Scope 1 Emissions
2022 Communication on Progress
Isbank (Turkiye Is Bankasi)
Published date
June 30, 2022
No. of questions
64
Supplemental files
2021IntegratedAnnualReport.pdfOHS-Policy (1).pdfHuman_Rights_and_Human_Resources_Policy.pdfİşbank gifts and hospitality policy.pdfCEO Statement
Signed
Governance
Policies and Responsibilities
1. Does the Board / highest governance body or most senior executive of the company:
Optional commentAt İşbank the Sustainability and Risk Committees are chaired by the Chairperson of the Board of Directors. Sustainability Committee has two additional Board members as well as ten Deputy Chief Executives. On the other hand, CEO, CRO, Risk Management Division Head, Internal Control Head and Compliance Division Head are fundamental members of the Risk Committee. In addition to these members, a Board Member appointed by the Committee Chairman and three Deputy Executives appointed by the CEO also serve as Risk Committee members. By the leadership of Board Chair, these committees consider climate change issues when reviewing and guiding business strategy, major plans of action and risk management policies as well as, setting performance objectives, monitoring implementation and performance. The composition of both committees which incorporate different functions of the Bank provides the opportunity for the business units to be represented in an inclusive manner thus, monitoring climate related issues in a holistic way. Climate-related issues are raised to the agenda of the Board by the board level committees, namely Sustainability Committee and Risk Committee. Sustainability Committee holds meetings regularly in order to steer and oversight the ESG strategy and policies of the Bank. Risk management activities of the Bank are conducted by the Risk Management Division reporting to the Risk Committee and the Board of Directors. Financial & non-financial risks are reported to the Risk Committee on a monthly basis and, through the Audit Committee to the Board of Directors respectively. Through the functioning of Sustainability and Risk Committees, climate related considerations are embedded in the most material decisions of the Board, such as reviewing and guiding strategy, major plans of action, risk management policies, business plans and financial planning. Deputy Chief Executive in charge of Investor Relations & Sustainability function assumes the role of Chief Sustainability Officer (CSO), the Sustainability Leader, who is responsible for steering İşbank’s sustainability initiatives and represents the Bank in sustainability communication including stakeholder engagement. Apart from board-level Sustainability Committee and the CSO, there is Sustainability Coordinator and Sustainability Working Group (WG). Head of Investor Relations & Sustainability serves as the Sustainability Coordinator to ensure sustainability issues are effectively embedded in the Bank’s executive bodies. To this end, the Sustainability WG is convened, which contains representatives from all key areas of the Bank, such as credit underwriting, risk management, financial institutions, project finance, product development and marketing, procurement, construction & real estate management, human resources and talent management. The objective of the Sustainability WG is to ensure sustainability & climate-related issues are embedded in business decisions and there is appropriate flow of information across all divisions. The Sustainability WG’s efforts are supported by a dedicated Sustainability Management System. The Sustainability Management System has documented processes, outputs are audited regularly, and audit results are reviewed by the top management. In addition, İşbank has positioned sustainability, which is the basis of its business model, as one of the main focal points of its corporate strategy with a holistic approach. As an indicator of this approach, the Bank has prepared its first Integrated Annual Report, which includes a comprehensive evaluation of its financial and non-financial performance in 2021. The 2021 Integrated Annual Report, which has been approved by the Board of Directors, includes İşbank's 2021 performance, the value created for all of its stakeholders with this performance, the risks and opportunities it has faced in the value creation process, and the integration of the Bank's sustainability priorities into business model and its sustainability targets. Besides, İşbank has a Anti-Bribery and Anti-Corruption Policy which has been approved by the Board of Directors. This policy covers all employees and participations of İşbank (the Bank), the individuals and corporations that act in the name of or provide services to the Bank including outsourcing companies, suppliers, consultants, external auditors and representatives. This Policy aims to enable the compliance of the aforementioned parties with the effective anti bribery and anti-corruption regulations, as well as ethical and professional principles within this context. https://www.isbank.com.tr/en/about-us/Documents/sustainability/anti-bribery-policy.pdf2. Does the company have a publicly stated commitment regarding the following sustainability topics?
