Sberbank corporate standards. Business Ethics

The culture of traditional and modern organization.

The modern market situation is characterized by such processes that put forward special requirements for the corporate culture of the organization. Traditional management of an organization comes down to rational setting of goals, analysis of the current situation, namely, own resources (strengths and weaknesses of the organization) and environmental factors (opportunities and risks), and then decisions are made based on the goals set, taking into account the analysis. The modern culture of the organization does not involve the formulation of specific performance indicators of the company in the horizon of time, but the formulation of long-term competitive advantages. These advantages come down to the formation of the qualities of the organization, allowing it to be ready for any changes in the market, consumer demand and consumer behavior, the labor market, employee motivation, etc. The differences between traditional and modern corporate culture are also expressed in relation to management towards subordinates, in the participation of personnel in decision-making, the functioning of communication systems.

Traditional corporate culture Modern corporate culture
1. The position of an employee depends on his place in the hierarchy of the organization. 2. Workers are deprived of the right to make decisions and are only executors. 3. Disagreements are not allowed, conflicts are considered as destructive processes. 4. Cooperation between employees belonging to different departments is extremely difficult. 5. The dominance of "tunnel" vision: none of the workers sees the whole picture as a whole. 6. A significant part of the information is classified, so employees try to get it through informal channels. 1. The position of an employee in an organization depends on his knowledge, skills and abilities. 2. The employee has the right to make an independent decision within the limits of his work. 3. Relationships are not formal and differences of opinion and discussion are allowed, managers consider employees as partners. 4. Considerable attention is paid to the relationship in the group, where the spirit of cooperation and cooperation is strengthened. 5. The goals and objectives of the organization and organizational units are widely discussed among all members of the organization. 6.Priority is given to the development of a wide network of communications between all organizational units and their members. 7. Creation of powerful motivation among employees, based on non-economic motives associated with self-actualization, participation, etc.; acceptance by employees of the organization as a "place" of their self-realization of employees, and their activities as areas of personal growth

Sberbank is a good example of a modern type of corporate culture. The corporate culture in the bank is aimed at creating in each employee a sense of belonging to the fulfillment of the mission of the bank, the strategic tasks facing it. The Bank seeks to create conditions that allow each employee to develop and apply their creative abilities, improve the level of professional training, take part in solving organizational issues, etc. The organization is dominated by partnerships, with the presence of friendly sympathy. Employees of the organization consider themselves part of this organization, share its interests and corporate philosophy and feel supported by management. In addition, Sberbank is also characterized by the presence of a well-coordinated and efficient system of internal communications. The main instrument of internal communications is the Intranet portal, which contains a special section on PSS, sections of structural divisions and territorial banks, internal regulatory and information documents. The internal portal is the most important feedback channel from employees to the Bank's management. On the local network, employees receive a special mailing “Good morning, Sberbank” every day, and once a week - the bulletin “Sberbank. Day by Day”, which includes a brief overview of the key events of the Bank over the past week. Other internal communications tools include the monthly newspaper My Sberbank and information boards. The Bank has an open telephone line for employees' requests.

Tasks and functions of corporate culture.

1. Formation of a certain image of the organization. For Sberbank, this means maintaining the image of a reliable and financially stable organization. Accordingly, the task of corporate culture is to ensure that the organization is perceived both in the external and in the internal environment.

2. Maintaining the values ​​inherent in this organization. This function of corporate culture is dominant for Sberbank. The code testifies to this. corporate ethics employees, the purpose of which is to consolidate the corporate values ​​of the bank, ethical norms and rules of conduct for employees, ensuring and understanding by employees of their role in the implementation of the bank's mission to customers, shareholders and business partners.

3. The corporate culture of Sberbank is aimed at creating and maintaining among the employees of the organization a sense of belonging to a common cause, which gives meaning to their work in the organization.

4. Promoting the socialization of new employees, adaptive function. To adapt new employees, Sberbank has developed a set of measures designed to facilitate the process of entering a position and adapting to a new corporate culture. Newcomer's Book was created, which is an interactive media publication that contains all the basic information needed by new employees. Some regional banks conduct special training programs for beginners. In addition, there is a practice of assigning personal tutors from among colleagues with long-term experience in the Bank for the period of probation.

Structural-organizational and structural-functional parameters of corporate culture include:

Corporate values, that is, objects and phenomena of organizational life that are essential, significant for the spiritual life of employees.

Styles of behavior that characterize the employees of a particular organization. This also includes specific rituals and ceremonies, the language used in communication, as well as symbols that have a special meaning for members of this organization.

Norms - a set of formal and informal requirements imposed by the organization in relation to its employees.

The psychological climate in an organization that a person encounters when interacting with its employees. The psychological climate is the predominant and relatively stable spiritual atmosphere that determines the relationship of team members to each other and to work.

The corporate culture of the organization involves:

1. Awareness of oneself and one's place in the organization;

2. The presence of a communication system and a special language of communication;

3. Certain requirements for appearance, clothing and representation at work;

4. The presence of good relationships between people: the impact on interpersonal relationships of such characteristics as age, gender, nationality, status, amount of power, education, experience, knowledge. Compliance with formal requirements of etiquette or protocol; the degree of formalization of relations, the support received, the accepted forms of conflict resolution;

5. Development and self-realization of the employee;

6. Work ethic and motivation.

The corporate culture of Sberbank is characterized by openness, there is emotional support for the staff (creativity is manifested through cooperation), the presence of a mission of goals and values ​​supported by all employees of the organization, an open communication system, and requirements for the appearance and clothing of employees. Disdainful attitude towards anyone is unacceptable; in the organization, equally respectful attitude towards persons different ages and nationality. The bank considers the increase of responsibility and independence based on the introduction of professional training standards as an essential factor in personnel motivation.

The study of corporate culture: diagnosis and assessment of the state.

As a result of the new development strategy for the period up to 2014, within which the bank aims to further develop its competitive advantages and create new areas of growth, the organization's staff was partially replaced (middle-aged employees were replaced by young professionals). Young employees are more loyal to customers, they have fewer complaints and a higher speed of service. Significant resources are allocated to staff training, which allows achieving high professional results. The corporate culture has become more visual for the external environment, everything - the clothes of employees, the design of the halls - reflects the corporate white and green colors. True, the attitude towards customers and the quality of service are not yet at an appropriately high level, compared with the reputation of the organization.

However, Sberbank's corporate culture is quite strong. The core values ​​of the organization are strongly supported, clearly defined and widely disseminated. It has the utmost clarity of priorities, management informs employees about the tasks of the enterprise and actively involves them in solving these problems. The organizational culture of the Bank is focused on a personal approach and at the same time unites employees into a single whole.

Corporate culture, corporate identity and corporate image.

Corporate culture- is the sum of behavioral norms that define what should and should not be in the organization. Corporate culture is corporate values ​​and norms, written and unwritten rules by which the company lives.

The high-profile status obliges Sberbank to serve customers at a high level and determines the corporate culture. According to its own Corporate Governance Code, the bank sees the mission in meeting the needs of each individual client (both a private individual, and a corporate or public one). The emphasis is on both quantity and quality of service. Sberbank prioritizes respect for the legitimate interests and rights of customers and shareholders, ensuring the transparency of information, and maintaining the stability and profitability of operations. Sberbank positions itself as an organization seeking to combine internal and external corporate culture and provide high-quality and competent customer service by establishing appropriate relationships among employees. The Bank makes high demands on the level of training and qualifications of its staff and takes care of its continuous improvement. A part of the corporate culture of Sberbank is the holding of the All-Russian sports Sberbankiads twice a year, as well as various social activities.

Corporate sports are competitions of employees of enterprises and organizations in various sports. The main goal of corporate sports is to unite the team through increased physical activity to develop a team spirit. The promotion of corporate sports is based on the postulate of modern psychology: based on achieving the highest results in sports, company employees show leadership qualities in production.

The fire of the Sberbankiada is lit every year in different parts of Russia. Winter and summer sports competitions were held in Sochi, Ufa, Perm and Murmansk. Kazan is hosting the Sberbank Sports Forum this year. From July 15 to July 21, 2012, more than two thousand athletes from different regions of the country will come here, representing the teams of 17 territorial banks of Sberbank of Russia OJSC, the team of the central office of Sberbank of Russia OJSC, as well as teams of Sberbank subsidiary banks from Ukraine, Kazakhstan and Belarus . Sberbank employees will compete in more than ten sports: swimming and badminton, tennis and table tennis, Russian bast shoes, basketball, volleyball, chess, billiards, athletics and football.

Improving and strengthening the corporate culture in the bank is also aimed at creating in each employee a sense of belonging to the fulfillment of the mission of the bank, to the achievement by the Bank of high results, strategic tasks facing it, fostering a team spirit, creating a team of like-minded people aimed at achieving the set strategic goals.

