COMPLIANCE
Declaration of Compliance:
BKT Banking Group is committed to fully comply with the legal and regulatory framework of the jurisdictions in which it operates, and in particular in regards to:
- Prevention of money laundering and the financing of terrorism
- Compliance with international sanctions;
- Prevention of bribery and corruption;
- Data Protection;
- Human Rights Protection;
- Compliance with the legal framework on competition; and
- Compliance with principles of corporate governance.
BKT Banking Group is also committed in minimizing the impact on the environment in the activity that executes and above all is engaged in supporting projects and business relationships with a focus on environmental protection and social responsibility.
Prevention of money laundering and financing of terrorism as well as compliance with International Sanctions:
BKT Banking Group is fully committed in the fight against money laundering and the financing of terrorism, as well as full compliance with international sanctions, and operates on the principle of "zero tolerance" towards any activity related to the above. For this purpose BKT Sh.a:
- Performs due diligence and enhanced due diligence measures in identifying clients and business partners (or third parties) and prior to or during the processing of transactions.
- Implements the most advanced and well-known systems of transactions monitoring and identification of suspicious activities to prevent any transaction or activity with a risk of money laundering, terrorist financing or non-compliance with sanctions provisions.
- Cooperates closely with the authorities of the countries where it operates, central banks and correspondent banks on implementing measures and preventing any suspicious activity or transaction.
- Invests in the training and specialization of dedicated staff.
- Updates and adapts the internal regulatory framework and international sanctions lists to ensure compliance with prevention requirements.
Conflict of Interest
A conflict of interest is a situation where one or more persons or entities have conflicting interests and the pursuing of one party's interest may bring harm to another party.
This circumstances may arise between Banka Kombëtare Tregtare and its clients, staff members and customers, two or more costumers and/or a third party.
The mere fact that a conflict of interest exists does not guarantee that harm to one party will materialize, rather it only indicates simply the existence of an applicable risk.
As part of our commitment to upholding a high standard of ethics and risk management in compliance with the Code of Business Ethics, Banka Kombëtare Tregtare establishes an internal regulatory framework to recognize, handle, and document any potential conflicts of interest that may arise as part of the activity performed by the bank.
This internal regulatory framework is based on the legal provisions of the jurisdictions where the activity is conducted, the Code of Business Ethics, and local or international best practices.
The management of potential conflicts of interest is a continuous process that requires for the utmost commitment from all staff members at all levels in order to protect the interests of BKT Banking Group and its clients.
The fight against corruption and bribery
BKT Banking Group upholds a high standard of integrity and culture among its employees as well as those of third parties/partners in the provision of services, to combat corruption and bribery. The only way to guarantee a sustainable business development and the trust of customers, shareholders, and the communities in which it operates is to act with a high degree of integrity.
BKT Banking Group applies a "zero tolerance" stance against any form of bribery and corruption. This standard is implemented and put into practice by the internal policies of the bank and the principles of the Code of Business Ethics, which prohibit any form of offering or gift or event that could influence decision-making or can be interpreted as bribery or corruption.
In order to identify, prevent and report any activity that can be considered as bribery or corruption, Banka Kombëtare Tregtare:
- Establishes and implements an effective internal regulatory framework;
- Has a well-defined organizational and governance structure;
- Maintains precise and accurate records of all interactions and transactions with customers, suppliers and third parties when rendering services;
- Performs ongoing monitoring of activities of branches, agents or entities owned or operating on behalf of Banka Kombëtare Tregtare;
- Implements secure whistleblowing channels and reporting lines for identification of possible cases of corruption and bribery;
- Performs periodic risk assessment evaluations;
- Conducts periodic trainings to raise awareness of the staff.
In any event, it is the duty of the responsible persons who investigates whistleblowing cases, to preserve the whistleblower’s confidentiality in accordance with the provisions of Law No. 60/2016 "On reporting and protection of whistleblowers". Please refer to the authority's website, to learn more about the legal framework’s provisions. (https://www.ildkpki.al/).
Whistleblowing
Whistleblowing is one of the most effective processes for identifying ethical, procedural, professional violations, corruption acts or fraud attempts. Banka Kombëtare Tregtare for the purposes of reporting has implemented dedicated external and internal reporting channels where maximum confidentiality is guaranteed, protecting the whistleblower and his legitimate personal interests from any possible vindictive or discriminatory behavior.
All employees of Banka Kombëtare Tregtare are responsible for reporting any illegal activity (such as corruption) or any other case of fraud of which they are aware.
Any individual during or in connection with his banking activity, who is made aware of suspected practices of fraudulent, corruption, unethical or malicious activities, may exercise the right to report.
Whistleblowers must act in good faith and not make false allegations in reports provided.
For whistleblowing reports in regards to acts of bribery or corruption, the whistleblower may choose to remain completely anonymous, only if the reasons for anonymity are well stated and the information provided contains the minimal information necessary to properly investigate the reported case.
Everyone is encouraged to report any violations, if deemed appropriate, through the following channels:
Mandatory Deposit Insurance
All deposit accounts at Banka Kombëtare Tregtare in ALL or any foreign currency, whether held by individuals, commercial or corporate clients, resident or non-resident, and regardless of Albanian or foreign citizenship, are provided with insurance by the Deposit Insurance Agency (ASD), to the extent of 2,500,000 (two million five hundred thousand) ALL (or its equivalent in foreign currency), pursuant to the provisions set forth in Law No. 53 dated 22.05.2014,”On Deposit Insurance”, as amended. For additional details, please visit: www.asd.gov.al
For more information, the official leaflet as below:
https://asd.gov.al/wp-content/uploads/2024/04/Fletepalosje-informuese-ASD-per-bankat-2021.pdf
Data protection
Banka Kombëtare Tregtare acts in full compliance with the legal framework for the protection of personal data and “Bank Secrecy”. Data protection is a top concern for BKT Banking Group. and we make sure to only collaborate with partners who can likewise demonstrate an adequate level of data protection. We process personal data only if we have obtained the express consent of the data subject, if consent is provided to carry out a contract that the data subject has signed, or if the applicable legal framework in force permits the processing of the data for the specific purpose.
Any data that is classified as a “Bank Secret”, including transactions or any other activity of the client, is handled with the utmost confidentiality and all employees or other bank units are only granted limited access to data that is designated as a “Bank Secret” based on the “Need to Know” principle to fulfill the functions they exercise at the bank.
Banka Kombëtare Tregtare for the purpose of data protection, categorizes the data it processes based on sensitivity, establishes internal organizational and procedural requirements, and implements measures and control systems to prevent unauthorized access to data. Employees are required to attend specialized trainings in regards to compliance with bank secrecy and personal data protection requirements and provisions, in order to increase vigilance and awareness and stay up to date with best practices.
Obligation to update personal information
Based on the provisions of:
- Law No. 9917/2008 "On the Prevention of Money Laundering and Financing of Terrorism", amended,
- Law No. 9887/2008 "On the Protection of Personal Data",
- Law No. 4/2020, "On the Automatic Exchange of Financial Account Information"
It is mandatory for all costumers of Banka Kombëtare Tregtare to provide accurate and complete data and information and to visit one of the branches in any case in order to update the previously disclosed information whenever there are any changes.
Wolsfberg Questionnaire
USA Patriotic Act