Optional commentWe attach importance to develop collaborations with national and international initiatives that will carry our sustainability performance to higher levels. Some initiatives are as follows: - İşbank has strenghtened its commitment to supporting the transition to a net-zero economy by joining another international initiative in line with its sustainability vision. İşbank has joined the industry-led, UN-convened Net-Zero Banking Alliance (NZBA) which brings together banks worldwide committed to aligning their portfolios with net-zero emissions by 2050 in line with the most ambitious targets set by the Paris Climate Agreement. https://www.isbank.com.tr/en/about-us/net-zero-banking-commitment-from-isbank - In 2020, İşbank signed the Principle of Responsible Banking, announced by UNEP FI in 2019 with theaim of aligning the banking sector with the UN Sustainable Development Goals (SDG) and the Paris Climate Agreement. Defining the role of banking in the new economy, these principles aim to maximize the impact of the banking sector in achieving an equal and prosperous future. - İşbank underlined the importance it attaches to gender equality by signing the United Nations Women's Empowerment Principles. https://www.isbank.com.tr/en/about-us/memberships-and-initiatives İşbank adopts Board-level policies which reveal İşbank's sustainability approach. • Sustainability • Environmental and Social Impacts • Human Rights and Human Resources • Anti-bribery and Anti-corruption • Gifts and Hospitality • Gender Equality policies of işbank are available at https://www.isbank.com.tr/en/about-us/our-policies3. Does the company have in place a code of conduct regarding each of the following sustainability topics?
Optional commenthttps://www.isbank.com.tr/en/about-us/Documents/sustainability/suppliercodeofconduct.pdf4. Has the company appointed an individual or group responsible for each of the following sustainability topics?
5. Does the company have a formal structure(s) (such as a cross-functional committee) to address each of the following sustainability topics?
Prevention
6. Does the company have a process or processes to assess risk?
Optional commentFor risk measurement and analysis, the Bank uses top-down risk assessment, impact-likelihood analysis, loss event data analysis, scenario analysis, stress testing and risk indicators. Besides financial risks, non-financial risks such as climate change risk, environmental risks, internal behavior/culture and ethics risks, employee practice and employee relations risks are defined in the Bank's risk catalogue and handled as part of risk management activities. Risks related to people and employee rights are categorized and defined in Bank’s risk catalogue. These risks are measured and analyzed as a part of Bank’s enterprise risk management framework, which covers not only Bank’s own operations and employees, but also customers, suppliers and other value chain parties. For example, investments that are to be financed by the Bank and evaluated the risk score A (high risk) based on the Environmental and Social Risk Evaluation model are subject to an social impact evaluation, including a human rights impact evaluation, in accordance with the requirements of international standards. For environmental risks, the bank evaluates its own risks through a Risk-Control-Self-Assessment (RCSA) study. In addition, all new investment projects to be financed by İşbank with an investment amount of more than USD 10 million are evaluated using the Environmental and Social Risk Evaluation Tool (ÇESMOD). Projects within this scope are subject to environmental and social risk assessment, and a risk score is determined as a result of this assessment. If the risk of a project is determined to be high, an environmental and social action plan is established in cooperation with the customer to eliminate or mitigate the identified effects, and the follow-up of these actions is provided under the supervision of independent consultants, when necessary. The Climate Change Risk Policy, which sets out the principles and procedures to be followed for detecting, identifying, assessing and/or measuring, monitoring, controlling, reporting and managing the climate change risks that the Bank may be exposed to in connection with its activities, was approved and put into force by the Board of Directors in March 2021. As per the decision of the Board of Directors, the indicator "Share of Sectors With High Climate Change Risk Within Total Commercial Portfolio", monitored on a quarterly basis, was added to the Bank's solo risk appetite framework in September 2021 to prevent the concentration of sectors with a high exposure to climate change risks within the portfolio and provide guidance for composition of the portfolio in subsequent periods. The Bank utilizes a scenario approach in measuring climate change risks. For high-risk sectors, which are identified with the climate change heat map method, an impact analysis for climate change risk events is conducted by taking into account the United Nations Environment Program Finance Initiative (UNEP FI) scenario analysis approach. Risk analysis and assessment for measuring and prioritizing bribery and corruption risk also covers not only our own operations, but also other parties in the value chain. As an example, purchases of goods and services from suppliers that are found to be involved in practices of bribery and corruption are suspended, and such suppliers are banned.6.1. During the assessment of risk, which business relationships are reviewed?
