The Bank lays strong emphasis on risk and compliance, and creating awareness among employees on the core values and desired behaviour. Employees are expected to act in accordance with the highest professional and ethical standards.
ICICI Bank is committed to strengthening its culture and encouraging adoption of values and code of conduct among employees and appropriate ways of doing business, where every action is in the interest of customers and the Bank. There is also a continuous endeavour to embed relevant principles and communicate the organisations culture on an ongoing basis. The Bank adopted the Risk and Compliance Culture Policy in fiscal 2022, as we recognise the importance of establishing effective frameworks and supporting processes that encourage employees to exhibit the desired ethos of the Bank.
The Risk and Compliance Culture Policy articulates the guiding principles and aspects for effective implementation of these principles.
The effective implementation of the policy includes a governance framework with roles and responsibilities of the Board, MD & CEO and Executive Directors and the Risk and Compliance Culture Council. Consistent and continuous communication of these principles in interactions with employees is considered an effective mechanism to establish these values that are core to the Bank. In addition, business compliance officers have been appointed within functional teams to strengthen compliance practices. All employees are encouraged to align with the guiding principles while conducting their activities.
The Bank is committed to act professionally and fairly in all its dealings. The ICICI Group Code of Business Conduct and Ethics provides the values, principles and standards that should drive decisions and actions of employees of the Bank. The Code is also the Bank’s commitment to its stakeholders for adhering to the highest ethical standards and dealing with integrity. All new employees are required to complete mandatory training/ e-learning modules pertaining to Code of Conduct, Information Security, Anti-Money Laundering and other compliance-related areas that are critical and sensitive.
As a global bank, the Bank is subjected to Prevention of Corruption Act, 1988 (POCA) in India, Foreign Corrupt Practices Act (FCPA) in the United States of America and similar applicable anti-bribery regulations as amended from time to time in other jurisdictions where the Bank does business and as may be applicable. The Bank has a zero tolerance approach to bribery and corruption. The Bank has a well-defined Anti-Bribery and Anti-Corruption policy articulating the obligations of employees in these matters. The Bank’s third-party vendors are also required to adhere to the Bank’s Anti-Bribery and Anti-Corruption policy, including providing an annual self-declaration confirming their compliance. Apart from an annual review of the policy, the Bank also undertakes periodic external risk assessment of the policy at least once in three years. The last risk assessment was conducted in fiscal 2021, and no material gaps were identified. The Bank’s Vigilance Committee reviews matters pertaining to bribery and corruption.
The Bank has a Board-approved Group Anti-Money Laundering (AML) and Combating Financing of Terrorism (CFT) Policy. The policy specifies a risk-based approach in implementing the AML framework. AML standards of the Bank are primarily based on two pillars, namely, Know-Your-Customer (KYC) and monitoring/reporting of suspicious transactions (MSTR). The policy also specifies monitoring of transactions on pre-defined rules as per the regulatory guidelines and any suspicious transactions found are required to be submitted to the concerned reporting authorities. The Bank through name screening procedure ensures that the identity of the customer does not match with any person with known criminal background or with banned entities. For the purpose of avoiding proliferation financing/terrorism financing, the Bank shall maintain lists of individuals or entities issued by Reserve Bank of India, United Nations Security Council, other regulatory and enforcement agencies, legislation, internal lists as the Bank may decide from time to time. Further, while handling cross-border transactions, the Bank carries out screening of names involved in a transaction against sanctions lists and other negative lists, as applicable.
The Bank continuously focusses on effectiveness of financial controls and assesses compliance with all relevant regulatory requirements. All the key policies of the Bank are regularly reviewed and enhanced to ensure relevance, adherence to regulations and adoption of best practices on an ongoing basis. The Board-approved Group Compliance Policy lays down the compliance framework with emphasis on ensuring that products, customer offerings and activities conform to rules and regulations and adheres to the Bank's ethos of 'Fair to Customer, Fair to Bank'.
The Bank undertakes periodic training sessions and sends information mailers, as part of knowledge-enhancement and awareness, to employees. The frequency of messages are high with regard to areas like fraud risk management, data privacy, cybersecurity, compliance policies, conflict of interest, sexual harassment, etc. The Bank is committed to constantly reviewing its governance practices and frameworks, with a focus on staying updated and responsive to the dynamic and evolving landscape, and acting in the best interest of all stakeholders.
Fair to Customer, Fair to Bank