The bank considers the increase of responsibility and independence based on the introduction of professional training standards as an essential factor in personnel motivation. The Bank seeks to create conditions that allow each employee to develop and apply their creative abilities, to improve the level of professional training. The Bank seeks to maintain the level of remuneration corresponding to the level of remuneration in the industry and adequate to the end result of labor. The Bank pays constant attention to the issues of protecting the health of employees and the safety of their work. When hiring, the possibility of discrimination on political, religious, national and other motives not related to professional qualities is excluded.

corporate identity of each organization consists in a unique combination of its values ​​and principles for realizing their imperative potential in practice. Values ​​are generalized ideas of people about the goals and norms of behavior that embody experience and express in a concentrated way the meaning of the culture of the social community. They can also be called the ability to satisfy certain needs of an individual or group. Organizational values ​​are what is valuable for the organization and the person in the organization, for which he is ready to act expediently.

The mission of Sberbank emphasizes the most important role of the bank in the Russian economy and a special social role in society - maintaining confidence, reliability and stability in it. The mission of the Bank clearly defines that its clients, their needs, dreams and goals are the basis of all activities as an organization. The mission also emphasizes how important its employees are for Sberbank and how it is impossible to achieve its goals without realizing the personal and professional goals of the people working in it. High goals are achieved by a team of like-minded people who are united by a common system of values. Sberbank's values ​​determine the set of rules, criteria, and requirements that will apply to every person who is or wants to become a member of the Bank's team. Sberbank's values ​​are a set of principles based on which the Bank's managers will set goals and determine whether they have been achieved. Based on these values, relationships between employees will be created and maintained, management systems within the Bank will be built, as well as the Bank's relationships with customers, society, shareholders and investors.

These values ​​include:

· Integrity

· The pursuit of excellence

Respect for traditions

· Trust and responsibility

・Integrity and professionalism

· Initiative and creativity

· Teamwork and performance

· Openness and friendliness

Healthy lifestyle (body, spirit and mind)

In relation to employees, Sberbank adheres to the following principles:

A bank that values ​​its employees takes care of them.

A bank that enables employees to develop personally and professionally, where the best professionals aspire to work.

A bank in which employees feel like active participants in all processes, and not "cogs in a big machine."

A bank that provides its employees with decent material wealth and position in society.

A bank that is fun to work for.

A bank where you can be proud of your work, which is respected, and whose employees are confident in their future.

In relation to its clients, Sberbank adheres to the following principles:

A bank that values ​​every client.

A partner bank that is ready to help each client every day in everything related to finance.

A bank you can trust: it is financially stable, it will not deceive you, it has fair conditions, it will provide fast and convenient service, it will help you choose and make the best financial decision based on the interests of the client.

A bank that is constantly working and improving to please its customers and improve its work.

Corporate image organization appears as a result of purposeful perception by the public of a complex of communication messages created by the company. The purpose of its creation is to ensure that the subjects outside and inside the organization have an image of this organization that contributes to the achievement of external goals and objectives set by its management.

In order to remain competitive, companies have to pay special attention to their image and reputation, and especially the visual aspects of the company's corporate image are important. Corporate image includes several concepts. In general terms, it can be defined as a positive and loyal attitude towards the company by its target audience. Corporate image is one of the means of solving external and internal problems of the organization.

One of the aspects of the visual corporate image is corporate identity. Corporate identity is one of the main ways of broadcasting the visual image of the company. A corporate identity is a set of graphic forms and principles of construction, united by one idea, the main task of which is to distinguish a company from its own kind and create a recognizable image in the eyes of consumers. The corporate identity of the organization includes: a set of color, graphic, verbal constants that provide visual and semantic unity of goods and services, all information coming from the company, its internal and external design. Corporate image or corporate identity is the basis of the company's communication policy. Based on the corporate image, relationships with the audience are built, the way they unconsciously perceive the company. With the help of corporate identity, the company stands out among its peers. The main components of corporate identity are color and shape. The basis of corporate identity is the logo. Anything can be a carrier of style: internal documentation, outdoor advertising, a website, an office building, employee uniforms. Since employees communicate with customers on a daily basis, the color scheme of the uniform is of great importance.

The color environment directly affects the emotional and psychophysical state of people. Color is very important in shaping the visual corporate image of an organization. It is perceived not only visually, but also psychologically and emotionally. Different shades of colors have different psychological effects on people, depending on which color is dominant. Knowledge of these features can help both in communication and in building a visual corporate image.

The main goal of Sberbank's corporate image is to maintain the image of a serious company with a long history. Corporate identity should inspire consumer confidence in the company and confidence in its actions. Because the main thing for a bank is to broadcast reliability and stability in any financial conditions.

There are two colors in the corporate identity of Sberbank: green and white.
Green is the calmest color. It does not have kinetic energy acting outward, but contains potential energy enclosed in itself. It promotes life, growth, harmony, unites people with nature, helps to be closer to each other, gives self-respect, firmness, naturalness, justice, develops willpower, constancy. Green is soothing nervous system.
White is the so-called achromatic color along with black and shades of gray. White is the sun, air, insight, purity, impartiality. Meaning white color- the color of goodness, good luck, the color of purification and multiplication.

The company name and logo are in green, while the uniforms of the employees are a white shirt and a green tie. The green color is chosen very well for the company logo, and it is also present in the uniforms of the employees. Green is the bank's confidence in the future, a stable position in any financial conditions. The green color favorably emphasizes the existing image of Sberbank as one of the oldest banks in Russia, with a high level of consumer confidence. Also, this color reflects the above values ​​of the company, such as respect for traditions and goodwill, a healthy lifestyle. There is only one drawback of the green color in the company logo - this color does not prompt action, it is static.
White represents purity and a new beginning. For a bank, this explanation of color is quite suitable. With a bank, people can start a new life, with a loan, for example. White color helps to solve all problems - Sberbank strives for the same in its image. After all, most of the serious problems of people are associated with a lack of Money. White color makes people feel reliable, incorruptible. White color in the corporate style of Sberbank carries a similar meaning with green. For the company, he personifies incorruptibility, justice, good luck. Employees in white uniforms are more trusted, because in the subconscious of people, white means stability, purity of thoughts. The lack of white in the uniform of employees is that some people are afraid of people in white clothes, as they associate them with doctors and with some kind of officialdom.

In combination with white, green becomes even more calm, soft. This combination of colors has a positive effect on the emotional state of the target audience, which includes both employees and consumers. The uniform of these colors helps employees to be calm, balanced, honest, polite. For consumers, the combination of white and green also helps to make a more balanced and considered decision in the bank, to calm down.

Sberbank follows the company's values ​​even in the color scheme of the corporate identity. The meaning and symbolism of colors also coincides with the already created image. The colors confirm this image as the oldest bank with the highest level of trust among the population.

brand culture. Corporate brand and corporate reputation

Corporate culture and corporate identity is significant for commercial organizations. This phenomenon makes it possible to realize the goals of branding and achieve its successful formation. Recognition, a positive image, a good reputation, an effective impact on perception and consciousness - all this is necessary to create a successful brand and all this is formed in the process of developing a corporate culture and corporate identity. Thus, the goals of branding for the most part coincide with the goals of forming a corporate culture and corporate identity.

The corporate culture and corporate identity allows creating a high brand value in terms of money, while being clearly expressed in transactional value. Thus, corporate culture and corporate identity contribute to the realization of branding goals. They are able to form a recognizable external and internal image, influence the popularity of the brand and bring it to the level of the brand, increase the value of the brand. Of particular importance, in turn, is the brand for the organization. It enhances its tangible and intangible assets, forms a positive image of the organization and other brands. As a result, brand and corporate culture and corporate identity are inextricably linked.

Sberbank of Russia is of particular interest as a successful brand in the Russian banking market.

· Took first place in the recognition and fame ratings of Russian banks published by the National Agency for Financial Research (NAFI). According to the agency, the recognition of Sberbank in Russia is 96%, the popularity is 86%.

· In the BrandFinance® Global 500 2011 ranking of the world's most valuable brands, compiled by the Brand Finance consulting company, Sberbank ranked 65th and became the most valuable Russian brand. The brand is valued at $12 billion.

Reliability and impeccable reputation Sberbank of Russia is confirmed by the high ratings of the leading rating agencies. Sberbank of Russia has been assigned a long-term foreign currency default rating of BBB by Fitch Ratings, and a long-term foreign currency deposit rating by Moody's Investors Service. In addition, Moody's assigned the Bank the highest rating on the national scale.

