Interview Zlatkis

Bella ZlatkisMember 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 information 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 conclusions 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 t he s econd h alf o f t he y ear, p rovisions w ithin t his l aw r egarding 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 increased 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, provisions about conflicts of interest on the financial markets.

The Bank’s plans for 2012 include training each employee in compliance procedures. We will continue to amend our employment contracts in order to limit any possibility that our employees could engage in dealings on the financial markets or disclose sensitive information.

The integration of the investment company Troika Dialog in 2011 increased 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

A socially responsible financial institution is a potential partner for any other socially responsible major business or institution, or any conscientious citizen. We firmly believe that by paying greater attention to social responsibility, we will earn the loyalty of our investors, partners, the general public, customers, regional governments and the monetary authorities.

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