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The Executive

Committee is the body

to which the Steering

Committee’s most

important functions

are delegated.

CODE OF CONDUCT

As such, all members of governing bodies and employees adopt a number of

principles and standards of behaviour that guide their performance in work.

Some professionals are also subject to specific codes of conduct related to

their sphere of work, such as the Internal Regulation for Conduct in the

securities market.

The institution has an Ethics Channel which started to function fully in 2014.

The Ethics Channel is managed by the multi-disciplinary Monitoring Com-

mittee, comprising the Head of Auditing, Control and Compliance, the Se-

cretary General-Director of Legal and Fiscal Advisory Services, and the Di-

rector of the Associate Services and Audit Department.

This Committee is responsible for ensuring the correct functioning of the

communication channel created for employees for matters related to the

Code of Ethics, and passes on the questions and complaints received, gua-

ranteeing privacy, confidentiality, impartiality, efficacy, and objectivity.

The Monitoring Committee received no questions or complaints in 2016.

Access to the ethics code (link)

The Executive Committee is the body to which the Steering Committee’s

most important functions are delegated. This committee is made up of the

company’s Managing Director, the Assistant Managing Directors, and the

Assistant Directors.

The Executive Committee met on nine occasions in 2016.

Executive Committee

Cecabank has an Ethical

Code that formalises

the commitment of

all of the company’s

staff, with the highest

standards of integrity

and professional ethics.

Cecabank

2016 Annual Report

Page. 53

04 CORPORATE GOVERNANCE

4.1

. Governing Bodies

4.2

. General Shareholders’ meeting | Operation and relevant issues

4.3

. Board of directors | Board of Directors’ Committees | Steering Committee | Executive Committee

4.4

. Code of Conduct