Optional commentWith respect to supply chain management, İşbank exercises ESG due dilligence for key suppliers via Supplier Sustainability Performance Measurement Survey that includes questions under the headings of environment, employee and human rights, ethical and sustainable procurement. In 2021, target group of the survey represented 67% of the procurement budget for 2021. In addition, a supplier evaluation study is conducted and a survey is applied to our employees in order to enable our employees who are in contact with our suppliers to evaluate the companies they work with. Within the scope of this survey, there is also a question aiming at the assesment the supplier in terms of sustainability.7. Does the company have a due diligence process through which it identifies, prevents, mitigates, and accounts for actual and potential negative impacts on sustainability topics?
7.1. During the due diligence process, which business relationships are reviewed?
Concerns and grievance mechanisms
8. Are there any processes through which members of the company’s workforce can raise concerns about the company’s conduct related to human rights, labour rights, environment, or anti-corruption?
Optional commentAt İşbank, the ideas and suggestions of our employees are valued. The Bank listens to the employees' suggestions, complaints and feedback through constant communication channels and reflects them in its management and decision-making processes. Various platforms have been created in order to systematically ensure employee communication and participation in İşbank. HR Help Desk (Maximo) is a practice where employee opinions, evaluations, requests and complaints are received and forwarded to the relevant units. Submissions coming through the "Negative News Line" can only be viewed and directly answered by the CEO. Thus, employee privacy and confidentiality is protected at the highest level. In 2021, 314 employees created 344 negative news items, and product and process improvements were evaluated by the related business divisions. Employees can report actual or suspected violations of İşbank's Ethical Principles and Operational Rules, the Bank's policies and internal regulations, as well as national and international legislation via the Ethics Hotline. It is essential that the reports are kept confidential; and unless expressly requested, the name of the reporting person is kept confidential. Employees are not exposed to any disciplinary action, direct or indirect retaliation, or put at any disadvantage compared to their peers for reporting a violation.8.1. Please provide additional detail regarding the process(es) the company has through which members of the company’s workforce can raise concerns about the company’s conduct.
Optional commentVarious platforms have been created in order to systematically ensure employee communication and participation in İşbank. These platforms are available in the 2021 Integrated Annual Report and işbank's website in Turkish & English. In addition,İşbank Ethics Line's Notification Channels are published on the Bank's website and are open to the access of our Bank's employees, customers and all other relevant parties. The confidentiality of the notifications is essential and the identity of the person making the notification is kept confidential unless he/she wishes it to be disclosed. Even if the Bank’s employee conveys his/her suspicion about the non-compliance in question to his/her own manager or to the authorized units of the Bank, the principles regarding the confidentiality of the notification still apply. Confidentiality principles apply to notifications made by third parties as well. According to İşbank's Ethical Principles and Code of Conduct, employees who make notifications in good faith will not be subjected to practices such as disciplinary punishment, disadvantageous treatment compared to peers, or direct or indirect retaliation, solely because of their notification. https://www.isbank.com.tr/en/about-us/Documents/investor-relations/ethical_principles_and_code_of_conduct.pdf9. Does the company provide or enable access to effective remedy to right holders / stakeholders where it has caused or contributed to the adverse impact?
Optional commentNotification Channels - Ethics Line Notification Channels are published on the Bank's website and are open to the access of our Bank's employees, customers and all other relevant parties https://www.isbank.com.tr/en/about-us/Documents/investor-relations/ethical_principles_and_code_of_conduct.pdfLessons
