Risk and Compliance Culture, and Values

Risk and Compliance Culture

Building trust with all stakeholders is critical to ICICI Bank’s strategic objectives. The Bank continues to focus on a strong risk and compliance culture that underpins our engagement with them.

The Bank continuously endeavours to strengthen its culture and encouraging adoption of values, code of conduct among employees and doing business in a fair and transparent manner. Every action is aimed at benefiting the customer and the Bank. The Bank strives to embed relevant principles and communicate the organisation’s culture on an ongoing basis. It has put in place a Risk and Compliance Culture Policy, that enumerates the guiding principles for strengthening the risk and compliance culture, recognising the importance of establishing effective frameworks and supporting processes that encourage employees to exhibit the desired ethos of the Bank.

For the effective implementation of the policy, the Bank has put in place a governance framework that defines the roles and responsibilities of the Board, MD and CEO, Executive Directors, and the Risk and Compliance Culture Council. The Council undertakes periodic review of the status of implementation of the policy and updates are provided to the Board on an annual basis. Consistent and continuous communication of these principles during employee interactions is one of the adopted approaches for establishing these core values. All employees are encouraged to align with these guiding principles in their activities. Additionally, business compliance officers are appointed within functional teams to strengthen compliance practices. The guiding principles under the Risk and Compliance Culture Policy are communicated to all new employees as part of their induction programme. In addition, train the trainer sessions and dilemma training workshops are conducted for customer-facing employees to ensure effective implementation of Risk culture.

Group Code of Business Conduct and Ethics

ICICI Bank expects its employees, officers and Directors to act in accordance with high professional, governance, legal and ethical standards in all its dealings. To aid in achieving these objectives, the Bank has put in place ‘The ICICI Group Code of Business Conduct and Ethics’. This Code provides the values, principles and standards that should guide the decisions and actions of the Bank employees. All new employees must complete mandatory training and e-learning modules on the Code of Conduct, Information Security, Anti-Money Laundering and other critical/sensitive compliance-related areas. The Code is reviewed once a year and the latest Code is available on the website of the Bank. Additionally, in compliance with the SEBI Listing Regulations, a confirmation from the Managing Director and CEO regarding compliance with the Code by all the Directors and senior management forms part of the Annual Report.

Whistle Blower Policy

The Bank has formulated a Whistle Blower Policy which is periodically reviewed. The policy comprehensively provides an opportunity for any employee (including directors), secondees or stakeholders of the Bank to raise any issue concerning breaches of law, accounting policies or any act resulting in financial or reputation loss and misuse of office or suspected or actual fraud. The policy lays out a mechanism to report such concerns to the Audit Committee through specified channels. The policy is periodically communicated to the employees and is also posted on the Bank’s intranet. Issues raised under the Whistle Blower Policy or to senior management are investigated for appropriate action, including an assessment of the impact on financial statements, if any. The Whistle Blower Policy complies with the requirements of vigil mechanism as stipulated under Section 177 of the Companies Act, 2013 and other applicable laws, rules and regulations. The details of establishment of the Whistle Blower Policy/vigil mechanism have been disclosed on the website of the Bank.

In whistle blowing cases, the identity of the whistle blower is not revealed. The Bank also does not tolerate any attempt on the part of anyone to retaliate, to cause disadvantage or to discriminate against any person who has reported to the Bank serious and genuine concerns regarding an apparent wrong-doing. Protection under the policy is available to the employee who raises the concern under this policy till such time that the complainant’s employment subsists with the Bank or its subsidiaries.

Group Anti-Money Laundering and Combating Financing of Terrorism Policy

ICICI Bank has a Board-approved Know Your Customer (KYC), Anti-Money Laundering (AML) and Combating Financing of Terrorism (CFT) Policy The policy lays down a risk-based approach in implementing the AML framework. AML standards of the Bank are mainly based on two pillars, namely Know-Your-Customer (KYC) and monitoring/reporting of suspicious transactions (MSTR). The policy also requires monitoring of transactions based on pre-defined rules as per regulatory guidelines and any suspicious transactions found are required to be submitted to the concerned reporting authorities.