CORPORATE ETHICS CODE FOR SBERBANK OF RUSSIA EMPLOYEES

CORPORATE ETHICS CODE FOR SBERBANK OF RUSSIA EMPLOYEES

TABLE OF CONTENTS President s Address 2 Introduction 3 Our Bank Sberbank of Russia 3 Bank s Values 4 Standards and Rules of Conduct of Bank Employees 8 Prevention of a Conflict of Interest 10 Corporate Social Responsibility 13 Code Compliance 14 7 Kazanskaya St., Board of Trustees Building, St. Petersburg The St. Petersburg Savings Bank occupied this building from 1842 to 1917. 1

Dear Colleagues, This is the Corporate Ethics Code for Sberbank of Russia Employees. It is a set of rules describing the standards of our conduct, our commitments and responsibility towards the bank, society, our customers and each other. It would not be an exaggeration to say that we are working in a special and unique bank. The role it has played throughout its history for the country s economy cannot be underestimated. One way or another, we owe our successes to the many-thousand-strong team of our bank, operating in various regions of our homeland that has always been like a big family, a community of fellow thinkers united by common ideas, corporate values and moral principles. The Code sets forth these underlying principles and shows how personal pursuit of successful work and career should yield to the interests of the bank, its customers and our country. Today, Sberbank of Russia is an acknowledged leader of the Russian banking system and is ranked high in the world ratings. I am sure the Corporate Ethics Code will help us to maintain and strengthen the standing of our bank and be an example of reliable and professional work. CEO, Chairman of the Management Board, Sberbank of Russia A. I. Kazmin /Signature/ 2

INTRODUCTION The purpose of the Corporate Ethics Code for Sberbank of Russia Employee (the Code ) is to set out the Bank s corporate values, ethical standards and rules of conduct of Sberbank of Russia (the Bank ) employees, to ensure they are aware of their roles in implementing the Bank s mission in respect of its customers, shareholders and business partners. The Code contains standards and rules of conduct for Sberbank employees, which are based on the values adopted by the Bank and comply with the Bank s mission and philosophy. The provisions of the Code apply to all employees of the Bank, regardless of their position, professional activity or location of the Bank's division or branch. Each employee undertakes to comply with this Code. OUR BANK SBERBANK OF RUSSIA Sberbank of Russia is a leader of the Russian banking system and the basis of its stability and reliability. The Bank s presence in all the sectors of the banking market makes it an alternative to any other bank operating in Russia and ensures the functioning of the country's banking system in any conditions. Sberbank of Russia is a bank on a national scale. The Bank takes part in shaping economic policy, influences the macroeconomic processes of the country, and implements economically efficient projects and programs of development. The Bank s extensive branch network and the use of advanced technologies are designed to ensure the availability of the Bank's services anywhere in the country. Sberbank of Russia represents the Russian banking system on the international market. The Bank has partner relations with leading foreign banks and credit institutions, and takes part in international banking conventions and forums. Sberbank of Russia is a universal commercial bank. The Bank strives to satisfy the needs of all its customers for a wide range of services and to a high standard. The Bank aims to deposit funds raised from private and corporate customers in an efficient manner for the benefit of the Bank's customers and shareholders. Sberbank of Russia is a socially significant bank. Being the only banking institution offering services throughout the Russian Federation, the Bank plays 3

an active role in implementing social programs, provides support for the development of national culture, science, education and healthcare. The mission of Sberbank of Russia is to meet the need of its every customer throughout Russia with banking services of the highest quality and reliability, to ensure stable functioning of the Russian banking system, the saving of customer deposits and their investment in the real sector, thus, contributing to development of the Russian economy. THE BANK S VALUES The Bank s Corporate Values The Bank pursues the highest customer service standards and strives to improve banking products and services. The Bank meets the laws, ethical standards and rules of fair business, unconditionally fulfills its obligations and values its reputation. The Bank adheres to the principle of neutrality in respect of financial and industrial groups, political parties and associations, and conducts its business in the interests of its customers and shareholders. The Bank does not finance environmentally harmful or socially hazardous production, projects or programs. The Bank factors in the social significance of its activities and considers the social factor along with the economic one. The Bank develops new types of operations and business areas, following the principles of reasonable conservatism. The Bank values its employees, creates conditions in which each of them has an opportunity to realize their abilities in full, and cares for veterans. The Bank honors the traditions of Russian entrepreneurship and contributes to their revival, conservation and development. Bank Customers Among its customers, the Bank sees all citizens of the country, organizations, companies of any form of incorporation, credit institutions, other financial institutions, executive governmental authorities, and sole traders. The Bank aims to establish long-term partner relations with every customer. 4

