Good Business Conduct

In its operations, Sberbank strictly complies with current legislation and the provisions of the Code of Ethical Principles of the Banking Industry. We also adhere to the principles of good business conduct and fair competition. For example, for ethical reasons, the Bank does not provide loans to certain categories of customers such as pawnbrokers and gambling businesses.

We disclose full and reliable information to our customers on the terms, conditions and procedure for paying for banking services; the appendices to our banking service agreements explain in detail how the cost of services is calculated, which makes it easier for our customers to estimate their financial capabilities and make sound decisions. At the end of 2008, when the financial crisis was worsening, we published our general principles for lending to corporate clients on our website.

Against a backdrop of general instability in the banking system, frequent changes to lending terms and conditions and the lack of clarity, this information proved very helpful. Despite the fact that the situation in the financial markets and in the economy as a whole has generally stabilised, the level of customer confidence still remains much lower than before the crisis. At the same time, the availability of loans has increased; interest rates are lower than before the crisis and lending procedures have been simplified. This is why Sberbank decided to take another step in informing its customers about how lending decisions are made and how problems are dealt with by the Bank. Today the Bank’s Credit Manifesto, a document that outlines general lending principles and significant changes that took place over the past two years, is available on our website.

We recognise our responsibility for the actions of our clients and their impact on society and the environment. Therefore Sberbank requires all of its corporate clients to fully comply with current legislation, including environmental laws and regulations. In certain sectors, such as in the chemical and forestry industry, our policies require a mandatory environmental expert review of proposed investment projects. The same requirement applies to construction projects.

Our specialists analyse the conclusion of the expert review and monitor project compliance against environmental requirements. The customer applying for the loan is responsible for organising the review and associated costs. In order to minimise environmental risks, the Bank recommends that its customers use well-tested state-of-the-art technologies and include costs to reduce emissions and prevent accidents in their project budgets.

Sberbank recognises the necessity and importance of taking action to prevent the use of banking services and operations for criminal ends and we take an active stance in combating money laundering and the financing of terrorism. In 2003, Russia joined the Financial Action Task Force (FATF), an inter-governmental body whose purpose is the development and promotion of national and international policies to combat money laundering and the financing of terrorism. In 2008, Russia was recognised as one of the five best countries in the field of combating money laundering and terrorist financing (MLTF), and Sberbank contributed to that result. The Bank has also signed the Banks Against Money Laundering declaration, a joint statement of a group of Russian commercial banks, and strictly follows its principles and priorities.

Sberbank complies with all Russian legislative requirements in the field of combating MLTF; we have in place a financial monitoring system covering all regional banks and have developed and introduced internal control rules. We have also designated controllers responsible for MLTF-related activities in the Bank’s security divisions. As a result of their checks, more than 580,000 suspicious transactions were reported to the Federal Financial Monitoring Service in 2010.

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