action of concealment of fact or not informing an
incident that might cause harm to the interest of EBL is a serious breach of code of conduct
of EBL which might result in termination also.
 8.5.13 Fair competition and anti-trust: We are committed to doing business fairly,
everywhere we operate. Always use good judgment and avoid agreements and discussions
about competitive matters. Never make agreements that may create an unfair advantage
 in the market, such as those to fix prices, divide customers, or prevent competitors from
entering the market. Don’t discuss competitively sensitive topics with competitors, such
as price, contract terms, or marketing plans.
 8.5.14 Terrorist activity or fundamentalism: Bank will show zero tolerance to
employee getting involved in terrorist activity or fundamentalism or any activity that is
subversive to the Bank or nation.
8.6 We take care
 8.6.1 Honesty and Integrity: An employee must act honestly and with integrity all time.
He/she must act fairly and equitably when dealing with the public, customer and other
employee. We have to work with honesty and sincerity to uphold the image of Bank. We
have to be very sincere and show honesty in dealing with our customers in order to win
their trust. We should treat every customer, regardless of their race or class, fairly and
equitably so that they cannot question our integrity at any time. We must set our standard
of living as per our earnings.
 8.6.2 Health & Safety: Everyone deserves to work in a safe and secure workplace. That’s
why we maintain our workplace free of intimidation, threats, or acts of violence. We want
to provide a safe work environment for everyone at EBL, including employees, customers,
and visitors. We take our commitment to ensuring a safe and healthy workplace seriously
and believe it’s everyone’s responsibility. Valuing the safety of our coworkers and
customers as we would our own families.
 8.6.3 Protecting Privacy, personal information and security: We are asking
customers to trust us with their personal information. Preserving that trust requires that
each of us respect and protect the privacy and security of that information. Our security
procedures strictly limit access to and use of users' personal information, and require that
each of us take measures to protect user data from unauthorized access. We follow privacy
principles and strive to implement reasonable and appropriate practices in sharing of
personal information about individuals. These principles and practices ensure that:
Personal information can be used to support legitimate business purposes only and
development processes for products and services.
 8.6.4 Maintaining information security: It is important that our products are safe for
our customers, protect their data, and are designed with security in mind. As we develop
and offer products and services, we understand the role of cybersecurity in protecting our
customers, their data, and our bank. We shall focus on our customers and their data, so
our products are safe and secure.
 8.6.5 Intellectual Property: EBL’s Intellectual Property assets contribute to our ability
to effectively conduct our business and to grow and achieve our business objectives. These
assets include the ideas, new product plan or design, software, business information,
financial data, technical information, trademarks, brands copyrights, Logo, applications,
and all other proprietary information made for EBL or made by EBL employees.
 8.6.6 Password sharing: Any user ID and password provided by the Bank to any
employee should be maintained with highest confidentiality. The user ID and password(s)
are issued to authorized person for official purpose and to be used by the individual only.
All employees of EBL must take all reasonable precautions to keep their used ID(s) and
password(s) secure. Unauthorized user ID and password sharing is a terminable offense.
 8.6.7 Customer Complaints: All employees should give priority in resolving customer
complaints quickly, fairly and record them accordingly. Employee must thank them for
bringing the problem to them. Customer complaints should be handled with care and
sincerity. We should allow the customers to vent their anger. We have to listen attentively
to the customer’s complaints with a positive frame of mind. We should exude empathy by
responding to the customer’s feelings. We should acknowledge the inconvenience caused
to the customers by speaking politely. We should apologize if we are at fault. We will solve
 the problem right away. If outside help is required, customers should be explained and
time must be taken to resolve it.
 8.6.8 Use of Corporate Name and Letterhead: An employee should not use EBL’s
name, logo, corporate letterhead and seal for any purpose other than in the normal course
of banking business. There’s no way in which we can use these items for personal purpose.
We must not keep the letterhead, official seal in an open space.
 8.6.9 Use of Service Facilities: An employee must ensure that Service facilities,
equipment and vehicles are used efficiently and economically in the course of performing
his or her duties. Unless authorized, a member must not use service facilities, equipment
or vehicles for private or improper purposes except where such use is authorized by the
Management. We should not use the pool car and official telephone for our personal
purpose. We have to obtain prior permission for using official facilities after office hours
or during holidays. We should take care of the facilities properly. We should do
maintenance work regularly for smooth operation of the equipment under our control.
 8.6.10 External Communications: Everything we communicate about EBL can have an
impact on our reputation, coworkers, and brand. We make sure the information we
communicate is reliable, consistent, and accurate, which is why only certain people are
authorized to speak on our bank’s behalf. That’s why it’s important that you refrain from
speaking on our bank’s behalf unless you’re authorized to do so. If you ever are contacted
by the media about our bank, refer them to EBL Brand and Communications department.
 8.6.11 Social Media: Social media offers a great way to build relationships and exchange
ideas. While we respect your right to use social media, use it in a way that’s consistent
with our values and policies. Follow the law and be aware that you are responsible for
what you publish, so use good judgment. Understand that we never tolerate the use of
social media to intimidate, harass, or discriminate against fellow employees.
 8.6.12 Misrepresenting and Mis-selling the Bank’s Product and Services: All
employee should be aware about the product and services the Bank provides and they
should be careful when selling these products to the customers. Employees should comply
with the rules and regulations on mis-selling and misrepresenting including advertising.
We must not sell any product or services to customers that do not meet their needs or
their interests. We should provide full range of information about the services and product
to the customers so that they can take their decision based on merits. We must describe
the pros and cons of the products including the complexity to the customers.
 8.6.13 Workplace Violence: Everyone deserves to work in a safe and secure workplace.
That’s why we maintain a workplace free of intimidation, threats, or acts of violence. As a
bank, we work to provide a safe and secure workplace to our employees. We also do not
tolerate conduct that harasses, disrupts, or interferes with another person’s work
performance or that creates an intimidating, offensive, or hostile environment.

8.7 Frequently Asked Questions

What if I am uncertain if an incident violates the Code of Conduct?
You should ask your line manager or eblHR for clarification.

What will happen to me if I file a report?

EBL encourages you to report suspected violations of the Code of Conduct. If you feel that
you have been retaliated against, you can report this through eblHR.

My manager or supervisor has asked me to do something that I think is illegal or

which violates the Code of Conduct. What should I do?
You should report the issue through eblHR.
I have seen some conduct at the office that I think is illegal but it is not addressed
in the Code. What should I do?
If you suspect illegal behaviour, you should report it or talk with your supervisor or line
manager about it. No Code of Conduct could possibly address every situation. The bottom
line is that you have to exercise good judgment and high ethical standards at all times
whether or not an issue is specifically addressed in the Code of Conduct.

I have been asked to serve as a consultant / trainer for one of our vendors during
off hours. Can I do this?
Serving as a consultant for another company that does business with EBL or other Banks(s)
can create a conflict of interest. Consequently, you must receive approval from EBL
Management prior to agreeing to serve as a consultant or trainer. Raise the issue with your
line manager, who will then take the issue to the appropriate authority for consideration.