The Bank excludes any political, religious, national, age or gender discrimination of its customers. The Bank offers a wide range of bank products and services and conscientiously fulfills its obligations. The Bank seeks to ensure a high quality of customer services in accordance with international standards. The Bank guarantees confidentiality of information related to its customers. Such information may be used only for the purposes stipulated by the applicable laws and the Bank s internal documents. Bank Shareholders The Bank s corporate conduct practice is intended to ensure that its shareholders are treated equally. The shareholders define the main principles of the Bank's business development. The Bank is responsible to its shareholders for ensuring the growth of the Bank s assets, its profitability and implementing the standards and traditions of Russian corporate business conduct, compliant with internationally accepted standards in the Bank's daily practice. The shareholders have the right to regular, full and timely receipt of reliable information about the Bank and its performance. The Bank is interested to have its strategic partners and customers, who consider shareholding as part of a long-term cooperation program, among its shareholders. The Bank welcomes the desire of its employees to hold the Bank s shares and thus to participate both in its management and profit distribution. Bank Employees The Bank values and respects its employees. The employees are the Bank s main asset. The Bank builds its relations with employees based on principles of long-term cooperation, mutual respect and unconditional performance of mutual obligations. The Bank strives to ensure that each employee shows respect for the Bank s traditions and history and is genuinely proud that he or she works for Sberbank of Russia. 5

In its employees, the Bank values honesty, integrity, professionalism, orderliness, inner culture, self-discipline, and being result-oriented. The Bank adheres to the principle of tolerance of any ideological, personal or physiological differences of its employees. Any individual peculiarities of a person not having a negative impact on the quality of his or her work may not be grounds for any restrictions in respect of such employee. The Bank maintains a balance between personal interests of its employees and the Bank s interests: encourages professional and personal development and cares for the health and welfare of its employees and their family members. The Bank creates conditions enabling each employee to realize their creativity, be able to improve their professional knowledge, and have good prospects of career advancement. The Bank views increasing the level of independence and responsibility of its employees as a material factor of personnel quality improvement. The Bank welcomes the development by its employees of the following qualities: Goal orientation Customer orientation Compliance with corporate rules Innovation Professionalism Teamwork skills. Single Team The Bank is a multi-national team united by the idea of high-quality customer services, improvement of the Bank's image, and strengthening of its business reputation and status. The Bank s goals are attained by combining the efforts of all the Bank employees and creating a cohesive and highly professional team of fellow thinkers, able to respond adequately to the changing market requirements and challenges. The Bank is focused on maintaining the stability of its teams and the succession of personnel professional experience. 6

The Bank arranges interaction between all employees based on common values, and ensures the functional integration of all Bank divisions. Each employee of the Bank contributes to the work of his or her team and is responsible for its result. Each employee should be aware that the work performed by the employees of different divisions all serves the common objective. High Reputation and Reliability The Bank values and strengthens its reputation ensuring compliance with all obligations in its relations with customers, employees and shareholders. The Bank declares its commitment to the principles of fair competition and the counteraction of the legalization (laundering) of the proceeds of crime. The Bank is responsible for the correctness and validity of its marketing and advertising campaigns. The Bank builds relations with its competitors based on principles of integrity and mutual respect. The Bank s business reputation is characterized by reliability, stability and success. Reliability is the basis of the reputation of the most popular Bank that attracts and retains customers. The Bank s stability, profitability and management efficiency are benchmarks for our customers, partners and shareholders. STANDARDS AND RULES OF CONDUCT OF BANK EMPLOYEES Ethical Conduct Standards The Bank treats all its employees and business partners with respect and good will. This is a fundamental issue. The conduct of each employee gives the Bank s business partners and customers a general idea of the Bank and has an immediate effect on their desire to cooperate with it. 7

