The document on professional conduct and ethics in the Iraqi Islamic Commercial Bank sets the ethical standards that employees must adhere to, to maintain public trust, enhance integrity, prevent conflicts of interest, and protect the bank's reputation. The charter also emphasizes the shared responsibility to promote a culture of ethics and integrity through cooperation between managers and employees.
Conduct is the activity expressed by an individual through their relationships with those around them. The rules of conduct are a set of principles and standards aimed at ensuring integrity, transparency, and accountability in all matters related to the Iraqi Islamic Commercial Bank. These rules are legally binding for all employees.
The Iraqi Islamic Commercial Bank is a bank licensed by the Central Bank of Iraq to practice banking activities and services. The Iraqi Islamic Commercial Bank is committed to following best practices and market standards in terms of accountability, transparency, and work ethics to develop and promote sustainability. This code aims to define and identify banking activities and the roles and responsibilities of the team at the Iraqi Islamic Commercial Bank. Every employee, regardless of their job grade, must review and adhere to the principles and standards set forth in the code. Any breach of any provision of this code may lead to actions against the violating employees, in addition to resorting to legal procedures deemed appropriate by the bank. These procedures depend on the nature and extent of the breaches and violations, and the level of non-compliance with the provisions of this conduct code.
Ensuring that all policies and procedures comply with Islamic Sharia and local laws. All employees must be aware of local and international legal and regulatory requirements and policies and adhere to them. Ensuring their implementation will enable the Iraqi Islamic Commercial Bank and its employees to comply and adhere to them. The bank's policies focus on important matters and provide a set of high-level guidelines. All employees are required to review and familiarize themselves with them, especially those related to their responsibilities and personal conduct. Both senior management and department managers establish and update procedures to provide employees with details of the arrangements that must be adhered to ensure compliance with the requirements stated in the policies and make them available for reference within each work unit.
Procedures are more detailed than the policies they support and deal with daily operational requirements. If procedures are not available for a specific area within the activity, the relevant department should be consulted for necessary assistance.
An internal Sharia committee exists to oversee the bank's compliance with Sharia in all its activities.
One of the policies of the Iraqi Islamic Commercial Bank is to maintain the bank's good reputation. All employees are responsible for preserving the bank's reputation in terms of ethical behavior, honesty, fairness, and a sense of responsibility, which should be evident at all times in all dealings and communications, including electronic correspondence with clients, regulators, shareholders, and colleagues, whether during or after working hours, within or outside the bank's premises, or otherwise. Any matters that may threaten the good reputation should be referred to the CEO of the Iraqi Islamic Commercial Bank.
The Iraqi Islamic Commercial Bank seeks to provide and build a supportive work environment to achieve productive and profitable goals for employees and create respect, cooperation, and camaraderie among them, reflecting on their daily interactions with customers.
The Iraqi Islamic Commercial Bank believes that good customer service is fundamental to its culture and approach. Internal policies and procedures are established to ensure the bank's operations are conducted in this manner.
The bank's commitment to adopting the highest standards of corporate governance, compliance with regulations, and accountability is clarified in the bank's mission statement. This commitment is reinforced by a primary obligation towards good customer service.
The Iraqi Islamic Commercial Bank always strives to meet the desired outcomes for all its customers, which is a fundamental requirement in conducting the bank's business.
The Iraqi Islamic Commercial Bank seeks to facilitate the development of a cultural environment that reduces the risk of failure in performing banking tasks assigned to any department, which would limit or reduce exposure to penalties and reputational damage resulting from such failures.
A conflict of interest arises when the interests of the Iraqi Islamic Commercial Bank or the interests of any employee conflict with those of one or more customers.
Officials and employees must disclose to the Human Resources Department any actual or potential conflicts of interest between them and the Iraqi Islamic Commercial Bank. Board members must immediately disclose all actual and potential conflicts of interest to the Board Secretary. Additionally, any other conflicts identified between the Iraqi Islamic Commercial Bank and its customers must be reported to the Compliance Department.
To achieve a single interest, which is the bank's interest, there are essentially four ways to manage conflicts of interest:
Confidential information is information not generally known to the public regarding the bank, its customers, or other parties who have a relationship with the Iraqi Islamic Commercial Bank and expect confidentiality. Confidentiality includes maintaining all non-public information that may be useful or commercially valuable to competitors or that may cause harm to the bank or its customers if disclosed. Employees must maintain complete confidentiality of both confidential and proprietary information obtained through their work. This clause is one of the conditions in any employment contract, and any violation will be fully subject to the law and disciplinary procedures outlined in the Human Resources policy.
Employees are responsible for protecting the bank's confidential information, whether disclosed by its customers, information about the bank and its activities, or information about the employees themselves. The bank adopts a systematic approach to disclosing information to employees based on the need to know, rather than making it generally available to all employees.
Bank information is information that the bank does not want others to see or publish and is related to work within the bank for use by a limited number of employees.
All employees working in the bank's departments must respect the work context. For example, when submitting any transaction or request by bank department employees to the relevant department, they must respect the work context and not exert pressure to execute those transactions immediately, as this behavior will create confusion and distraction in completing transactions. Any department in the bank has the right to follow up on work between the bank's departments in a functional manner that does not exceed reasonable limits. Employees are not allowed to view the margins of executive managers without the approval of the concerned manager to maintain the privacy and confidentiality of information.
It is essential to respect the structure of departments, as administrative overreach on a particular department to obtain administrative approvals from higher authorities in the bank without the knowledge or opinion of the concerned department is considered a breach of the bank's administrative hierarchy.
As a general rule, no gifts should be accepted or offered by suppliers or customers, nor should they be requested by employees. It is acknowledged that giving and receiving small gifts is a common business practice that can be managed properly, provided employees adhere to the highest standards of integrity and honesty and avoid situations that may negatively affect their decisions or actions.
