www.vtb.com Open in urlscan Pro
195.242.83.14  Public Scan

Submitted URL: http://www.vtb.com/ir/disclosure/compliance/
Effective URL: https://www.vtb.com/ir/disclosure/compliance/
Submission: On March 28 via manual from IN — Scanned from DE

Form analysis 0 forms found in the DOM

Text Content

 * VTB Group
 * Corporate business
 * Financial institutions
 * Investor Relations


Go to «VTB Group»VTB Bank

 * Go to «VTB Bank»

VTB Group

 * Go to «VTB Group»
 * About VTB Group
 * Mission, Vision, Values
 * Strategy

Press-center

 * Go to «Press-center»

Contact information

 * Go to «Contact information»

Careers

 * Go to «Careers »

Go to «Corporate business»Transaction management

 * Go to «Transaction management»
 * Opening an account
 * Money orders and transactions
 * Secure documentation
 * Cash collection and cash desk operations
 * Secure documentation
 * Currency control
 * Value Today, Value Tomorrow, Spot Forex Transactions
 * Money orders and transactions
 * Cash collection and cash desk operations
 * Internet-Client
 * Mobile Client
 * Benefits of the Bank-Client system
 * Acquiring services
 * Customer’s processing centre
 * Cash pooling

Documentary Operations

 * Go to «Documentary Operations»
 * Documentary and Clean Collection
 * Letters of Credit

Lending

 * Go to «Lending»
 * Short-, medium- and long-term loans
 * Credit lines
 * Overdraft loan
 * Complex loan products and consultancy services
 * Credit operations through remote banking system
 * Loans to the mining industry

Savings and investment products

 * Go to «Savings and investment products»
 * Standard term deposits
 * Corporate Overnight
 * Structured deposits
 * Placement of funds on current account
 * Promissory notes

Custody Services

 * Go to «Custody Services»
 * Depository Services
 * ADR / GDR programs
 * Individual client accounts with international clearing houses
 * Weekly Custody Newsletter

Trade and export finance

 * Go to «Trade and export finance»

Go to «Financial institutions»
Go to «Investor Relations»Shares and dividends

 * Go to «Shares and dividends»

Credit ratings

 * Go to «Credit ratings»

Dividend History

 * Go to «Dividend History»

Charter and profile

 * Go to «Charter and profile»
 * Charter and profile
 * Anti-corruption policy
 * Compliance

General meeting of shareholders

 * Go to «General meeting of shareholders»

Sustainable development

 * Go to «Sustainable development»

Financial Results

 * Go to «Financial Results»
 * IFRS Financial Results
 * Annual Reports

 * Menu

VTB Group
VTB BankVTB GroupPress-centerContact informationCareers Go to chapter
Go to «VTB Bank»

Go to «VTB Group»

VTB GROUP

About VTB GroupMission, Vision, ValuesStrategy


Go to «Press-center»

Go to «Contact information»

Go to «Careers »

Corporate business
Transaction managementDocumentary OperationsLendingSavings and investment
productsCustody ServicesTrade and export financeGo to chapter
Go to «Transaction management»

CASH MANAGEMENT PRODUCTS AND SERVICES

Opening an accountMoney orders and transactionsSecure documentationCash
collection and cash desk operations

SECURE DOCUMENTATION

Secure documentation

CURRENCY CONTROL

Currency control

VALUE TODAY, VALUE TOMORROW, SPOT FOREX TRANSACTIONS

Value Today, Value Tomorrow, Spot Forex Transactions

MONEY ORDERS AND TRANSACTIONS

Money orders and transactions

CASH COLLECTION AND CASH DESK OPERATIONS

Cash collection and cash desk operations

ELECTRONIC BANKING

Internet-ClientMobile ClientBenefits of the Bank-Client system
Card solutions
Go to «Documentary Operations»

DOCUMENTARY AND CLEAN COLLECTION

Documentary and Clean Collection

LETTERS OF CREDIT

Letters of Credit


Go to «Lending»

LENDING

Short-, medium- and long-term loansCredit linesOverdraft loanComplex loan
products and consultancy servicesCredit operations through remote banking
systemLoans to the mining industry


Go to «Savings and investment products»

SAVINGS AND INVESTMENT PRODUCTS

Standard term depositsCorporate OvernightStructured depositsPlacement of funds
on current accountPromissory notes


