In accordance with the high standard of the professional ethics and business practice, we have adopted the Code of ethics. On the basis of it, we regulate relationships with all parties in business – clients, employees, suppliers and the entire community. 


The Code of ethics is the expression of our Bank’s culture we adhere to in our day- to- day work and in all activities we perform.


In case of not observing the Bank’s Code of ethics, please report and submit your complaint to the email address: This email address is being protected from spambots. You need JavaScript enabled to view it.

1. Subject and purpose of the Code of Ethics


The Code of Ethics of Zapad bank AD Podgorica (hereinafter: the Code of Ethics) is a set of standards, ethical norms and professional conduct in performing the tasks that employees of Zapad bank AD Podgorica (hereinafter: employees) shall observe.

The purpose of the Code of Ethics is to improve the behavior of employees in accordance with the basic moral principles and standards of professional conduct, as well as the promotion of corporate values.

2. Application of Code of Ethics


Employees shall do their job consistently by applying ethical standards and rules of conduct.
An employee authorized to make decisions in Zapad bank AD Podgorica (hereinafter: the Bank) shall act within the given authorization, guided primarily by the interests of the Bank.

3. Use of gender-sensitive language


Terms and expression used in the Code of Ethics for persons in the masculine gender shall include the same terms and expressions in the feminine gender.

4. Impartiality and political neutrality


The employee shall perform their duties in impartial and politically neutral manner.
The employee is prohibited from wearing and / or displaying the insignia of political parties or introducing propaganda material at the Bank's official premises.
The employee may engage in political activity solely on his or her own behalf.
The employee is prohibited from influencing the political affiliation of other employees in the bank.

5. Personal and professional integrity


The Bank respects the right of employees to privacy. Personal information about employees is collected, processed, used and stored only to the extent necessary to comply with legal and other regulations relating to employment, work and tax obligations.

6. Loyalty, professionality, kindness and responsibility


The employee is loyal to the Bank and performs his/her duties responsibly, honestly and efficiently, according to professional standards.

In relations with parties, members of the Management and Supervisory Boards, the Secretary and other employees, the Employee shall act honestly and with integrity and perform his/her duties with appropriate skill, due care and commitment.

The employee is aware of the responsibility for violation of work duties, as well as the possibility of conducting court proceedings and penalties.

7. Committment to clients – service users


The employee shall perform his/her duties in such manner that, in the manner prescribed by law, within the established rules and procedures, he/she ensures the exercise of the rights and obligations of the parties – persons and legal entities (hereinafter: service users). If the service user is dissatisfied with the Bank's service, the employee shall inform them that they may, in accordance with the Bank's procedure, file a complaint.

8. Treatment of service-users


In performing their duties, in relation to service users, the employees shall:

  • act correctly, kindly and politely, and base his/her position on objectivity, impartiality and legality,
  • act professionally and constructively, showing interest and patience, especially in relation to an ignorant party,
  • timely, correctly and accurately provide data and information, in accordance with the law and other regulations,
  • be guided by the principle of equality, without granting privileges depending on political attitudes, racial, national, ethnic or social origin, or other personal characteristics,
  • respect the personality and dignity of the person – service user.
9. Conflict of interest

The conflict of interest raises whan the employee has personal interest due to which he/she influences or can influence the impartial and objective performance of duties. This matter is regulated by the Conflict of Interest Management Policy. 
10. Performaning other activities

The employee may not perform activities that are inappropriate or would endanger the reputation and interests of the Bank outside working hours. If the employee is not able to assess it himself, it is necessary to address in writing the head or management board of the Bank and ask for advice.
11. Maintaining public trust

The employee should conduct himself in such manner to keep the public trust in impartial amnd efficient operation of the Bank preserved and improved.
Outside working hours, the employee shall refrain himself from behaviour that could adversely impact the Bank’s reputation.
12. Access to information

The employee shall provide accurate and complete information on issues he/she is authorised for within his/her duties, unless the content of document with restricted access in accordance with the law would be disclosed in that way.  

