a. Code of Ethics
The Barclays Way is our code of conduct. It establishes the behavioural standards expected of every Barclays employee in our conduct day to day. The Barclays Way sets out how our Purpose and Values should be put in practice and provides a roadmap aligning them to the behavioural, ethical and practical compliance aspects of our work as a bank.
b. Conflicts of interest
Identifying and managing conflicts of interest is fundamental to the conduct of our business as Barclays Africa Group Limited (BAGL), in term of our relationships with customers and the markets in which we operate. Understanding the conflicts of interest that impact or potentially impact the businesses enables us to handle them appropriately. Even if there is no evidence of improper actions, a conflict of interest can create an appearance of impropriety that undermines confidence in BAGL and its employees. If we do not identify and manage our conflicts of interest appropriately, we could harm customers and the markets in which we operate. To find more on how we manage our conflicts of interest, please contact us.
c. Related party transactions policies
Parties are considered to be related to the bank if they have control over the bank, directly or indirectly, or can influence the bank significantly in making financial and operating decisions or vice versa or if they and the bank are subject to common control. The Bank of Mauritius has issued a guideline on Related Party Transactions in December 2011, which sets out the control and monitoring that banks must exercise over related party transactions. It also sets limits on exposures to related parties, which banks cannot exceed without prior approval from the Bank of Mauritius. As part of our policies and practices, and in compliance with the guideline on Related Party Transactions, senior officers are required to disclose their interests in entities and close relatives that deal with us, and that can meet the definition of a related party to the bank. The bank also ensures that all transactions with related parties are carried at arms’ length. To find more on how we manage our related party transactions, please contact us.
d. Information, Information technology and Information security policy
Barclays Bank Mauritius Limited (‘Bank’) is governed by an Enterprise Risk Management Framework where controls, through policies and standards, are enforced to risk manage identified critical risks faced by the Bank. Policies and standards are regularly reviewed and subsequently approved by the Board of the Bank in addition to the Board of Barclays Africa Group Limited. The policies and standards are posted on the organisation’s intranet, accessible to its employees.
The Bank has implemented a set of policies for data management, information security, cyber security and technology risks so as to have a holistic controlled approach for confidentiality, integrity and availability of information created, processed, transmitted, stored and disposed by the Bank. The policies and standards cover information which can be accessed both logically and physically while regular training and awareness programmes are done to ensure common understanding across the Bank.
As per the Enterprise Risk Management Framework, the Bank has also implemented appropriate governance and monitoring teams across different lines of defence, who are responsible to monitor adherence to these policies and standards while assessing their operating effectiveness. Governance forums like the Risk Forum and the Control Forum, which are comprised of relevant members of the Management, are used to review and track remediation of any non-adherence to these policies and standards.
e. Dividend policy
BBML has a Board-approved dividend policy which adheres to the local statutory and regulatory requirements.