The study showed that Sberbank occupies the leading position in the reputation rating of banks, far ahead of other market players. Its reputation index was 60. A certain role in shaping such a high level of Sberbank's reputation was also played by the fact that at the time of the study it was in the focus of public attention, which directly affected the number of mentions in the media. The results of the survey showed that among the representatives of the low-income group, the examined banks have reputation indices lower than in Russia as a whole. The first two places in the low-income group were occupied by Sberbank and Alfa-Bank, their indices were 53 and 31, respectively. In the high-income group of the population, the opposite situation has developed - almost all banks have higher reputation indicators compared to the average sample, which indicates a higher level of trust. And in the highly profitable group, Sberbank remained the leader in terms of reputation. Among the population with an average income, Sberbank, Rosbank and VTB have the best reputation. Their GRI indicators in this population group are higher compared to the average sample. There is an absolute pattern in the fact that Sberbank has become the leader in the reputation rating. The reliability of the company for the consumer is, first of all, its size, duration of work on the market and active presence in the information field. In addition, people in Russia are accustomed to trusting companies that are supported by the state. In the current situation in the financial markets, and taking into account the Russian mentality, we can confidently predict further growth in the reputational capital of banks with state participation.

Formation of corporate culture and corporate leadership

In general, organizational culture is the result of the interaction of the desires and passions of the founders of the company and the basic attitudes of employees that they have acquired as a result of their previous experience.

The subjects of corporate culture (in the narrow sense) are corporate leaders and the corporate elite. Leadership and culture are closely related, since leadership at its core is attitudes and motivation that encourages a person to study culture and manage it. As a rule, the founders of the organizational culture are the founders of the organization, because, when creating a company, they also try to create its ideal image.

E. Shane presents us with the process of establishing a corporate culture through the activity of a leader: the founding leader puts forward the idea of ​​creating a new organization; the founder attracts a group of like-minded people to implement his plan; the leader and a group of his associates (founders) begin coordinated activities to implement the organization's project (patenting, registration, etc.). Like a living organism, a corporate culture, according to Shane, is born, grows, becomes mature and even ages when it loses the potential to move forward. And at all these stages of the life of an organization and its culture, leadership is a decisive factor in adaptability and stability.

The process of formation of corporate culture by leaders and elites is tied to the life cycle of the organization. In relation to corporate leadership, Sberbank goes through the following stages:

1st stage- Creation of an organization. Sberbank was at the stage of formation, the formation of the life cycle of services. At this stage, all the morals, customs, the main style of activity, as well as the success or failure of the organization that were subsequently adopted in the organization, were laid down by its founders. In their activities, they were guided by previous experience in creating the organization and its cultural values. Thus, organizational culture was the result of the personal assumptions and biases of its founders.

2nd and 3rd stages - growth and growth retardation. The culture was supported by the customs and procedures that existed in the organization, which formed the appropriate experience for the personnel. The organizational culture was consolidated and formalized by personnel management procedures: personnel selection and evaluation; reward system; system of motivation and incentives; education; career advancement. All these procedures were aimed at maintaining those who fit this organizational culture and weeding out others.

Stage 4 - maturity. At this stage, the effectiveness/ineffectiveness of the integrating role of the corporate culture was diagnosed.

Stage 5 - new growth. The adequacy of the values ​​declared in the organization to the new business tasks was checked. Now Sberbank is at this stage of development. New goals are set for the transition to a new stage in the development of the organization and there is a need to reorganize the corporate culture. It was at this stage that the management of Sberbank came to the conclusion that the organization needed rebranding and strengthening of the corporate culture in the organization.

The most common (cultural) tasks of a corporate leader are as follows:

· Strives for a more efficient use of human resources and focuses primarily on the "human factor", and not on material gain;

· ensures the consolidation of the social forces of the team, intellect, abilities, energy and enthusiasm of people;

· takes an active position in the implementation of innovations, mobilization of people to update the organization.

To carry out this activity, the management of Sberbank conducted a new leadership development program. In August 2011, Sberbank of Russia launched the educational program Sberbank 500 - Program for Leaders. It is a one-year training course developed jointly by specialists from the Sberbank Corporate University, the leading Western business school INSEAD, and the Russian School of Economics. Within the framework of the program, about 500 heads of the Central Office and territorial banks of Sberbank will be simultaneously trained. Priority in recruitment for the program was given to regional banks (more than 90% of participants).

The main goal of the Sberbank 500 program is to bring up-to-date knowledge of management and business to the middle managers of Sberbank and improve the overall management level of the management team.

Goals, objectives and structure of the symbolic management of the organization

Symbolic management is understood as actions, behavior, dramatizations that, without further ado, become clear to others, unambiguously explain the essence of the matter, declare new priorities and place emphasis.

In world business practice, there is an experience of compiling by firms their own codes of honor, or codes of business conduct. Common to most of them is the principle of respect for the honor of their own company. To protect the honor of the company, to protect and defend its interests, to bear responsibility for actions discrediting the company - requirements that are equally addressed to all its members.

Like most international organizations, Sberbank has its own Corporate Governance Code. The purpose of the introduction of this Code is to form and implement in the daily practice of the bank's activities the appropriate norms and traditions of corporate behavior of Russian business that meet internationally recognized standards based not only on unconditional compliance with legal requirements, but also on the application of ethical business conduct standards common to all members of the business community.

Following the norms of this document is aimed not only at creating a positive image of the bank in the eyes of its shareholders, customers and employees, but also at controlling and reducing risks, maintaining a steady growth in the bank's financial indicators and successfully implementing its statutory activities.

The provisions contained in this document have been developed on the basis of federal law“On Joint Stock Companies”, Charter of the Joint Stock Commercial Savings Bank Russian Federation(open joint stock company), “Concepts for the Development of Sberbank of Russia until 2005”, “Principles of Corporate Governance of the OECD”, “Code of Corporate Conduct” developed by the Federal Commission for the Securities Market, “Code of Ethical Principles of Banking”, approved by the XII Congress of the Association of Russian banks.

In companies with a strong organizational culture, such as Sberbank, managers play a leading role in maintaining and shaping it. They can be called conditionally "symbolic" managers. "Symbolic" managers differ from conventional ones in that they:

· Receptive to culture and aware of its importance for long-term success. They always talk about their company's culture, write about it in annual reports, and turn the power of culture into market success;

· trust employees to a high degree and rely on their commitment to success. The motto of Sberbank, as a company with a strong corporate culture, is “we will win because we are special”;

· are aware of the effectiveness of this approach and strive to concentrate the efforts and initiative of others on achieving goals;

· perceive themselves as actors, screenwriters, directors - participants in everyday events taking place in the company. They create symbols of the culture of the organization both purposefully, when working in the field of OP and general corporate philosophy, and spontaneously, under the influence of current events.

Thus, the "symbolic" manager is suitable for situational, command and other forms of management based on self-management, while the "rational" manager is suitable for management by goals, authoritarian and systemic management. The main problems of "symbolic" management are:

Inattention to global changes in the external environment;

Excessive arrogance of the manager and the team; tendency to make hasty decisions;

Government of the Russian Federation

State educational budgetary institution

"State University -

High School of Economics"

Faculty of Management

discipline program

for direction 080500.68 "Management"

Chairman department

"_____" __________________ G. "" ____________ G

Approved by the RS of the faculty

management

Scientific Secretary

" ____" ___________________ G.

Moscow 2012

Topics in Stakeholder Ethics

Instructor: Ryan Burg

Email: *****@***ru

Office: 33/5 Kirpichnaya str. Office 805

Office hours: Friday 3:00-4:00 pm and by appointment.

COURSE DESCRIPTION AND OVERVIEW

The field of business ethics focuses on moral conflict within and around economic organizations.

Many of the moral issues of organizational life concern specific organizational constituencies, commonly known as stakeholders. These constituencies enjoy different entitlements and constraints within modern corporate cultures, and their relative status is a question of consequence in both empirical and normative research.

This class considers a number of important debates regarding the identification of stakeholders and their treatment within the firm. After three introductory sessions, each subsequent class will focus on a specific stakeholder group and a set of relevant considerations that pertain to that group. Though the class covers most of the dominant stakeholder groups, its intended focus is not a comprehensive survey of the field of business ethics. Instead, the class seeks to encourage students to begin to engage and develop research questions and methods for answering them.

To that end, students are asked to prepare a one-page research proposal for each class session, and to actively participate in discussions on the articles assigned for the session. Along the way, students will collaborate with the instructor by conducting, transcribing, translating, and evaluating one tandem interview on an active research project.

Students will be evaluated based upon their participation and the quality of their work.

Evaluations will be based upon three work products: weekly research proposals, a collaborative interview exercise write-up, and a final exam.

CLASS SCHEDULE

No readings due to class.

Research Proposal Due

Donaldson, Thomas and Lee E. Preston. 1995. “The Stakeholder Theory of the Corporation:

Concepts, Evidence, and Implications.” Academyof Managementreview, 20(1): 65-91.

Freeman, R. Edward, “Stakeholder Theory of the Modern Corporation.” In Ethical Issues in Business, 7th Edition, edited by Thomas Donaldson, Patricia H. Werhane, and Margaret Cording, 38-49. Upper Saddle River, NJ: Prentice Hall.

