Banky’s Understanding: Insider Trading: Employees trading based on internal information NOT available to public. Example: selling stocks of a company before its bank account becomes NPA (not publicly announced). SEBI insider trading rules. Quarterly declarations by employees. Proprietary Data: Intellectual property, trade secrets. ALL stakeholder data (customers, vendors, promoters, investors) must be kept confidential. Key strategies and sensitive data not to be revealed to competitors. Bribes: Money or gifts to get favourable treatment. In: credit appraisals, loan disbursements, monitoring, recovery, marketing, dealing with agencies. Both taking AND giving bribes = unlawful and punishable. All are violations of Code of Conduct.

Banky’s Understanding: Sexual Harassment: RBI advised banks Feb 1998 to implement Supreme Court guidelines. 5 acts of sexual harassment: (a) Physical contact. (b) Demand or request for sexual favours. (c) Sexually coloured remarks. (d) Showing pornography. (e) Any other unwelcome physical, verbal, or non-verbal conduct of sexual nature. When: victim has reasonable apprehension of humiliation, health/safety risk, or disadvantage in employment (recruiting/promotion). Creates hostile work environment. Requirements: Complaints committee mandatory. Appropriate work conditions (work, leisure, health, hygiene). No hostile environment. Women not to be disadvantaged. Employees aware of definitions and prohibitions. Conduct rules must cover these aspects with appropriate penalties.

Banky’s Understanding: Conflict of Interest: Person derives personal benefit from official decisions. Types: (1) Bank and its client/s. (2) Among employees. (3) Employee and a client. (4) Bank and multiple clients. (5) Between bank services to different clients. Resolution: identify and prevent, institutional controls, full disclosures to affected parties. Top management must recognise and take pre-emptive measures. Fair Accounting: RBI instructions on financial statements and disclosures. Minimum disclosures in Notes to Accounts. Banks comply with Accounting Standards (Companies Act 2021). Related party transactions must be disclosed. Transparency and accuracy in all financial reporting.

Banky’s Understanding: Job Discrimination: Differentiating employees based on religion, caste, sex, or race = PROHIBITED. From entry to working conditions, emoluments, and promotions. Proper HR practices required. Employee conduct in inter-personal behaviours must be non-discriminatory. Third-Party Obligations: When bank outsources functions: clear, transparent contracts and agreements. Service Level Agreements (SLAs) defined minutely. Third party must not cause inconvenience to customers. Bank remains responsible for outsourced services.