Each employee strives to perform their duties to the fullest extent and with maximum responsibility, contributing to the attainment of the Bank's single goals. When performing their job duties, employees of the bank should aim to find the best solution, combining low cost and high efficiency. It is important for the Bank to develop an atmosphere of cooperation among the Bank s personnel. The Bank does not promote competitive relations between its subdivisions or branches, but welcomes a competitive spirit among its employees as an impetus to personal growth and professional development of each employee and enhancement of the Bank s overall performance. Personal communication of the Bank s employees during business hours shall be in accordance with generally accepted standards of business ethics. The Bank encourages a healthy lifestyle of its employees. The Bank employees are prohibited from: Using any material or intellectual resources of the Bank for their own needs Saying or doing something detrimental to the Bank Using narcotics Drinking alcohol at their work place and/or within the Bank territory. Drinking alcohol is only allowed on holidays and other special events and is restricted by the standards of business ethics Visiting gaming establishments that practice gambling and/or accept bets (casinos, sweepstakes, bookmaker s offices, slot machine halls and other gambling houses or venues) Smoking within the Bank s territory except for specially designated areas. The Bank has a business dress code. The Bank employees shall wear neat and modest clothes. The Bank promotes the development an atmosphere of trust among its teams in which any ethical problems can be discussed. Each employee shall resist any deviations from the standards of corporate conduct of the Bank employees. Following high ethical standards and upholding the Bank's reputation are one of the main objectives of each employee. Relations with the Bank s Customers 8

The relations of employees with the Bank s customers are based on amiability and a desire to provide customers with maximum services and high professional service competence. The employees may service customers only within the scope of orders given by customers and contractual obligations. The employees shall not create such service conditions for a customer that will impair the Bank s interests or prejudice the rights of other customers. The Bank employees are not allowed to receive money or costly presents from customers, provide or receive services with the purpose of influencing decisions. PREVENTION OF A CONFLICT OF INTEREST The Bank and its employees try to avoid situations giving rise to a conflict of interest. Restrictions on the participation of the Bank s employees in operations (transactions) with an organization in respect of which such employees may be recognized as interested parties are established under the laws of the Russian Federation. An employee shall abstain from any activity if such activity contradicts the Bank's interests or may cause doubts as to the reputation and reliability of the Bank. In the event of a potential conflict of interest, the employee shall bring such details to the notice of his or her immediate supervisor, the internal control service, and, where necessary, the security service of the Bank that will advise the employee on his or her actions under the circumstances. If a conflict of interest cannot be eliminated for objective reasons, the interests of the Bank's customers shall prevail, unless it is in conflict with the laws and the Bank s internal regulatory documents. In the event of a conflict of interest between an employee and the Bank, the Bank s interests shall prevail. Employment outside the Bank Recognizing the right of its employees to engage in other professional activities outside the Bank, the Bank does not approve the part-time employment and employment under civil agreements with other commercial organizations (save for teaching and research activities). In case of employment outside the Bank, the Bank employees shall: 9

Notify their immediate supervisor and the head of the Bank s (branch s) HR department of such other employment Engage in other labor activity only out of working hours, subject to the requirements of this Code, except to the extent provided for by applicable laws Make sure that such other employment does not affect the performance of their primary duties or impair the Bank's image or interests Comply with confidentiality restrictions in respect of insider information as set forth by the Bank s regulatory documents. The Bank employees shall not hold full-time management positions with organizations, save where a resolution on holding a concurrent full-time management position with an organization is passed by the executive authorities of the Bank s (branch s) management board to implement a program for financial rehabilitation of the organization, for the period of the liquidation commission, bankruptcy of the organization or the taking of other measures. The employees may not engage in any activities, whether directly or indirectly, that may, as a competitive action, cause damage to the Bank. Participation of the Bank employees in other organizations is subject to written obligations assumed towards the Bank. Participation of employees in political, religious and public organizations The Bank does not restrict the participation of its employees in any political, religious or public organizations beyond working hours. Religious and political preferences are a matter of personal opinion of employees and shall not prevent them from performing their job duties or communicating with colleagues. The Bank s employees taking part in political, religious and public activities shall in this case act as private individuals only and not as the Bank s representatives. No agitation of employees for the benefit of any political party or candidate or distribution by employees of their religious beliefs or views is permitted within the territory of the Bank. Employees shall not perform political, religious or public activities using the Bank's resources, image or reputation to that end. Information Transparency and Confidentiality Compliance 10

