Human Resources

This Code is a guide to the ethical conduct required of Bank employees. The Code also aims at informing the public of the principles to which its employees are committed. The Code sets aspirational standards that require conscious striving to attain. The principles of the Code derive both from the general values of society, and from the profession’s special responsibility to serve the public interest.

I The Bank employee’s responsibility to the Public

• The employee’s primary obligation is to serve the public interest.
• The employee must strive to provide full, clear and accurate information on all the services American Bank of Investments offers to all citizens.
• The employee must strive to expand choice and opportunity for all persons, recognizing a special responsibility to serve the needs of disadvantaged groups and persons.
• The employee must strive for excellence of environmental design, whenever possible, as well as endeavor to conserve the heritage of the built environment.

II The Bank employee’s Responsibility to Clients and Employers

• The employee owes diligent, creative, independent, and competent performance of work in pursuit of the client’s or employer’s interest.
• The employee must accept the decisions of his supervisor or employer concerning the objectives and nature of the professional services to be performed unless the course of action to be pursued involves conduct that is illegal or inconsistent with the employee’s primary obligation to the public interest.
• The employee must not, without the consent of the client or employer, and only after full disclosure, accept or continue to perform work if there is an actual, apparent, or reasonably foreseeable conflict between the interests of the client or employer and the personal or financial interest of the Bank employee or of another past or present client or employer of the employee.
• The employee must not solicit prospective clients or employment through use of false or misleading claims, harassment, or pressure.
• The employee must not sell or offer to sell services by stating or implying an ability to influence decisions by improper means.
• The employee must not use the power of any office to seek or obtain a special advantage that is (or is not) in the client’s interest, nor any special advantage that is not a matter of public knowledge.
• The employee must not reveal information gained in a professional relationship which the client or employer has requested be held inviolate. Exceptions to this requirement of non-disclosure may be made only when (a) required by process of law, or (b) required to prevent a clear violation of law, or (c) required to prevent a substantial injury to the public. Disclosure pursuant to (b) and (c) must not be made until after the Bank employee has verified the facts and issues involved and, when practicable, has exhausted efforts to obtain reconsideration of the matter and has sought separate opinions on the issue from other qualified professionals employed by the client or employer.
• The employee must not make any compromise or personal agreement with the Bank’s Portfolio debtors without the knowledge, or to the detriment, of the Employer.
• In case the responsibility of employee regarding the above is proven, coming as a result of neglect or intentional actions, the employee must renounce any claim or counterclaim against the decision of the Bank to charge a compensation (payment claim) up to 100% of the principal of the loan or loans subject to heavy negligence or intentional actions, but not less than EUR 10,000 (ten thousand Euros).

III The Bank employee's Responsibility to the Profession and to Colleagues

• The employee should contribute to the development of the profession by improving knowledge and techniques, and increasing public understanding of bank activities and services.
• The employee should treat fairly the professional views of his or her qualified colleagues.
• The employee must protect and enhance the integrity of the profession and must be responsible in criticism of the profession.
• The employee must accurately represent his or her qualifications, views, and findings, as well as those of his or her colleagues.
• The employee, who has responsibility for reviewing the work of other professionals, must fulfill this responsibility in a fair, considerate, professional, and equitable manner.
• The employee must share the results of experience and research that contribute to the body of planning knowledge.
• The employee must strive to increase the opportunities for women and members of recognized minorities to become professional employees of the Bank.

IV The Bank employee's Self-Responsibility

• The employee should strive to achieve and maintain top standards of professional integrity, proficiency, and knowledge.
• The employee must not commit a deliberately wrongful act that reflects adversely on the Bank’s mission, or on the employee’s professional growth.
• The employee must respect the rights of others and, in particular, must not improperly discriminate against other persons.
• The employee must accurately represent their professional qualifications, education and experience.
• The employee must systematically and critically analyze ethical issues in the Bank activities.