PASHA_BANK_ANNUAL REPORT 2022

72 PASHA Bank 2022 Annual Report PASHA Bank has established an equilibrium policy regarding stakeholders in order to tackle any potential conflicts of interest among them in a balanced manner within the framework of the Corporate Governance Policy. The Bank follows the general principles and code of practice defined in the Conflicts of Interest Policy in managing potential conflicts of interest among stakeholders as described below, and implements the measures set forth in the aforementioned policy to prevent conflicts of interest. • Conflict of interest between the Bank and its customers; • Conflict of interest between the Bank and its employees; • Conflict of interest between employees and/or functions; • Conflict of interest between customers; • Conflict of interest between the Bank’s employees and customers. Compliance Department Manager is responsible for sharing incidents of conflict of interest detected with the Audit Committee and reporting them to the Human Resources Department and Internal Audit Department via the Compliance Report. Human Resources Department is responsible for reporting those cases which were communicated by the Compliance Department to the Human Resources Committee, along with the solutions and action plans determined by the Committees of the Headquarters. PASHA Bank announces to the public its Conflict of Interest Policy and Corporate Governance Policy by publishing the same on the corporate website. The Audit Committee conducted a risk assessment on the support services procured by the Bank; and prepared an evaluation report on whether or not any situation has emerged in a way to prevent or pose a risk for the effective and efficient functioning of the Bank’s internal systems or performance of internal control or internal audit activities in procurement of support services; as well as whether or not the qualified shareholders of, and managers authorized to represent, the support service organizations continue to meet the criteria required by law. The committee submitted the report to the Board, and monitored the efficiency of the services performed by support service organizations regularly. No conflict of interest was found in the evaluations made by the Committee. Moreover, independence of activities between the Bank and the chairman and members of the board of directors, managers, appraisal experts, employees and auditors of the appraisal institutions which the Bank procured services from in 2021 were reviewed. No conflicts of interest were noticed for the Bank and the risk group which includes the Bank other than the ones anticipated at the appraisal service agreement. Measures Intended to Prevent Conflicts of Interest