Jensen, Michael C. 2002. “Value Maximization, Stakeholder Theory, and the Corporate

Objective Function.” Business Ethics Quarterly.: 235-256.

Jones, Thomas M. 1995. “Instrumental Stakeholder Theory: A Synthesis of Ethics and

economics.” Academyof Managementreview. 20 (2): 404-437.

Phillips, Robert. 2003. “A Principle of Stakeholder Fairness.” In Stakeholder Theory and

Organizational Ethics. San Francisco: Berrett-Koehler Publishers, Inc. 85-118.

Research Proposal Due

Asher, Chery l Carleton. James. M. Mahoney and Joseph T. Mahoney. 2005. “Towards a Property Rights Foundation for a Stakeholder Theory of the Firm.” Journal of

management and government, 9: 5-32.

Heath, Joseph. 2009. “The Uses and Abuses of Agency Theory.” Business Ethics Quarterly 19 (4): 497-528.

Kacperczyk, Aleksandra. 2009. “With Greater Power Comes Greater Responsibility? Takeover Protection and Corporate Attention to Stakeholders.” Strategic Management Journal. 30: 261-285.

Mitchell, Ronald K., Bradley R. Agle, and Donna J. Wood. 1997. “Toward a Theory of

Stakeholder identification and Salience: Defining the Principle of Who and What Really

counts.” Academy of Management Review.: 853-886.

Research Proposal Due

Bebchuck, Lucian Arye and Jesse M. Fried. 2003. “Executive Compensation as an Agency Problem.” Journal of Economic Perspectives,: 71-92.

Dobbin and Jung (Unpublished). “Which Theories do Markets Perform?”

Westphal, David and Ithai Stern. 2007. “Flattery Will Get You Everywhere (Especially If You Are a Male Caucasian): How Ingratiation, Boardroom Behavior, and Demographic

Minority Status Affect Additional Board Appointments at U. panies.” Academy of

Management Journal, 50(2): 267–288.

Research Proposal Due

Locke, Richard M. 2002. “The Promise and Perils of Globalization: The Case of Nike.” MIT Industrial Performance Center Working Paper.

Phillips, Robert A. 2010. “Ethics and Network Organizations.” Business Ethics Quarterly. 20 (3): 533-543.

Spar, Deborah L. 2002. “Hitting the Wall: Nike and International Labor Practices.” HBS Case.

Research Proposal Due

Green, Sandy Edward Jr. 2004. “A Rhetorical Theory of Diffusion.” Academyof Managementreview. 29 (4): 653-669.

Hirschmann, Albert O. 1970. Exit, Voice, and Loyalty: Responses to Decline in Firms,

Organizations, and States. Cambridge: Harvard University Press. 1-43.

Marens, Richard S., Andrew C. Wicks, and Vandra L. Huber. 1999. “Cooperating with the Disempowered: Using ESOPs to Forge a Stakeholder Relationship by Anchoring

Employee Trust in Workplace Participation Programs.” Business & Society. 38(1): 51-82.

Research Proposal Due

Fuller, Robert W. 2003. Somebodies and Nobodies: Overcoming the Abuse of Rank. Gabriola Island, British Columbia: New Society Publishers. 1-43.

Smith, Vicki. 1994. “Braverman’s Legacy: The Labor Process Tradition at 20.” Work and

occupations, 21 (4): 402-421.

Van Buren, Harry J. III, Michelle Greenwood, and Cathy Sheehan. 2011. “Strategic Human Resource Management and the Decline of Employee Focus.” human resources

management review, 21: 209-219.

Research Proposal Due

Braithwaite, John. 2005. “Competition Policy and Efficient Vice” and “Tax Systems in Crisis.”

In Markets in Vice, Markets in Virtue. New York: Oxford University Press. 1-34.

Danneels, Erwin. 2003. “Tight-Loose Coupling with Customers: The Enactment of Customer Orientation.” Strategic Management Journal,: 559-576.

Dunfee, Thomas W. and Daniel E. Warren. 2001. Is Guanxi Ethical? A Regulatory Analysis of Doing Business in China.” Journal of Business Ethics, 191-204.

Prahalad, C. K. 2006. “The Innovation Sandbox.” Strategy+Business 44: 1-10.

Vogel, David. 2010. “The Private Regulation of Global Corporate Conduct: Achievements and Limitations.” Business & Society: 68-87.

Research Proposal Due

King, Brayden G and Sarah A. Soule. 2007. “Social Movements as Extra-institutional

Entrepreneurs: The Effect of Protests on Stock Price Returns.” Administrative Science

Quarterly, 52: 413-442.

Lonkila, Markku. 2011. Networks in the Russian Market Economy. Palgrave Macmillan.

(especially 48-76).

Robertson, Diana C. 2009. “Corporate Social Responsibility and Different Stages of Economic Development: Singapore, Turkey, and Ethiopia.” Journal of Business Ethics, 88: 6

Research Proposal Due

Phillips, Robert A. and Joel Reichart. 2000. “The Environment as a Stakeholder? A Fairness Based Approach.” Journal of Business Ethics, pp. 185-197.

Stone, Christopher D. 1972. “Should Trees Have Standing?--Toward Legal Rights for Natural Objects” Southern CaliforniaLaw Review, 45: 450.

Final grades will reflect overall performance in the class, including engagement in classroom discussion and performance on written assignments. The percentage weights used in calculating course grades are as follows:

23% Participation

27% Research Proposals

20% Collaborative Interview

With the exception of clerical errors, there will be no change of grades after posting.

PARTICIPATION

Class participation is an important part of the seminar. Students will gain points for

demonstrating effort in understanding the readings and course materials and from sharing research findings. Students will lose points for missing class or coming unprepared. A note on language: this course is taught in English. If students do not understand a word or concept, they are encouraged to ask questions about the specific vocabulary that they missed or to ask the instructor to repeat as is necessary.

RESEARCH PROPOSALS

In order to encourage students to develop an aesthetic for good research, students are expected to bring a one-page research proposal to every class pertaining to the day’s topic. The proposal should introduce a research question, explain why the question matters, and briefly describe how one might answer the question. Though an exhaustive search is not necessary every student should run an online search to determine the novelty of his or her idea. Creativity, methodological novelty, and alternative research designs are encouraged. If students wish to propose cross-cultural comparisons as research projects, they must clearly explain why such comparisons are worthwhile.

COLLABORATIVE INTERVIEW

Students will conduct one interview with their instructor as a part of an ongoing research project.

After the interview, students will transcribe, translate, and critique the interview process.

Students will be responsible for finding the person to be interviewed and arranging a time to conduct the interview with the instructor. The goal of this exercise is to provide some worthwhile exposure to the research process, to learn about listening as a means of moral awareness, and to better understand the complexity of business norms.

FINAL EXAM

The final exam will cover class topics with special emphasis upon the readings and class discussions. The exam will include both multiple choice and essay questions.

transcript

2 MISSION AND VALUES We give people confidence and reliability, we make their lives better by helping them realize their aspirations and dreams. Our values: Guidelines that help us make the right decisions in any situation: I AM THE LEADER We take responsibility for ourselves and for what is happening around us. We do the best we can. We are constantly developing and improving ourselves, the bank and our environment. We are honest with each other and with our clients. WE ARE A TEAM We readily help each other, working for a common result. We are open and trust our colleagues. We treat each other with respect. We help our colleagues grow and develop. EVERYTHING FOR THE CLIENT All our activities are built around and for the sake of the interests of our clients. We want to surprise and delight customers with the quality of our services and our attitude. We exceed our clients' expectations.

