Principles of Information Transparency

MDM Bank’s shareholders and management consider information transparency to be one of the most important conditions for establishing civilized business relations in the market, an important prerequisite for achieving sustainable operating results, as well as the keystone in creating successful competition to attract capital investments. Ensuring information transparency by MDM Bank to all stakeholder groups is one of the primary tasks in the Bank’s Corporate Social Responsibility Strategy.

The Bank applies the following key principles when disclosing information to its stakeholders:

• Reliability and consistency. The Bank provides its stakeholders with true information. The Bank also carries out regular controls to ensure that the information it discloses is not distorted and that the information on it disclosed by third persons is not erroneous or false.
• Completeness. The Bank ensures that the information provided to its stakeholders is sufficient for them to form an objective and independent opinion about the Bank. We proceed from the legitimate rights and authority of our stakeholders. Therewith we assume that our stakeholders respect our commitment to never breach the principles of commercial and banking secrecy. The Bank does not elude disclosing unfavorable information on its activities, if such information is important for decision-making by its stakeholders.
• Timeliness. When disclosing information, the Bank strictly observes timing requirements provided for in the acting legislation, bilateral agreements and internal regulatory documents of the Bank. To the extent possible, we strive to follow the best international practice in this sphere.
• Clarity and accessibility. The Bank discloses information in a form and format easily understandable and accessible for its stakeholders. For distribution of information, the Bank uses the most advanced methods and technologies which ensure timely access for the vast majority of the stakeholders.
• Stakeholder inclusiveness. The Bank provides equal opportunities to receive both compulsory and voluntary information for all stakeholder categories, which each has an equal legitimate right to receive such information.
• Control over insider information. The Bank takes measures to prevent the unauthorized usage (incl. for private purposes) and/or transfer of insider information to third parties by the Bank’s employees.

Individual procedures on information disclosure as well as those on distribution of functions and responsibilities in this sphere are described in separate internal regulatory documents of the Bank.

09.10.2007 11:52