The Bank establishes the procedure, forms and ways of providing official information subject to the applicable laws, the nature of information provided and the needs of interested parties. The Bank keeps official information on its employees, including personal information and information on personal income, confidential. The Bank ensures the confidentiality of such information, except to the extent provided for by the applicable laws. Employees may not use illegally restricted official information, including when making transactions beyond their job duties and/or upon a conflict of interest. To protect customers interests, employees shall observe information barriers between divisions when carrying out financial activities in accordance with the Bank's internal regulations. The Bank restricts the number of persons entitled to communicate with mass media on behalf of the Bank. Only authorized persons may make comments on the Bank s activities for mass media and other sources. An employee shall not question the Bank's activities or actions of his or her colleagues using mass media. Employees shall be held personally liable for the content of information they publish about the Bank in public Internet resources. The employees who change their employment shall keep the Bank's restricted official information in confidence in accordance with their previous written obligations. The Bank does not require that its employees disclose confidential information accessed by them when working for other companies (organizations). In the event of intentional or negligent disclosure by a Bank employee of any information treated as a commercial secret, that was made available to him/her for the performance of his/her job duties, the Bank reserves the right to impose measures provided for by applicable laws. CORPORATE SOCIAL RESPONSIBILITY The Bank s social responsibility to society involves: Providing quality services to each customer 11

Creating work places, paying legal salaries and investing in the development of human capital Strict legal compliance Taking into account public expectations and generally accepted ethical standards in its business practice Efficient conduct of business, including subject to the interests of the least socially protected social groups Contributing to the formation of a civil society through partner programs and local community development projects. The Bank s social mission is implemented by pursuing an interest-rate policy on private deposits, factoring in the interests of the least protected social groups, by maintaining private customer service outlets unprofitable for the Bank where they are the only bank institutions, and in certain cases by performing bank operations free of charge. For the Bank, socially significant business involves not only charitable and sponsorship campaigns, but also the creation of a sustainable business environment and active interaction with society, which contributes to the stabilization of the economy and improvement of quality of life. The Bank plays a significant role in providing financial services to the public and demonstrates ways of solving social problems to the rest of the business community. The general approach to forming and implementing internal corporate social programs is focused on enhancing the consolidation of the Bank s teams united by a single production process and preserving the basic values inherent in the Bank. The Bank views the level of social security of its employees as an important element of its image distinguishing the Bank among its competitors by economic efficiency, internal stability and the status of its employees. CODE COMPLIANCE The Bank employees shall comply with this Code. If an employee has any questions as to the correctness of his or her conduct in any situations covered by this Code, and if he or she has reasonable suspicions that any of his/her actions or omissions may lead to a violation of the Bank's 12

ethical standards or give rise to a conflict of interest, such employee shall apply to one of the following instances: The employee's immediate supervisor HR Department (Unit) Internal Control, Inspection and Audit Department (Unit) Legal Department (Unit) Security Department (Unit) Line manager. Employees shall display a spirit of cooperation in any investigations concerning bank ethics violations. No employee may be persecuted for pursuing the Bank's ethical standards or his/her reasonable demands that these standards be observed by other employees. The Bank is confident that unconditional compliance by all employees with this Code improves the Bank's performance, maintains and strengthens its image and reputation and contributes to the development of strong business relations with its customers, partners and shareholders. Each employee shall be personally responsible for ensuring that their relations with customers, colleagues, shareholders and the public contribute to the Bank s leadership, dynamic growth and higher quality of the services provided. The Code is compliant with the Bank's current internal regulatory documents (Sberbank of Russia Development Concept, Sberbank of Russia Corporate Management Code, Regulations on Participation of Sberbank of Russia in Other Organizations, Regulation on Commercial Secret of Sberbank of Russia, and others). Each employee shall have a personal copy of this Code. The text of this Code and all subsequent amendments hereto will be published on the corporate website of Sberbank of Russia. Each employee shall read the Code and sign the Declaration of Consent with the Ethical Standards of Sberbank of Russia. The signed copy of the Declaration shall be stored in the employee s personal file. 13

Employee s ignorance of the provisions of this Code or refusal to sign the Declaration shall not relieve such employee from his/her obligation to comply with the corporate standards and rules of conduct approved by the Bank. 14