3 LETTER FROM THE CHAIRMAN OF THE SUPERVISORY BOARD OF PJSC SBERBANK 4 LETTER FROM THE PRESIDENT, CHAIRMAN OF THE BOARD OF PJSC SBERBANK 5 1. ABOUT THE CODE OF ETHICS For whom is the Code intended? Follow the Code - Do the Right Thing Additional Responsibilities of Managers (“Tone from Above”) Ethical Conflicts and Whistleblowing Reporting Violations Immediately ETHICAL WORK ETHICAL WORK Customer Relationships Bank as Employer Working Atmosphere Health, Safety and Health Appearance Standard ( "dress code") followed by the Bank's employees Protection of the Bank's assets and frugality Conflict of interest Collaboration of close relatives Work outside the Bank, participation in the authorized capital and management bodies of third parties Gift exchange and entertainment expenses Use of the services of the Bank and counterparties Risk culture COMMITMENT TO ETHICAL BUSINESS PRACTICES Fair competition Anti-corruption Anti-money laundering and anti-terrorist financing Operations using insider information and market manipulation DISCLOSURED INFORMATION Transparency of business conduct Reliability of reporting Public communications Protection of confidential information Communication in social networks RESPONSIBLE LEADERSHIP Shareholders Participation in public and political activities. Charity and Sponsorship Government Relations Promoting Economic Progress and Social Welfare Respect for Human Rights Protecting the Environment FINAL PROVISIONS Responsibility for Violating the Code Amending the Code 61 SYMBOLS: WHAT DOES IT MEAN FOR ME? IMPORTANT QUESTIONS AND ANSWERS ADDITIONAL 2 3

4 LETTER FROM THE CHAIRMAN OF THE SUPERVISORY BOARD OF PJSC SBERBANK LETTER FROM THE PRESIDENT, CHAIRMAN OF THE BOARD OF PJSC SBERBANK Dear colleagues! Bankers and financiers at all times attached particular importance not only to the business, but also to the moral qualities of the representatives of their profession. Accuracy and accuracy, responsibility and loyalty to the given word, knowledge and compliance with laws play a fundamental role in the financial world. All these requirements are reflected in the Code of Corporate Ethics of Sberbank, which takes into account both international experience and the specifics of Sberbank, the largest bank in Russia. The Code establishes requirements for professional activities, teamwork, relationships with partners, clients and society. Sberbank is distinguished not only by its scale; it enjoys a high level of customer confidence. This trust is an invaluable capital that is made up of the actions of employees and managers. Therefore, each of us must follow the values ​​of the Bank, the principles of morality and standards of corporate ethics in our daily work. The Supervisory Board supports the Code and considers it important to show commitment to the high standards of corporate ethics of Sberbank by personal example. Sincerely, S. M. IGNATIEV Dear colleagues! Here is the Code of Corporate Ethics of the Sberbank Group. This is a set of the most important rules of conduct and business principles adopted by our team. The Code is intended for everyone who works at Sberbank and represents its interests in Russia and abroad. It is based on our mission and values, high professionalism, respect for clients and colleagues, strict compliance with the requirements of the law and the Bank's internal policies, unacceptability of corruption and any other illegal actions. For me, as well as for every member of the Sberbank team, adherence to the Code is an indispensable condition of work, on which the trust of customers, the reputation of the Bank, and hence its successful long-term development depend. At the same time, it is my duty, and the duty of all the leaders of the Bank, to set an example of impeccable behavior and maintain an atmosphere of open communication in the team, in which adherence to the principles of ethics is a priority in any situation. If you have a question about the ethics of a particular decision, be sure to ask your manager or special information lines for help. Never disregard the rules of the Code and remember that the success of the Bank depends on each of us members of the Sberbank team of over 300,000 employees in 22 countries. Only by joint efforts can we achieve the lofty goal we set ourselves to make the Bank one of the best financial companies in the world. Sincerely, G. O. GREF 4 5 APPEAL

5 1. ABOUT THE CODE OF ETHICS 1.1. WHO IS THE CODE FOR? The Code of Corporate Ethics of Sberbank (hereinafter referred to as the Code of Ethics, the Code) reflects the standards of conduct adopted by the Bank, based on our mission and values, guaranteeing honest and fair treatment of our team members, customers, partners, as well as compliance with laws and internal policies. The Code will help you recognize situations that do not comply with the ethical principles of Sberbank in time. The Code will tell you what to do if you have questions about ethical behaviour. Remember that the daily work of each of you, your actions and decisions are reflected in the attitude towards the Bank, its reputation. Throughout the Code, you will see self-assessment questions in the “What does this mean to me?” sections, as well as examples of how the Code can be applied in practice in the “Questions and Answers” ​​sections. The Code of Ethics is intended for each member of the Sberbank team: all employees of the Bank, regardless of their position, as well as members of the Supervisory Board. We welcome and encourage Sberbank's partners, counterparties, and clients to follow ethical standards adopted by the Bank. If you involve third parties to work with Sberbank, make sure that the partner has the due reputation and shares the ethical standards reflected in the Code. The Code establishes uniform principles of business ethics and business conduct for all companies of the Sberbank Group, regardless of their location. Sberbank Group companies may develop their own Codes of Ethics based on the provisions of the Code and applicable law. Q: What do the Bank's statements that it conducts business in an honest and open manner and complies with the requirements of business ethics mean? A: This means that we strive to work honestly and openly with clients, contractors, partners and colleagues. None of the employees should use their official position for personal purposes, as well as receive undue advantages for themselves or other persons. 7 ABOUT THE CODE OF ETHICS

6 1.2. OBSERVE THE CODE DO THE RIGHT THING Do I always follow the Code in my work? Am I acting "bypassing" the accepted requirements? Have I contacted my manager or the Bank's information lines when I had doubts about compliance with business ethics? Sberbank operates in many regions of the world. Our team members are citizens of many countries, as a result of which the Bank's operations are subject to many different laws, customs and cultures. In our work, we must comply with all applicable local laws and regulations in addition to the Code. Compliance with the provisions of the Code is mandatory for all members of the Sberbank team; this is an essential condition for the work of each of us. In some cases, certain provisions of the Code may conflict with local laws. If you encounter a conflict and local laws are more restrictive, please follow the local laws. EACH MEMBER OF OUR TEAM IS OBLIGED: to comply with the requirements of the law. If you notice any violation of the law, or you are asked to take an action that, in your opinion, may lead to their violation, immediately report this to your line manager or to the existing information lines; get acquainted with the provisions of the Code of Ethics and be guided by them in daily work, avoid inappropriate behavior; attend training courses organized by the Bank on certain issues of the Code; know and comply with the provisions of the internal policies applicable to your work. You, of course, may not remember by heart the provisions of all the Bank's regulatory documents, but you must understand the principles laid down in the documents and know which document you need to check with if necessary; treat co-workers with respect, provide support to new employees; perform official duties efficiently and on time, strive to find the best solution, be responsible for the result of their work; admit their mistakes, report them to managers and colleagues in order to minimize possible negative consequences; assist in the Bank's investigations into the facts of possible violations; seek help from your line manager or the information line if you have questions about the application of the Code or concerns about ethical compliance. If you have contacted your line manager and the issue is not being resolved, you will find further in the Code detailed description other means of reporting a problem. 8 9 ABOUT THE CODE OF ETHICS

7 1.3. ADDITIONAL RESPONSIBILITIES OF LEADERS (“TONE UP”) As a leader, do I create an atmosphere of trust in the team in which any ethical issues can be discussed? not give employees instructions that violate the requirements of the law, the Code or other principles of business ethics; ensure active interaction of subordinate employees with the authorized divisions of the Bank on ethics issues, provide support to employees who, in good faith, initiate discussion of ethical issues; immediately take measures to eliminate violations of the principles of ethics, as well as take the necessary measures of influence; take into account compliance by employees with the requirements of the Code and the contribution of employees to the formation of a culture of behavior in the Bank when assessing them. Bank leaders have the added responsibility of creating and maintaining a culture of conduct where employees know and understand their responsibilities and freely communicate their concerns and concerns. MANAGERS AT ANY LEVEL SHOULD: by personal example show adherence to the principles of ethics; ensure that subordinate employees are familiar with the provisions of the Code, understand and comply with the principles of the Code, including the understanding that commercial or financial results cannot be more important than ethical behavior; Q: What does the term "open communication environment in the team" mean? A: An open team environment is an open and trusting team environment where employees can discuss any ethical issues without fear and leaders listen to their opinions. However, this term does not mean that you can freely disclose internal, proprietary, confidential, insider information, personal data of employees and other non-public information of the Bank, its customers and third parties. create an environment of open communication in the team, in which each employee feels comfortable bringing up a particular issue for discussion; ABOUT THE CODE OF ETHICS

8 1.4. ETHICAL CONFLICTS AND REPORTING VIOLATIONS WHEN YOU HAVE DOUBT AS TO ACT IN THIS SITUATION, ASK YOURSELF THE FOLLOWING QUESTIONS: 1. Does this decision or action (inaction) comply with the law, the Code of Ethics, or other internal policies of the Bank? YES 2. Is this decision or action (inaction) logical and justified from the point of view of the interests of the Bank? YES 3. Were the interests of all persons who may be affected by it taken into account when making a decision or taking an action (inaction)? YES 4. Are you sure that this decision or action (inaction) will not have a negative effect on the Bank's reputation? YES NO NO NO NO SEEK ADVICE SEEK ADVICE SEEK ADVICE SEEK ADVICE qualified advice. You can also ask for clarification on the information line. If you think your manager is involved in questionable activity, contact your superior. Any employee who asks questions, seeks advice, reports a violation in good faith, acts in accordance with the Code. The Bank guarantees that an employee will not be subjected to any punishment for reporting a violation in good faith and for reasonable demands that other employees comply with ethical standards. All information received from an employee is checked in compliance with the confidentiality regime, and revealed violations are investigated in accordance with the procedures established by the Bank. The employee has the right to maintain the anonymity of his oral and written appeal. If an employee was involved in actions that are contrary to the Code, but voluntarily reported a violation, such actions will be taken into account by the Bank when considering the issue of liability. At the same time, measures may be taken in accordance with the law in relation to an employee who deliberately provided distorted, knowingly false information. We understand that sometimes it is difficult to make the right choice, so we encourage everyone to openly discuss ethical issues. 5. Will you be able to explain and justify to colleagues and/or regulators this decision or action (inaction), including after a certain period of time after its adoption? YES NO GET ADVICE ABOUT THE CODE OF ETHICS

