Code of Conduct

The following rules of Conduct of Conduct shall apply to all employees including members of the board of management of Ayeyarwaddy Farmers Development Bank Public Company Limited (A bank) and will be served as a minimum standard requirement for A bank. More expansive particular standards should exist within A bank or local jurisdiction in those standards should additionally be applicable.

1. Principle
Employees are required to conduct themselves with honesty and integrity towards A bank, their customers and other business partners, their stockholder and public institutions as well as adhere to the legal requirements in each jurisdiction. Conflicts of interest are to be avoided.

2. Gifts and Gratuities to Third Parties
Representatives of public institutions should not give gifts or other gratuities directly or indirectly. The distribution of gifts and other gratuities to private third parties in the course of the employee’s duty must be handled very restrictively. Gifts and gratuities must remain within customary limits and be of defined nominal value. In such cases no actual or apparent compromising, binding or corrupt relationship must arise between A bank and the recipient. In case of doubt, prior approval from the Legal Department must to be obtained.

3. Gifts and Gratuities from Third Parties
In the course of their work, employees must not demand or accept gifts and gratuities or other favors, neither for themselves nor for a third party, where such conduct may affect or appear to influence their business judgment or which exceed the customary limit of nominal value which was adopted by the government.

4. Political and Charitable contributions
Political and charitable contributions from A bank assets must remain within the framework of the respective legal system and require prior approval of the board of director or senior management.

5. Behavior towards other Colleagues
Employees of A bank shall act with integrity and treat your colleagues and others that you meet through your work with respect. No direct or indirect negative discrimination shall take place based on race, religion, age, gender orientation, disability, language, employee representation, political or other opinions, national or social origin, property, birth place or other status. No tolerate degrading treatments towards any employee, such as mental or sexual harassment or discriminatory gestures, language or physical contact that is sexual, coercive, threatening, abusive or exploitative.

6. Confidential Information / Secrecy
Confidential information and records of A bank must be kept secret in a suitable manner from third parties and non-involved colleagues. If third parties consistently or purposefully try to obtain confidential information from employees, the involved employees must notify the bank’s authority immediately. Customers’ data secrecy must be protected. Employees are prohibited from forwarding, processing or using personal data of each or others without authorization and salary information is strictly confidential and not shareable to others.

7. Additional Employment/ Substantial Private Participation
The Bank prohibits additional employment if it is to be feared that such employment would interfere with the interests of A bank. As far as additional employment competes with the interests of A bank, such employment is prohibited.The exercise of special positions/mandates with other business enterprises outside the A bank (i.e. board of directors, advisory board, and advisor) requires the approval of A bank’s senior management. A bank or employees shall inform without delay of substantial private participation of its employees or immediate family members in companies of business partners or competitors that could lead to a conflict of interest.

8. Protection of A bank’s Property
Business documents, work tools and other valuable material and intellectual property of A bank may neither be used for personal purposes nor provided to third parties to the extent that this would negatively affect the interests of A bank.

9. Anti-money Laundering and Combating the Financing of Terrorism (AML/CFT)
Money laundering, Combating the Financing of Terrorism (AML/CFT ) regulations cover the compliance of CDD, record keeping, STR CTR reporting requirements, know your customer (KYC) procedures for your line of business and sanction lists. These are to result from unlawful or criminal activities to obliterate the banking operational risks, and to prevent from the reputational risks. It shall be followed by the all employees to be high ethical and professional standard in the banking sectors. Employees from A bank have a role for making to appear that the money comes from legitimate sources or transactions, and to play in helping to prevent criminals from using A bank’s products and services. This includes an obligation to identify and report suspicious or unusual activities, must make reasonable efforts to determine the true identity of all customers by following all required related documents of AML/CFT from Legal and Compliance Department instructions to comply with the guidelines adopted by the Central Bank of Myanmar.

10.Internal Communication Policy and Public Communication Policy
Accounting as well as internal and external reporting of A bank has to be true and fair. The dissemination of information to the public concerning with A bank is to be handled by authorized person only.

11.Reporting Infringements of the Code of Conduct
Infringements of the Code of Conduct must be reported to either to the employee’s superior or to the Human Resources department, Internal Audit or, in case of insider violations to Legal Department. In accepting this offer, it is hereby agreed and understood that you will abide by A bank’s rules & regulations as may be amended from time to time. Please acknowledge of your acceptance of the above-mentioned terms and conditions and return an original letter along with the signed “Code of Conduct” and shall keep a singed copy by the employee. Should you have any inquiries, please contract to A bank’s Human Resources Department.