Compliance

In the exercise of its public powers and tasks as set out by the Bank of Slovenia Act, the Bank of Slovenia endeavours to uphold the highest standards of ethical conduct on the part of its staff, in accordance with the common guidelines and values established within the framework of the ESCB and the ECB. Upholding these standards is an essential prerequisite for building and maintaining the public’s trust in the sound governance of the Bank of Slovenia in carrying out its public tasks.

The Bank of Slovenia has adopted the Code of Ethics of the Bank of Slovenia, which sets out rules of ethical conducts for its staff, and has put in place the function of the compliance officer, who ensures that staff conduct complies with the applicable regulations in the area of the Bank of Slovenia’s independence and integrity, and with professional ethical rules. The Bank of Slovenia endeavours to maintain and build the public’s trust in its integrity by setting out rules of conduct, and by expecting its staff to maintain independence, objectivity and professionalism in performing their professional duties. Pursuing a preventive brief, the compliance officer advises staff members, and monitors their actions in performing their professional duties and in their outside activities and private financial transactions.

With regard to staff members’ contacts with external stakeholders when performing their professional duties, the Bank of Slovenia aims to ensure that such contacts apply the four eyes principle and are undertaken in transparent fashion. In so doing the Bank of Slovenia endeavours to ensure that all stakeholders are equally informed of all relevant issues and of the general positions held by the Bank of Slovenia, and have the opportunity to provide their own feedback and suggestions. Bank of Slovenia function holders and staff members are required to report any contacts with external stakeholders that have the nature of lobbying to the Commission for the Prevention of Corruption.

The Bank of Slovenia further requires staff members to obtain the prior permission of the compliance officer for any private activities connected with the Bank of Slovenia or its business processes or activities, irrespective of whether such private activities are paid or unpaid.

The Bank of Slovenia also sets out rules with regard to the private financial transactions that staff members execute outside their professional activities at the Bank of Slovenia that could entail a conflict of interest for the Bank of Slovenia or the risk of the misuse of confidential information in connection with supervisory powers, the implementation of ECB monetary policy or other tasks of the Bank of Slovenia. The Bank of Slovenia prohibits staff members involved in supervisory activities or activities in the area of ECB monetary policy from any private financial transactions in instruments related to supervised entities or financial corporations, gold, or government securities.

The Code of Ethics of the Bank of Slovenia also sets out rules and restrictions with regard to the acceptance of gifts offered to staff members in connection with the performance of their professional duties. Even customary business gifts and other favours received by staff members from external stakeholders in connection with the performance of their professional duties are subject to internal reporting and disclosure requirements. Accepting gifts and favours is only allowed in exceptional cases, provided that it is a customary favour (e.g. at the end of the year) of negligible value; otherwise staff members are required to refuse any gifts received, or to hand them over to the Bank of Slovenia.

We therefore ask that you do not express your satisfaction from good relationships with staff members at the Bank of Slovenia through gifts or other favours for the staff. It would be unfortunate for a well-intentioned act to lead to a gift or favour being refused for the sake of preventing any doubts as to the independence, objectivity or professionalism of our staff or the integrity of the Bank of Slovenia itself.

If you are aware of any staff at the Bank of Slovenia acting in contravention of the applicable regulations relating to the Bank of Slovenia’s independence and integrity or with the ethical rules of the profession, please inform us of this conduct so that we are able to take appropriate action in the event of any breaches being identified, and to prevent any undesirable conduct on the part of staff members in the future (contact the Bank of Slovenia, FAO: Compliance Officer, Slovenska cesta 35, 1505 Ljubljana, Slovenia, marking the envelope “PERSONAL”).