Go to «Custody Services»

CUSTODY SERVICES

Depository ServicesADR / GDR programsIndividual client accounts with
international clearing housesWeekly Custody Newsletter


Go to «Trade and export finance»

Financial institutions
Go to chapter
Investor Relations
Shares and dividendsCredit ratingsDividend HistoryCharter and profileGeneral
meeting of shareholdersSustainable developmentFinancial ResultsGo to chapter
Go to «Shares and dividends»

Go to «Credit ratings»

Go to «Dividend History»

Go to «Charter and profile»

CHARTER AND PROFILE

Charter and profileAnti-corruption policyCompliance


Go to «General meeting of shareholders»

Go to «Sustainable development»

Go to «Financial Results»

FINANCIAL RESULTS

IFRS Financial ResultsAnnual Reports




 * Investor Relations/
 * /
 * Compliance/


COMPLIANCE

The term “compliance” means correspondence to legislation requirements and
internal organization documents along with observance of self-regulatory
organization standards.




COMPLIANCE

The term “compliance” means correspondence to legislation requirements and
internal organization documents along with observance of self-regulatory
organization standards.


 * 
 * Task
 * Value
 * Approach

The key task of compliance units

Arrangement of regulatory risk management processes and procedures, including
AML/CTF/CPF processes.



The Bank's core value

Establishment of a trust-based relationship with its clients, counterparties,
partners and shareholders, the trust of which directly depends on corporate
ethics. Corporate ethics presume a specific set of moral rules, the Bank's Code
of Ethics, that are observed by employees in relation to clients,
counterparties, partners, shareholders and towards each other.



Approach and internal procedures

Our Bank's approach and internal procedures guarantee compliance with
legislation requirements, self-regulatory organization standards, they enable us
to promptly respond to any changes to minimize reputation and regulatory risks.
The Bank participates in dedicated committees and professional and international
associations.



Formation of the corporate code of ethics

The Bank's Code of Ethics is a minimal and mandatory standard for all of its
employees and a benchmark for our clients, counterparties, partners,
shareholders and other stakehoholders who share our values.


The VTB Code of Ethics covers all areas of its activity and reflects its
requirements and expectations in relation to employee conduct.
Code of Ethics of VTB Bank


--------------------------------------------------------------------------------


THE PRINCIPLES OF CORPORATE GOVERNANCE


The Bank places a special focus on the principles of corporate governance,
developing open, trust and respect-based relationships with clients,
counterparties, employees, shareholders and ensuring compliance with
international ethical norms and principles of open and honest business.
Our Bank’s absolute value is respect for and strict observance of human rights,
support of the principles of:
 * the Universal Declaration of Human Rights,
 * Convention on Human Rights and fundamental freedoms,
 * Declaration of Fundamental Principles and Rights at Work,
 * International Labor Organization Conventions and other international
   documents on human rights.



--------------------------------------------------------------------------------

--------------------------------------------------------------------------------


ESG-BASED PRINCIPLES


In our daily activity our employees are guided by the rule of “Do more than you
formally should”, which is fully reflected in our ESG-based principles and
approaches:
 * Social responsibility;
 * Sustainable long-term development;
 * Caring about the environment;
 * Implementation of best corporate governance practices.



--------------------------------------------------------------------------------

Counteracting money laundering, terrorism financing and financing proliferation
of weapons of mass destruction

AML/CTF and CPF

The Bank uses all available resources in the area of counteracting money
laundering, terrorism financing and financing proliferation of weapons of mass
destruction


In order to ensure timely identification of threats connected with money
laundering and terrorism financing, control risks and prevent undesirable
consequences the Bank has created an AML/CTF and CPF system.


--------------------------------------------------------------------------------


AML/CTF AND CPF SYSTEM


In order to ensure timely identification of threats connected with money
laundering and terrorism financing, control risks and prevent undesirable
consequences the Bank has created an AML/CTF and CPF system with the following
elements in VTB Group:
 * Application of the Know Your Customer principle;
 * Identification of operations subject to so-called “mandatory control”;
 * Identification and prevention of suspicious operations;
 * Education and training of employees.



--------------------------------------------------------------------------------

--------------------------------------------------------------------------------


CONSOLIDATED AML/CTF/CPF POLICY


VTB Group has developed a Consolidated AML/CTF/CPF Policy for these purposes,
which determines unified standards and approaches to fulfillment of Russian and
international AML/CTF management requirements.