9 1.5. VIOLATIONS TO REPORT IMMEDIATELY The Bank encourages the development of an atmosphere of trust in the team in which any ethical issues can be discussed. However, there are violations that must be immediately reported to the information line: offering or receiving a bribe, promising to give a bribe, other violations of the Bank's Anti-Corruption Policy; cases of fraud; actions aimed at distorting reporting; actions that carry significant risks of loss of business reputation or legal risks for the Bank, such as violation of the rights of customers and investors, transactions using insider information, laundering of money obtained by criminal means and financing of terrorism; violations of ethical standards, as a result of which harm has been or may be caused to an employee/employees or the Bank, and the motives for informing are related solely to the desire to prevent or stop harm. Q: I believe that my colleague's actions violate the requirements of the Code and may damage the reputation of the Bank. A colleague responds evasively to my recommendations to follow the principles and comply with the requirements of the Code. I'm going to report my suspicions anonymously to the reporting line. Can I do this? A: Yes, you must report any incident or suspicion of possible violations of the Code to the Bank's information lines in any way: by phone or e-mail. In the case of an anonymous report, sufficient information must be provided to enable it to be verified in a timely manner ABOUT THE CODE OF ETHICS

10 2. COMPLIANCE WITH ETHICAL PRINCIPLES AT WORK We value our reputation, observe ethical principles and fulfill our obligations at all times and in all circumstances. We treat colleagues, clients, partners and other persons with whom we interact with respect and benevolence. We are responsible for the results of our work and for the surrounding working atmosphere RELATIONSHIPS WITH CUSTOMERS Relationships with customers are the foundation of our business. We are here to provide a service to our clients that is guided by the principles of honesty, openness and fairness. The development of our clients' business is the main condition for the development of the Bank's business. We always strive to meet the highest standards of service, to provide professional services. We apply an individual approach to everyone, as it is important for us that the client feels safe and confident. Each employee of the Bank fulfills the promises given to clients, promptly responds to requests, is personally responsible for the results of his work, admits mistakes, learns lessons and takes actions necessary for the quality performance of his duties, gives comprehensive advice that does not mislead clients, and informs clients about possible risks. Feedback from our customers is an integral part of our development and self-improvement. Working with appeals, we immediately take measures to quickly resolve the difficulties that have arisen and prevent the occurrence of similar situations in the future. Feedback on our work is highly valued and taken seriously as it enhances the quality of our products and services and keeps our customers loyal. Working with information about customers, we take care of its safety. Access to the specified data is due to operational necessity and is limited to the Bank's personnel who are endowed with the appropriate authority. 17 ETHICAL WORK

11 2.2. BANK AS AN EMPLOYER Q: In the process of discussing the transaction with the client, it became clear to me that the client does not fully understand the inherent risks of a financial product. What are my actions? A: It is strictly forbidden in the Bank to take any actions that may have Negative influence on the financial interests or reputation of the client, including using the client's ignorance or limiting his access to information. Therefore, you need to provide the customer with information about the product, indicating all the features. The Sberbank team is our main competitive advantage, so we strive to make the Bank the best place for people of different generations and with different needs to work. The Bank strictly complies with labor laws, stands for a reasonable balance between work and personal life of employees, respects their obligations outside of work. Based on the principles of fairness and meritocracy (when the success of employees depends, first of all, on their abilities and diligence), we guarantee our team members decent wages and equal opportunities for career development in accordance with the results of personal performance assessment. Such an assessment takes into account not only the effectiveness, but also the compliance of employees with our key competencies: “I am a leader”, “We are a team”, “Everything for the client”. It is a Bank practice for managers to provide regular feedback to their subordinates on evaluation results. In order to improve the level of social security of employees, we are constantly developing a system of corporate benefits and privileges. It includes, among other things, a medical support program, insurance against accidents and serious illnesses, a corporate pension program, material payments in connection with important life circumstances. Continuous development is necessary condition our success, therefore we pay great attention to the professional and personal growth employees. The Bank provides ample opportunities for training and development of professional, leadership and managerial competencies of its team members, including on the basis of the Corporate University we created COMPLIANCE WITH ETHICAL PRINCIPLES AT WORK

12 2.3. WORKING ATMOSPHERE We encourage employees to improve themselves and achieve high results in their work. The Bank has a system of corporate awards that provides for different kinds non-material incentives and recognition of the achievements of employees. It is customary for us to celebrate the best employees, both in terms of their professional competences and for exemplary manifestation of the Bank's values ​​in their behaviour. Q: My boss gave me a low rating of 5+. I think I deserve a higher rating. Can I complain about my manager's unfair treatment? We strive to create and maintain a working environment that allows each member of our team to reach their potential. Our employees openly express their point of view, they are not afraid to talk about problems. We admit mistakes, learn lessons and take action. We value teamwork, where every voice will be heard. We respect the views of others and share knowledge and resources to achieve excellence, deliver high quality work, and promote individual and collective growth. Our team members treat each other as an internal client, we are open and trust each other. Creating an atmosphere of understanding and trust, as well as maintaining a productive work environment is our common responsibility. Obscene, vulgar, rude, cruel, discriminatory, offensive or offensive language, gestures or behaviors are not allowed on our team. We value diversity within our team. No forms of discrimination, including on the basis of beliefs, age, gender and other characteristics, have the right to exist in the Bank under any circumstances. A: Discuss the situation with the manager, give arguments in your defense. If you do not agree with the result of the meeting, you can contact your senior manager up to the head of the functional unit. If you do not receive a response or do not agree with the decision, you can contact the labor dispute committee.

13 Q: Most of the time the working atmosphere in our department is friendly and open. However, in stressful situations, my boss/colleague allows himself rude and aggressive statements addressed to me. What should be done in such cases? A: Difficult situations at work happen to everyone, and this should not be an excuse for inappropriate behavior. You should openly tell your boss/colleague that his words are offensive. In most cases, an open conversation is enough to stop the unwanted behavior. If this does not help, or if you are unable to discuss the matter with him/her in person, you may seek assistance from Human Resources or the HEALTH, SAFETY & HEALTH We care about the health and well-being of our team members, so Ensuring safety and comfortable working conditions, maintaining a healthy lifestyle are a priority for us. The Bank evaluates the working conditions of employees on a systematic basis, and also implements a set of measures to maintain security at a high level. At the same time, workplace safety depends not only on the measures taken by the Bank, but also on the competence of each employee. Even the most important and urgent tasks must be carried out only if the rules of safety and labor protection are observed. We believe that a healthy lifestyle is the basis for the harmonious development of our employees. Sport for us is a means of creating a team spirit and a positive attitude. Therefore, the Bank supports the efforts of employees aimed at improving their own health and maintaining a healthy lifestyle, regularly organizes sports events for employees and their families. Be attentive to issues related to ensuring workplace safety and labor protection. Attend Bank-sponsored training courses in this area ETHICAL WORK

14 2.5. APPEARANCE STANDARD (“DRESS CODE”) FOLLOWED BY BANK EMPLOYEES Sberbank's team consists of self-confident employees striving for success. Our appearance corresponds to this content. In choosing clothes, hairstyles and accessories, we are guided by the principle “I am determined to do serious business and am not going to shock anyone.” We are not a fan of too rigid and conservative rules, however, the traditional business style is a must for our appearance from Monday to Thursday. On Fridays, it is acceptable to come to work in loose-fitting, neat-looking clothes. Exceptions are employees who have meetings with clients, travel outside of the office for meetings, or are required to wear a uniform. For those categories of employees whose work standards require the wearing of a uniform, it is mandatory to wear it on all working days without exception. Am I using the Bank's resources for personal purposes? Do I forget about the rules of rational use of resources? Do I turn off water, lights and office equipment, electrical appliances in a timely manner? We are convinced that all members of the Sberbank team are obliged to act in good faith and prevent the improper use or waste of the Bank's property, proprietary information, and funds allocated for travel and hospitality expenses. First of all, our employees are guided by the interests of the Bank. We spend when there is no other way not to spend, and only to get the job done. We save the Bank's money and pay expenses as if we were managing our own money. For more details, the requirements for the appearance of employees are set out in the Bank's Internal Labor Regulations COMPLIANCE WITH ETHICAL PRINCIPLES AT WORK