10. How does the company capture lessons regarding each of the following sustainability topics?
Executive Pay
11. Is executive pay linked to performance on one or more of the following sustainability topics?
Optional commentAll C-Suite executives have cost optimization targets, which include the energy costs of their respective units. These are described in our CDP Climate Change Report 2021. Beyond the incentives already in place, İşbank's Human Resources Management and Strategy & Corporate Performance Management divisions are planning an extension of the climate-related targets in the next two years. On the one hand, Human Resources Management will introduce behavioural change related indicators. Employees will be given incentives for participating in a climate change e-learning experience on the Mobile HR app, and aligning their behaviours to our climate targets. On the other hand, our Strategy & Corporate Performance Management division is planning to implement sustainability & environmental (covering climate change) related KPIs in performance cards of employees to incentivize climate related targets in the upcoming 2 years.Board Composition
12. Percentage of individuals within the company’s Board / highest governance body by:
Optional commentAs of 31.12.202113. Do you produce sustainability reporting according to:
Data Assurance
14. Is the information disclosed in this questionnaire assured by a third-party?
Optional commentIndependent Assurance Report of KPMG is available at İşbank 2021 Integrated Annual Report (pp. 467-470) https://www.isbank.com.tr/contentmanagement/IsbankSurdurulebilirlikEN/pdf/2021IntegratedReport.pdfHuman Rights
Materiality / Saliency
1. Which of the following has the company identified as material human rights issues connected with its operations and/or value chain, whether based on their salience (i.e., the most severe potential negative impacts on people) or another basis?
Optional commenthttps://www.isbank.com.tr/en/about-us/Documents/sustainability/Human-Rights.pdf https://www.isbank.com.tr/en/about-us/Documents/sustainability/Gender_Equality_Policy_03_2021_EN.pdf https://www.isbank.com.tr/en/about-us/Documents/sustainability/OHS-Policy.pdf https://www.isbank.com.tr/bankamizi-taniyin/Documents/yatirimci-iliskileri/20220104-PDPP.pdfCommitment
2. Does the company have a policy commitment in relation to the following human rights issues?
Optional commentData subjects are directly and transparently notified about the data processing activities through various suitable channels. Freely given, specific and informed consent is obtained when required. https://www.isbank.com.tr/bankamizi-taniyin/Documents/yatirimci-iliskileri/20220104-PDPP.pdf2.1. For each human rights policy, is it:
Optional commentInformation Security Policy and Personal Data Protection Policies are approved by the Board.Prevention
3. In the course of the reporting period, has the company engaged with affected stakeholders or their legitimate representatives in relation to the following human rights issues?
4. What type of action has the company taken in the reporting period with the aim of preventing/mitigating the risks/impacts associated with this human rights issue?
5. Who receives training for the following human rights issues?
Optional commentThe Bank suggests online training for all employees and training for focus groups regarding information security and personal data protection.6. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following human rights issues?
Response
7. During the reporting period, has the company been involved in providing or enabling remedy where it has caused or contributed to adverse impact associated with the following human rights issue(s)?
8. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the human rights principles, including any challenges faced and actions taken towards prevention and/or remediation.
Responsibilities and principles regarding human rights and human resources practices in our bank are determined in the Human Rights and Human Resources Policy adopted on 31.12.2014.Labour
Commitment
1. Does the company have a policy commitment in relation to the following labour rights principles?
Optional commenthttps://www.isbank.com.tr/en/about-us/Documents/sustainability/Human-Rights.pdf https://www.isbank.com.tr/en/about-us/Documents/sustainability/OHS-Policy.pdf1.1. For each labour rights policy, is it:
Prevention
2. In the course of the reporting period, has the company engaged with affected stakeholders or their legitimate representatives in relation to the following labour rights issues?
Optional commentİşbank closely keeps track of sectoral and global trends in the fields of sustainability, regularly measures stakeholder expectations in this area, and also conducts risk and opportunity analyzes, as well as business processes. In 2021, the Bank updated its sustainability priorities in accordance with the AA1000 Stakeholder Engagement Standard in such a way that it reflected the opinions of İşbank employees and external stakeholder expectations with 1.326 stakeholders. Employee Rights, Commitment and Satisfaction Employee Health and Safety Equal Opportunity and Diversity are among the priority issues of the Bank.3. What type of action has the company taken in the reporting period with the aim of preventing/mitigating the risks/impacts associated with this labour rights issue?
4. Who receives training for the following labour rights issues?
Optional commentTrainings information is available in İşbank 2021 Integrated Annual Report, p. 455, under the title of Human Resources Data. In addition, maintaining a healthy and safe work environment is as important as providing such an environment. Therefore, employees need to have OHS awareness. İşbank organizes trainings to increase OHS awareness among employees. In 2021, 40,146 hours of OHS training were given to 6,529 employees. Source: İşbank 2021 Integrated Annual Report, p. 33. https://www.isbank.com.tr/contentmanagement/IsbankSurdurulebilirlikEN/pdf/2021IntegratedReport.pdf5. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following labour rights issues?