--------------------------------------------------------------------------------

--------------------------------------------------------------------------------


IN ITS AML/CTF/CPF ACTIVITY THE BANK IS GUIDED BY


 * the legislation of the Russian Federation and the regulations of the
   countries of the location of our branches;
 * Recommendations and comments from the Central Bank and Rosfinmonitoring;
 * Best practices of international organizations: o Groups for development of
   AML financial measures (FATF); o The Eurasian Group on Combating Money
   Laundering and Financing of Terrorism (EAG) o Wolfsberg Group; o Basel
   Committee on Banking Supervision.

The Bank's Management puts special focus on observance of AML/CTF/CPF
requirements by all Bank employees, clients, counterparties and partners for
transparent business processes and preventing use of Bank products and services
for the purpose of AML/CTF/CPF. Being a market leader in new anti-money
laundering management technologies the Bank takes part in Rosfinmonitoring
projects, developing proposals for legislative initiatives and submitting
proposals for improvement of regulatory AML/CTF/CPF requirements.
VTB develops solutions and approaches for implementation of such requirements in
collaboration with other financial market participants.
The Bank of Russia distinguishes our Bank as an institution that inputs
significant efforts to achieve a common goal and ban individuals that aim to
perform shadow operations and evade taxes from the financial sector.


--------------------------------------------------------------------------------

Сountering corruption, prevention and settlement of conflicts of interest

Countering corruption is one of VTB’s priorities. Our Bank has a zero tolerance
policy towards corruption in any form and materialization.


Anti-Corruption Policy

In order to form a zero tolerance policy for corruption the Bank has developed
and implemented and Anti-Corruption Policy that is mandatory for all employees.
This Policy reflects the Bank’s and the Bank management’s commitment to high
ethical standards of open and honest business for improvement of the corporate
culture, compliance with best corporate governance practices and maintenance of
the Bank's immaculate reputation.
Employees report all identified or potential violations of the Bank's
Anti-Corruption Management Policy to the Compliance Hotline.
VTB Bank's Anti-Corruption Management Policy



Anti-Corruption Rating

According to the results of the national Russian Business Anti-Corruption Rating
(arranged by the Russian Union of Industrialists and Entrepreneurs in 2022) the
Bank was assigned the highest A1 rating as a “Company with Maximum
Anti-Corruption Management and a Minimum Corruption Risk Level. Minimum Level of
Connected Threat for Investors, Lenders, Business Partners and Other
Stakeholders”.
Certificate of assignment of A1 Class to VTB Bank according to the 2022 Russian
Business Anti-Corruption Rating



--------------------------------------------------------------------------------


ANTI-CORRUPTION MANAGEMENT PLAN


The Bank has developed and implemented an Anti-Corruption Management Plan based
on the National Anti-Corruption Management Plan of the Russian Federation.


--------------------------------------------------------------------------------

--------------------------------------------------------------------------------


MANAGEMENT OF CONFLICTS OF INTEREST


Any display of corruptive conduct may be the reason for a conflict of interest.
Bank employees are obliged to independently assess the possibility of a conflict
of interest in their work.
In case of identification of a conflict of interest, including potential cases,
information about such conflicts of interest must be provided by employees to
the compliance unit on a mandatory basis.
The Bank expects its clients, counterparties and shareholders to comply with
established principles and requirements for management of conflicts of interest
and anti-corruption management, which aredocumented in contractual relationships
in accordance with the current market practice.


--------------------------------------------------------------------------------

If you have become aware of corruption violations or any conflict of interest in
the Bank

Please report such facts to us
Send report


Countering unfair practices on financial markets

Control in financial markets is an important area in any credit institution.
Countering market manipulation and insider trading is a necessary condition for
protecting a competitive environment, financial service consumer interests and
mutual trust among market participants.


Control in financial markets

The Bank's compliance unit continuously monitors observance of established rules
and actively prevents any potential market manipulation actions, including
distribution of unreliable information, performance of transactions by
arrangement and misuse of insider information.



--------------------------------------------------------------------------------


MEASURES FOR REDUCTION OF POTENTIAL RISKS


VTB takes into account Russian and international legislation requirements in its
activity and implements measures for reduction of potential risks of:
 * abuse on financial markets and transactions with insider information;
 * market manipulation.