16 2.8. JOINT WORK OF CLOSE RELATIVES Did I disclose to the Bank the information that my relatives work in the Bank and I interact with them in the course of my work? Q: Can I make/influence decisions about working with organizations where my relatives or close friends work? A: Such situations should be avoided. In either case, you need to disclose the information to your manager. More detailed principles for prevention, timely disclosure and management of conflicts of interest established by the Bank, as well as examples of situations that may lead to a conflict of interest, are set out in the Bank's Conflict of Interest Management Policy. In most cases, the joint work of relatives in the Bank is not prohibited. However, in order to minimize the risk of a conflict of interest, the Bank adheres to the principle of limiting the cases of joint work of close relatives, and also prohibits protectionism based on nepotism. Joint work of close relatives in the Bank who are in direct or functional subordination is prohibited, and in other cases of a potential conflict of interest is allowed only by decision of the Compliance Committee COMPLIANCE WITH ETHICAL PRINCIPLES AT WORK

17 2.9. EMPLOYMENT OUTSIDE THE BANK, PARTICIPATION IN THE SHARE CAPITAL AND MANAGEMENT BODIES OF THIRD PARTIES Have I disclosed to the Bank information about my participation in the authorized capital of third parties / work in the management bodies of other organizations / on the implementation of independent commercial activities? How does my work outside the Bank affect the performance of my official duties in the bank? The Bank recognizes the right of employees to engage in labor activities outside the Bank, subject to a number of conditions. In accordance with the banking legislation, certain officials of the Bank are prohibited from combining activities in other credit and a number of other non-credit organizations. follow the Bank's rules for protecting the confidentiality of non-public information entrusted to you or made known in the course of performing your official duties. To ensure there is no conflict of interest, the Bank expects employees to notify their line manager of any employment outside the Bank. Q: While working in the field of information technology at the Bank, I plan to open a similar business in the field of IT development, which I do at the Bank. Can I do it? A: In the Bank, employees are prohibited from engaging in entrepreneurial activities or other commercial activities that have become available due to their position in the Bank, including using business connections and opportunities of the Bank. If the proposed activity meets the requirements of the Bank, it is possible. Detailed requirements for employees in dealing with clients and counterparties, in particular, restrictions on participation in the authorized capital or management bodies of such organizations, as well as on independent commercial activities, are reflected in the Bank's Anti-Corruption Policy. IT IS NECESSARY TO REMEMBER THE FOLLOWING RULES: carry out such activities only during the time free from the performance of official duties in the Bank; make sure it's different labor activity does not affect the performance of your labor duties in the Bank, does not damage the image and interests of the Bank; ETHICAL WORK

18 2.10. GIFT EXCHANGE AND REPRESENTATION Before accepting a gift, ask yourself: Could this gift, or the reason for accepting it, affect the objectivity of my decisions with this company? Would I like my immediate supervisor and my colleagues to know about this gift? The Bank welcomes the development of partnerships with clients and counterparties and allows the exchange of corporate gifts in line with business practice. We are aware that the exchange of business gifts and invitations to hospitality is a socially recognized component of business relations, however, it must be remembered that such cases should not, under any circumstances, damage the Bank's business reputation. Gifts must be directly related to the legitimate purpose of the gift and must not give the impression of misconduct. It must be remembered that the internal policies of customers and partners may not imply the acceptance of gifts and even completely prohibit their acceptance and giving. BANK EMPLOYEES ARE NOT ALLOWED TO ACCEPT GIFTS FROM ANY THIRD PARTY: for performance of any actions (inaction) related to work in the Bank; in the form of cash or cash equivalents; in the absence of a generally accepted reason for the gift. Q: What should I do if I am given a gift that is prohibited by the Bank's internal policies? A: You must refuse to accept this gift by politely explaining that the Bank's internal policies prohibit such gifts. The requirements for business gifts are set out in the Bank's Anti-Corruption Policy. value exceeding the limit set by the Bank; ETHICAL WORK

19 2.11. USE OF THE BANK AND COUNTERPARTY SERVICES RISK CULTURE Sberbank employees and their family members are encouraged to apply to the Bank for financial services for private purposes, however, such services must be provided on the same terms as they are provided to other customers or, if the Bank has a corporate program, other employees. Servicing of employees must not be detrimental to the Bank and discriminate against other clients. Similarly, Bank employees should not enjoy counterparty benefits unless such privileges are available to other Bank employees on the same terms under corporate programs. The use of special conditions for servicing employees as clients is allowed only within the framework of special motivation development programs. Q: One of the Bank's suppliers with whom I work constantly offered me a discount on their products. Can I take advantage of this discount? A: You can use this discount only if a similar discount has been offered to all Sberbank employees. Otherwise, the supplier should be thanked for the offer and politely declined. Have I completed risk management training? Am I able to manage the risks associated with my job? Do I admit my mistakes, do I do it in a timely manner? Do I subject my planned decisions to critical analysis in terms of risks? Am I ready to cooperate to achieve the goals of the Bank? Do I understand the essence of the rules that apply to my work, do I observe not only their letter, but also the spirit? In order for the Bank to successfully develop in a constantly changing environment, we continuously improve our risk management system. Therefore, each of us should be aware of the risk management rules adopted by the Bank and act in accordance with the principles of risk culture, namely: identify the risks associated with our activities, analyze them and evaluate them using available tools, focusing on the acceptable risk limits set in the Bank ; to speak openly and report any situations associated with risks, even if it seems insignificant, since the timely detection of potential problems or the recognition of errors can minimize possible negative consequences; seek cooperation and follow the overall goals of the Bank, including those formulated in its Development Strategy, and not exclusively the goals of its division or its own; observe not only the letter, but also the spirit of the accepted rules COMPLIANCE WITH ETHICAL PRINCIPLES AT WORK

20 3. COMMITMENT TO ETHICAL BUSINESS PRACTICES We categorically do not accept unethical business practices of any kind and require all members of our team to comply with the requirements of the law and the Bank's internal policies. You can familiarize yourself with the Bank's policies in the field of risk management, information about the principles and rules of the risk culture in the Bank on the internal portal. 36

21 3.1. FAIR COMPETITION Do I legally receive and use information about competitors and partners? In our relationships with our partners and competitors, we act in accordance with fair competition standards and best business practices. The Bank complies with competition laws in all countries where it does business. When choosing partners to provide services, perform work or supply goods, the Bank observes the principles of equality, fairness and non-discrimination. We collect and use information about partners and competitors solely on the basis of legality and ethics ANTI-CORRUPTION Is the service offered to me by one of the Bank's partners acceptable, or is it a hidden reward? The Bank in its activities adheres to the principle of non-acceptance of corruption in all forms and manifestations (the principle of "zero tolerance") and considers it its duty to promote an increase in the level of anti-corruption culture in society. A member of the Sberbank team is prohibited under any circumstances, including directly or indirectly, personally or through third parties, to offer, give, promise, solicit and receive bribes or make payments to simplify administrative, bureaucratic and other procedures in any form. The Bank expects its customers, counterparties and partners to comply with their respective anti-corruption obligations. Our common goal is to maintain a high business reputation of the Bank, therefore, every employee of the Bank makes reasonable efforts in their daily work to minimize the risk of business relations with counterparties that have been or may be involved in corrupt activities COMMITMENT TO ETHICAL BUSINESS PRACTICES

22 Q: The Bank's partner offered to do me a favor if I informed him about the parameters of the new products that the Bank plans to launch in the near future. What should I do? A: You should refuse this offer and explain to the partner that Sberbank does not provide such information before its official announcement. The Bank's Anti-Corruption Policy is set out in more detail in the Bank's Anti-Corruption Policy. Sberbank strictly complies with the requirements of the legislation on combating the legalization (laundering) of proceeds from crime and the financing of terrorism. We use all possible preventive measures to do business only with reliable clients and counterparties who are engaged in legitimate activities and receive income only from legitimate sources. When conducting the identification and pre-screening of clients and partners, you need to make sure that you understand the specifics of their activities, as well as understand the source of origin and destination of funds. COMMITMENT TO ETHICAL BUSINESS PRACTICES

23 3.4. INSIDER TRADING AND MARKET MANIPULATION Q: A client I work with has started making atypical cash transactions. What should I do? A: Report your findings to the Compliance Department. In more detail, the Bank's rules in this area are reflected in the Internal Control Rules in order to combat the legalization (laundering) of proceeds from crime and the financing of terrorism. Am I disclosing information that is not yet known to the public in conversations with friends and relatives? In the course of their work in the Bank, each member of the team may learn insider information about the Bank and other organizations before this information becomes public. The use of such information for personal gain for an employee or third parties violates the requirements of the law. All team members need to remember the following rules regarding the use of insider information and market manipulation: do not make personal transactions with financial instruments of organizations in respect of which you have insider information and do not recommend others to make such transactions; do not disclose insider information to anyone outside the Bank, including members of your family, prior to its official disclosure; COMMITMENT TO ETHICAL BUSINESS PRACTICES

