Protection of Inside Information
In order to prevent unlawful use and disclosure of inside information, the Bank has established an inside information protection system whose main purpose is to secure and protect documents containing inside information, protect systems containing inside information and control the circulation of documents containing inside information.
The Rules currently in effect also include a prohibition on using or disclosing inside information, or recommending or inducing another person to acquire or dispose of financial instruments on the basis of inside information which relates to such instruments.
The above prohibition applies to all persons who hold inside information as a result of performing various functions in the Bank's governing bodies, having access to such information in connection with their employment, practised profession, or a mandate contract or any other legal relation of a similar nature, and in particular to:
- members of the Management Board, the Supervisory Board, proxies or attorneys-in-fact of the Bank, its employees, auditors or other persons related to the Bank under a mandate contract or any legal relation of a similar nature (primary insiders),
- the Bank shareholders, and,
- persons employed or holding posts referred to in item 1 in a subsidiary company or the parent company of the Bank, or bound with such company under a mandate contract or any other legal relation of a similar nature.
The Bank monitors compliance with the above prohibition in accordance with the Rules. The Rules also define the manner of proceeding in the event of a reasonable suspicion of unlawful use or disclosure of inside information, non compliance with the disclosure requirements or entry into a prohibited transaction during a restricted period.