While performing their work, the employees will not ask to access information not required for his/her work, and shall properly use information available to him/her.
13. Safeguard bank secret

The employee shall safeguard in proper manner information, documents and facts representing the bank secret available to him/her.
14. Reporting unethical requests

An employee who believes that he/she is required to act in manner that is inappropriate, unethical or otherwise inconsistent with the Code of Ethics, shall report such a request to the person responsible for monitoring the compliance with regulations or the Bank's Board of Directors, and act in accordance with law.

The employee shall report violation of rules and principles of the Code of Ethics by other employees.
15. Gifts and offers

An employee may not request payment of remuneration for work for which the payment of remuneration is not prescribed.

An employee may not claim or receive gifts, benefits, privileges, or other benefits for himself, his family, close relatives, friends or other legal entities and persons with whom he has private, business or political contact and cooperation.

An employee may not offer or provide any privileges or gifts in connection with the work he/she performs, unless he/she is authorized to do so by law or other regulations.
16.  Protection of property and assets

The employee shall take care of the effective and economical management and use of material and financial means of work entrusted to him in performing his/her work, as well as to prevent their illegal use.

Employees should take care to take the prescribed measures to protect the entrusted means of work, equipment and objects and to eliminate the possibility of material damage in the Bank, in accordance with the internal act of the Bank.
17. Head of sector-department

The Head of Sector or Department shall point out the errors and ommissions in work of the employee to the Management Board and the Supervisory Board, in order to take appropriate measures in relation to actions that are not in accordance with the provisions of the Code of Ethics.

Heads of sectors, departments, the Head of the Compliance Department, the Secretary of the Bank and the Board of Directors, by their personal conduct, set an example of proper ethical behavior.

Rukovodioci sektora, odjeljenja, Rukovodilac odjeljenja praćenja usklađenosti, sekretar banke i upravni odbor, svojim ličnim ponašanjem daju primjer za pravilno etičko ponašanje.
18. Relation between the head of the sector and employee

The head of the department, in relation to employees should:

  • act correctly and honestly, with due care and respect of the employee,
  • respect impartial advice,
  • provide protection against threats, attacks and other actions insulting the integrity of the employee,
  • ensure the protection of employee’s privacy,
  • dedicate to professional education, professional development, advancement, work culture and continuous improvement of social standards of employees,
  • ensure the employee's conduct in accordance with the standards and rules of the Code of Ethics.
19. Treatment of employee towards other employees


In dealing with other employees in the performance of work, employee should:

  • provide the necessary cooperation,
  • improve the working atmosphere and correct relations with their conduct,
  • not disturb the work process,
  • avoid actions that harass other employees and could have harmful consequences for the operation of the Bank,
  • respects the personal and other characteristics of employees.
20. Treatment of former employees

In providing services and access to information, the employee may not provide privileged access to persons who have terminated their employment in the Bank.

An employee whose employment with the Bank has been terminated is prohibited from using official documents and data of the Bank for the period of 5 years, after termination of employment with the Bank.
21. Employment outside of the Bank

The employee may not abuse his/her work for the purpose of employment outside the Bank.

The employee may not allow employment outside the Bank to provoke a possible or actual conflict of interest, and he is obliged to communicate to the board of directors or the supervisory board any offer of employment that could cause a conflict of interest.

The employee shall immediately inform about the acceptance of the offer for employment outside the Bank.
22. Natural and working environment

The Bank is committed to the active and consistent protection of the living and working environment, with the aim of preserving it for the needs of future generations.

Employees should be committed to improving working conditions in a healthy living and working environment.
23. Decent dress code and conduct

The employee shall protect the reputation of the Bank with decent dress code and personal conduct.
24. Violation of the Code of Ethics

The employee is disciplinary liable for violating the standards and rules of the Code of Ethics, in accordance with the law.
25. Final provisions

The Code of Ethics shall enter into force on the day of its adoption and applied as of 01 January 2022. On the day of application, the Code of Ethics of 04 June 2015 ceases to be valid.