The Bank ensures confidentiality of its insider information and information of
its clients and counterparties, controls related requirements and restrictions
for such information, conducts preventive action for such possible violations in
the area of illegal disclosure of insider information and market manipulation
and establishes respective internal rules and procedures that are mandatory for
employees.
The Bank participates in working groups of professional associations of the
Russian Federation.


--------------------------------------------------------------------------------

If you have become aware of illegal use of insider information or market
manipulation

Please report such facts to us
Send report


FATCA and CRS

The Bank's internal procedures are compliant with FATCA/CRS requirements.
The Foreign Account Tax Compliance Act (FATCA)
The Bank acts as a financial institution complying with the requirements of the
Foreign Account Tax Compliance Act (FATCA).

FATCA identifier
The Bank has an assigned FATCA identifier (Global Intermediary Identification
Number, GIIN): 3FZXN5.00000.LE.643.

The Common Reporting Standard (CRS) of the Organization for Economic Cooperation
and Development (OECD)
The Bank complies with the Common Reporting Standard (CRS) of the Organization
for Economic Cooperation and Development (OECD) for automatic exchange of
information about financial accounts. The respective standard norms were
included in the legislation of the Russian Federation (Chapter 20.1 of the Tax
Code of the RF, RF Governmental Regulation No. 693 dated 16 June 2018).


Regulatory risk management

Regulatory risk management system.

The Bank has estanlished a functioning regulatory risk management system.
All Bank employees participate in regulatory risk management within the
framework of their activity while the compliance unit organizes the regulatory
risk management system, monitoring and reporting.
VTB performs an annual high quality assessment of internal processes from the
perspective of regulatory risk exposure and efficiency of existing control
methods, it also develops and implements measures for mitigation of identified
risks. Our Bank uses quarterly monitoring of key indicators that enables timely
identification and proactive management of regulatory risks for high-risk areas.
The Bank has a regular collective authority body for regulatory risk management
that reports to the Bank’s Management Board, the President and Chairman of the
Management Board and conducts regular reviews and approves decisions on the most
important issues related to regulatory risks.
VTB Bank Compliance Policy
VTB Bank Compliance Policy
89 Кб



Compliance hotline for bank employees

The Compliance Hotline enables employees to send reports about known facts or
justified suspicions of violation of the legislation of the Russian Federation
and internal Bank regulations.
All bank employees are aware of the Hotline and its possibilities.
Confidentiality and security
The Bank ensures confidentiality and security of personal data of employees that
submit reports and we guarantee non-application of corrective action to
employees that dutifully notify about violations/potential violations committed
by other Bank employees.

Notification about committed/potential violations
Notification about committed/potential violations may be provided in the
following manner:
 * electronic form on the internal Bank corporate portal website;
 * dedicated email channel (including anonymous reports);
 * hard copy (including anonymous reports).


Reviewing reports the compliance
When reviewing reports the compliance unit aims to perform a complete,
comprehensive and objective analysis of the circumstances that served as the
basis for the report.
Corrective measures are applied when violations are detected.
The Bank provides a reply on the results of reviewing a report to the respective
employee sender.


Feedback

The Bank has a zero tolerance policy for any violations and abuse and will take
action against unreliable reports tarnishing the reputation of the Bank’s
employees.


Information about committed or potential violations and abuse

You can report information to the Bank about committed or potential violations
and abuse on the following subjects:
 * corruption;
 * conflict of interest;
 * misuse of insider information and market manipulation.

Dedicated Bank units ensure the review of each received report. Identified cases
will be promptly and carefully reviewed, responsible individuals will be held
liable for committed acts.

Send message

You can also submit a report to the following telephone numbers

1000

Toll-free from a mobile

8 (800) 100-24-24

Toll-free for calls within Russia

8 (495) 777-24-24

For Moscow and Moscow Region residents

 * 8 (800) 100-24-24
   
   Free calls from Russia

 * +7 (495) 777-24-24
   
   Moscow and the Moscow region

   All contacts

 * Offices and ATMs
 * Vacancies

 * About
 * VTB Group
 * Bank details
 * Press center

VTB Online

The bank is where you are

All VTB apps

© VTB, 2024
Bank of Russia General Licence №1000

Degtyarnyy Pereulok, 11a,
Saint Petersburg, 191144