24 transfer insider information to other employees of the Bank only in accordance with the adopted regulations; do not take actions aimed at manipulating market prices, do not spread false information or rumors; adhere to the Bank's rules and restrictions on conducting personal transactions with financial instruments. Q: In the course of a conversation with a client, I received information that would enable me to make a successful private equity trade before the information becomes public. What should I do? A: You should not enter into a trade, as such a trade may be regarded as a trade made using insider information. 4. DISCLOSURE OF INFORMATION We want our clients, employees, partners, shareholders and investors to have complete and balanced information about our activities. We strive to be open and active in our communications. We protect confidential customer information, other legally protected information, and information that could affect our competitive advantage. For more details on the Bank's rules in the field of preventing the use of unfair trading methods, see the Bank's Standard for the performance of personal transactions by employees in the stock and exchange commodity markets, as well as the Procedure for accessing the Bank's insider information, the rules for protecting its confidentiality and monitoring the implementation of Federal Law 224- FZ. 44

25 4.1. TRANSPARENCY OF BUSINESS 4.2. RELIABILITY OF REPORTING We ensure the transparency of our activities by openly interacting with various stakeholders and publishing reliable and timely information, both financial and non-financial. When disclosing information, we are guided by the principles of regularity, consistency, efficiency, availability, reliability, completeness and comparability of the disclosed data. As a public company, we fully comply with the disclosure requirements of regulators and stock exchanges, as well as publish additional information that is necessary for interested parties to make investment or other decisions, to draw up a complete and objective view of the Bank's activities. More detailed standards and rules of information disclosure adopted by the Bank are reflected in the Bank's internal policies. Am I responsible enough to provide information to the relevant departments of the Bank for reporting? Am I sending the relevant information in a timely manner and in sufficient volume? Sberbank's financial and non-financial reporting is prepared in accordance with accepted standards and fully reflects, in all material respects, the financial position and performance of the Bank. Employees of the Bank, within their competence and in accordance with the rules of work processes, must honestly, accurately, timely and in full prepare reports on the indicators of their activities and the activities of the Bank. Providing inaccurate, incomplete, inconsistent and untimely reporting is unacceptable. The Bank prohibits falsification of documents, distortion of the true nature of any transactions. DISCLOSURE OF INFORMATION

26 4.3. PUBLIC COMMUNICATIONS The Bank has a circle of persons representing it in public relations. Therefore, in cases where media representatives ask us to comment on a particular issue, we recommend that they contact the authorized unit, most often the Bank's Press Service. When communicating with media representatives, investors, analysts or when carrying out other public communications, authorized persons are responsible for complying with the requirements of the Bank, applicable law, as well as ensuring the reliability and integrity of the information transmitted. Q: Recently, I was invited to speak at the university I graduated from, as part of a program where all graduates talk about their working lives. Can I speak about my work at the Bank? A: You can speak at external events (conferences, forums, round tables) with a story about your experience in the Bank in agreement with your immediate supervisor and with the public relations department. non-public (confidential) information concerning the Bank, colleagues, clients or counterparties. In this regard, employees are required to maintain information barriers between departments when non-public information is reliably protected. In particular, the transfer of confidential information should be carried out through secure channels. The Bank expects employees who transfer to another job to maintain the confidentiality of the Bank's proprietary/non-public information. In turn, the Bank does not oblige new employees to disclose official / non-public information of the organizations in which they previously worked. Q: I found documents with customer account information in the printer's shared area when I was late at work after the end of the working day. What should be done? A: Remove recovered documents to a secure location, report the find to your supervisor, and return to the person in charge. DISCLOSURE

27 4.5. COMMUNICATION IN SOCIAL NETWORKS 5. RESPONSIBLE LEADERSHIP Employees should remember that communication in social networks on the Internet, as a rule, is of a public nature. Employees are prohibited from distributing or discussing without the consent of the Bank on public Internet resources information related to the activities of the Bank, including the use of logos, trademarks and symbols of the Bank, post photos and videos that do not correspond to reality and / or discredit the business reputation of the Bank. Sberbank is the largest financial institution in Russia and operates in many countries around the world. Our team has many thousands of people, and the number of clients is in the millions. This provision implies a special responsibility of the Bank for the way in which its actions may affect the economic, social and environmental development of the regions of presence and local communities. Q: Can I respond on my own behalf to the questions and claims of clients addressed to the Bank via social networks? A: No, you can't. Remember that when communicating during working / non-working hours on the official pages of the Bank on social networks, you are perceived as a representative of the Bank and the information provided by you may be incorrectly interpreted. Answers to questions and comments on the official pages of the Bank in social networks are prepared by authorized employees of the Bank. fifty

28 5.1. SHAREHOLDERS Respect for the rights and legitimate interests of all shareholders of the Bank, ensuring equal conditions for owners of shares of one category, regardless of the number of shares they own, is the basis of the Bank's relationship with its shareholders and one of the fundamental principles of Sberbank's corporate governance system. In relation to shareholders, we create the most favorable conditions for exercising the rights of shareholders, including such as: participation in the management of the Bank, participation in profits, obtaining information about the activities of the Bank; application of the best Russian and international corporate governance practices; 5.2. PARTICIPATION IN PUBLIC AND POLITICAL ACTIVITIES. CHARITY AND SPONSORSHIP Good deeds are an integral part of our corporate culture. Therefore, one of the traditional areas of Sberbank's participation in the life of society is participation in socially significant projects in the field of sports, culture and art, science and education, in charitable and volunteer programs. We are committed to helping provide a reliable way to record rights to shares, as well as their free circulation in the stock markets, including providing shareholders with the opportunity to buy and sell shares at a market price. All our actions are aimed at preserving and increasing share capital. The corporate governance standards applied by the Bank are formulated in the Bank's Corporate Governance Code RESPONSIBLE LEADERSHIP

29 children's institutions and healthcare organizations, public organizations of war veterans. As part of sponsorship programs, Sberbank also contributes to major Russian and international business events. The Bank does not participate in the activities of political and religious organizations and does not finance their activities. Employees who take part in non-working hours in political, religious or other public activities are obliged to act in these cases only as individuals, and not as representatives of the Bank. Campaigning in favor of any political party or candidate, as well as dissemination by employees of their religious views and beliefs, is not allowed on the territory of the Bank. All team members are prohibited on behalf of the Bank from giving gifts, making political contributions, or organizing entertainment events for political parties or candidates for political office. principles of compliance with legislation, transparency and cooperation. The Bank's employees must be polite and professional, express only the official position of the Bank and not obstruct investigations if they are conducted. You can find information about the implementation of charitable activities in the Bank on the internal portal of the Bank RESPONSIBLE LEADERSHIP


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Code of Conduct

PJSC "Baltic Bank"

St. Petersburg

Article 1

Goals and objectives of the Code of Corporate Ethics

1.1. The purpose of the Code of Corporate Ethics (hereinafter referred to as the "Code") is to determine the performance standards of PJSC "Baltic Bank" (hereinafter referred to as the "Bank") and the behavior of its employees, aimed at maintaining ethical standards, quality of service and convenience for customers, improving the efficiency of operations, financial stability of the Bank and contributing to increased demands on the Bank's Employees and the Bank's Employees to themselves.

1.2. The objectives of this Code are:

· consolidation of the Mission and Corporate values ​​of the Bank;

· ensuring awareness by the Bank's Employees, members of the Management Board, members of the Board of Directors of the Bank of personal responsibility to customers, business partners, shareholders of the Bank and colleagues for the performance of their official duties, their role in the implementation of the Mission of the Bank;

12.8. An employee of the Bank, a member of the Management Board, a member of the Board of Directors of the Bank excludes any activity that may damage the business reputation, other intangible and material interests of the Bank, client, business partners.

12.9. An employee of the Bank may notify the immediate supervisor and the relevant structural subdivision, a member of the Management Board - the Chairman of the Management Board of the Bank about planned, current or implemented actions both inside and outside the Bank by other Employees of the Bank, members of the Management Board, the Board of Directors, customers, business partners that violate generally recognized principles and norms of international law, the provisions of the legislation of the Russian Federation, this Code (in cases provided for by the provisions of this Code) or other internal documents Jar.

For the purposes of this Code, an Employee of the Bank means any individual who has entered into an agreement with the Bank labor contract or another civil law contract providing for the personal performance of a certain function (work in a certain specialty, qualification or position) for a fee.

The emergence of a conflict situation within the workforce can be facilitated by factors such as ignorance or deliberate disregard for the norms of the current labor legislation, attempts to get rid of objectionable employees, insufficient motivation, unfair assessment of work, lack of professional competence of managers, psychological incompatibility of employees, unjustified protectionism and preferences in relation to individual employees (including due to family ties), etc.