The Iraqi Islamic Commercial Bank and its employees must be careful not to accept or offer any inducements that would call into question their independence. Employees must never seek gifts or rewards. The acceptance of gifts by the Iraqi Islamic Commercial Bank is subject to the conditions stipulated in the Central Bank of Iraq's instructions numbered 9/4/32 and dated 14/1/2024.
The bank must monitor gifts given by its customers to its employees, as accepting gifts may affect the employee's decision regarding the performance of their duties. Therefore, employees must exercise caution and evaluate the expected outcome of accepting gifts or hospitality. If the act of giving gifts and hospitality is intended to influence the decision, it falls under the concept of bribery and corruption.
Accepting gifts by employees may harm the reputation of the bank and the employee themselves. The Iraqi Islamic Commercial Bank does not encourage its employees to receive gifts, especially those not in line with Islamic Sharia principles. To accept gifts, all the following conditions must be met:
The Human Resources Department is required to keep a record of all gifts given to bank employees. The employee evaluates the acceptance of the gift according to the above. This record is available to senior management and regulatory departments in the bank and must include the following information:
Name | Job Title | Department | Section | Type of Gift | Value | Date of Receipt | Gift Giver | Action Taken |
/ | / | / | / | / | / | / | / | / |
The bank adopts a zero-tolerance approach to any bribery or corruption:
All bank departments must adhere to keeping books and records (whether in electronic or printed form) sufficient to issue financial statements and provide a complete record of the business conducted by the bank.
Records must be kept in accordance with the bank's record management policy and anti-money laundering policy to accurately reflect the bank's documents and transactions in compliance with laws and regulations.
Adherence to the record management policy is mandatory for all employees, and all employees must ensure they are aware of and understand the policies and procedures established and available to all employees.
All employees, regardless of their positions, are responsible for protecting and properly using the bank's assets, including office equipment and official stationery needed to perform their duties and tasks, and not misusing them for personal or private purposes.
The Iraqi Islamic Commercial Bank is obligated to comply with anti-money laundering and counter-terrorism financing requirements. The bank must implement and maintain policies and procedures that enable it to identify, assess, and manage financial crime risks, particularly money laundering, sanctions violations, terrorism financing, bribery, and corruption.
The Iraqi Islamic Commercial Bank has a set of control systems and processes to combat money laundering, detailed in the Anti-Money Laundering and Counter-Terrorism Financing Department's policy, which must be acknowledged and adhered to by all employees according to their specialization.
All employees are encouraged to disclose genuine concerns about any potential violations in the context of work execution, whether related to financial reporting or other misconduct, as soon as possible and appropriately, in accordance with the whistleblowing policy in place at the Iraqi Islamic Commercial Bank.
If any employee reasonably and in good faith believes that there are wrongful practices in the workplace, they must immediately report this to their direct manager. However, if they are hesitant to do so for any reason, they should report their concerns to:
The concerned department will be informed of these concerns or violations without disclosing the employee's identity. If these channels are followed but the employee still has concerns, or if the employee feels that there is a critical issue that cannot be discussed with any of the above parties, they should contact the authorized manager.
The Iraqi Islamic Commercial Bank must implement and maintain accounting policies and procedures that enable it to closely monitor its financial and prudential position and provide regulatory authorities with timely financial reports and returns that reflect a true and fair view of its financial position and compliance with all prudential regulatory requirements, adhering to all applicable accounting standards and rules.
The Iraqi Islamic Commercial Bank establishes strong arrangements for the internal audit function to monitor the adequacy and effectiveness of its system.
The internal audit function is carried out by the Internal Audit Department, which must have extensive experience in conducting risk assessments, designing internal audit monitoring programs, and performing related reviews. Internal auditors conduct at least one annual review of the bank's systems and report directly to the Audit Committee of the Board of Directors.
The bank ensures that the Internal Audit Department has unrestricted access to all relevant records and can refer to the relevant committees of the bank's Board of Directors when necessary.
Sharia Internal Audit Function:
The Iraqi Islamic Commercial Bank establishes and maintains strong arrangements for the internal audit function to monitor the adequacy and effectiveness of its system, control processes, and compliance with monitoring procedures.
The internal audit function is carried out by the Sharia Internal Audit and Control Department, which must have extensive experience in conducting risk assessments, designing internal audit monitoring programs, and performing related reviews. Internal auditors conduct at least one annual review of the bank's systems and control processes and report directly to the Sharia Audit Committee of the bank.
The Sharia Internal Audit Department conducts an independent and objective examination of the bank's compliance with Sharia principles, rulings, and fatwas issued by the Sharia Supervisory Board in all its activities. It provides advisory and guidance value to the bank, helping it achieve its goals. The examination includes contracts, agreements, policies, products, transactions, founding contracts, basic regulations, financial statements, and reports, especially internal audit reports and inspection and monitoring reports conducted by the Central Bank of Iraq inspectors.
Sharia Compliance Function:
The Sharia compliance function aims to enhance the governance of Islamic financial institutions in general and Sharia governance in particular. Therefore, an effective Sharia compliance function must exist within the Islamic financial institution to ensure adherence to Islamic Sharia principles and rulings.
To resolve any compliance-related issues with the previous points, there are some steps to keep in mind:
A complaint should be viewed as an opportunity to improve the bank's internal performance and procedures. When receiving a specific complaint from a customer, whether in person by filling out a complaint form in the Financial Inclusion Department, via email, or phone, a detailed and accurate report of the complaint should be submitted to the relevant committee to identify shortcomings and determine the type of violations, whether against general law or the bank's internal instructions.
