Investor Presentaiton
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corporate social responsibility >>>
INTERVIEW
SBERBANK
170 YEARS. BY YOUR SIDE
MPROVING CORPORATE GOVERNANCE
ANNUAL REPORT
2011
Bella Zlatkis
Member and Deputy Chairman
of the Management Board
>> Sberbank's corporate social responsibility
is an extensive system of measures, which
involve, amongst others, improving the
transparency of the Bank's commercial
transactions, keeping all stakeholders
informed about the Bank's performance
and creating mechanisms that ensure fair
and honest conduct by Sberbank employees,
while going as far as possible to prevent any
potential manipulations
Any socially responsible financial institution is interested in making
information about its performance available to all stakeholders-this
is what transparency means. Anyone has the right to access informa-
tion that is declared public at the international level and by Russian
legislation. The more information we disclose how we achieve our profit,
how many transactions we handle per second the more accurately our
investors will be able to assess our business and make their own con-
clusions without resorting to guesswork. I firmly believe the more open
a company is, the more competitive it is and the more chances it has of
trading at a fair price on the equities markets and attracting investors.
We pay enormous attention to ensuring that our operations comply with
all applicable legal and regulatory requirements and our own corporate
policies. Formal compliance procedures are essential in ensuring that
the Bank's investors and partners know that any transaction performed
or action taken at the Bank is in full compliance with all applicable rules
and requirements. This is particularly important for foreign investors
who demand that information be disclosed about the sufficiency and
reliability of compliance procedures.
We pay enormous attention
to ensuring that our operations
comply with all applicable legal
and regulatory requirements and
our own corporate policies
On 1 January 2011, the Russian law On Counteracting the Illegitimate
Use of Insider Information and Market Manipulation came into force.
In the second half of the year, provisions within this law regarding
oversight of information disclosure came into effect. These procedures
are particularly important in terms of ensuring deal transparency and
honest transactions on the financial markets at fair prices. Today our
Insider List includes over 1,500 individuals and 20 legal entities. The
list includes all employees of the Bank, its subsidiaries and business
partners who are related or have access to information that could affect
the price of Sberbank shares.
One of the requirements of the new law is the creation of a separate
organisational unit to oversee the handling of insider information. In
2011, Sberbank created such a unit and adopted a number of internal
policies in this area, including the Definition of Insider Information
and the Regulation on Accessing Insider Information. The Bank also
defined specific procedures for accessing insider information. Moreover,
Sberbank became the first Russian bank to introduce a new practice;
the Supervisory Board and the Management Board prohibited insiders
from carrying out any transactions involving Sberbank shares in the
30 calendar days running up to the publication of annual and quarterly
financial statements of Sberbank and its subsidiaries and dependent
companies and during the two business days after disclosure.
The integration of the investment company Troika Dialog in 2011 in-
creased the significance of the Bank's Code of Conduct on the Financial
Markets, a document adopted by the Bank in 2010 to define ethical
standards for our traders. To accommodate a broader range of trading
operations, we plan to amend the Code, including, in particular, provi-
sions about conflicts of interest on the financial markets.
251
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corporate social responsibility
170 YEARS. IT'S JUST THE BEGINNING
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