Performance
6. What is the percentage of employees covered under collective bargaining agreements?
Optional commentİşbank 2021 Integrated Annual Report, p. 11. https://www.isbank.com.tr/contentmanagement/IsbankSurdurulebilirlikEN/pdf/2021IntegratedReport.pdf7. What is the percentage of employees in a trade union or other workers' organization?
8. In the course of the reporting period, what was the percentage of women in:
Optional commentAs of 31.12.2022 including the Board of Directors and the Executive Committee.9. What was the average ratio of the basic salary and remuneration of women to men (comparing jobs of equal value) during the reporting period?
Optional commentRemuneration is managed through transparent and measurable processes and systems, and there is no gender-based wage differentiation. In the calculation, monthly regular payments made to employees working in Turkey as of the end of 2021 regardless of their performance were taken into account. Payments such as overtime pay, shift compensation and other social benefits and non-guaranteed payments made once a year were not taken into account. In 2021, İşbank's Board of Inspectors reviewed data pertaining to 85% of all of the Bank's employees, including male and female employees working in the Bank's operations in Turkey, except for middle- and top-level managers. Information was collected about the wages paid in 2021 to the employees included in the review. It was concluded that there is no causality relation between differentiation in wages and the gender of our Bank's employees across all regular wages.10. In the course of the reporting period, how frequently were workers injured (injuries per hour worked)?
11. In the course of the reporting period, what was the company’s incident rate?
Optional comment(Total Number of Lost Days * 200,000)/Total Working HoursResponse and Reporting
12. In the course of the reporting period, has the company been involved in providing or enabling remedy where it has caused or contributed to the adverse impact associated with the following labour rights issues?
13. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the labour rights principles, including any challenges faced and actions taken towards prevention and/or remediation.
The Bank signed a collective bargaining agreement with the authorized union on 27.01.2022 in order to protect employee rights, which it sees as a part of human rights, at the highest level in the sector. In addition, it has implemented flexible working types in order to ensure the health and safety of its employees at work.Environment
Commitment
1. Does the company have a formal policy on the following environmental topics?
Optional commentİşbank has the Environmental and Social Impacts Policy. This policy aims to set forth the principles to be considered by İşbank (the Bank) concerning its activities that have an environmental and social impact. https://www.isbank.com.tr/en/about-us/Documents/sustainability/environment-and-social-impact-policy.pdf Besides, İşbank's Climate Change Risk Policy sets out the principles and procedures to be followed for detecting, identifying,assessing and/or measuring, monitoring, controlling, reporting and managing the climate change risks that the Bank may be exposed to as a result of its activities. Source: 2021 İşbank Integrated Annual Report, p. 153. https://www.isbank.com.tr/contentmanagement/IsbankSurdurulebilirlikEN/pdf/2021IntegratedReport.pdf1.1. For each environmental policy, is it:
Optional commentİşbank has the Environmental and Social Impacts Policy. This policy aims to set forth the principles to be considered by İşbank (the Bank) concerning its activities that have an environmental and social impact. In addition, procurement activities and purchases of goods/services in İşbank are carried out within the framework of the ‘Supplier Code of Conduct’ that sets forth the founding principles and the internal regulations constituted in line with the said policy. https://www.isbank.com.tr/en/about-us/Documents/sustainability/environment-and-social-impact-policy.pdf Besides, İşbank's Climate Change Risk Policy sets out the principles and procedures to be followed for detecting, identifying,assessing and/or measuring, monitoring, controlling, reporting and managing the climate change risks that the Bank may be exposed to as a result of its activities. Source: 2021 İşbank Integrated Annual Report, p. 153.Prevention
2. In the course of the reporting period, has the company engaged with affected stakeholders or their legitimate representatives in relation to the following environmental issues?
Optional commentİşbank closely keeps track of sectoral and global trends in the fields of sustainability, regularly measures stakeholder expectations in this area, and also conducts risk and opportunity analyzes, as well as business processes. In 2021, the Bank updated its sustainability priorities in accordance with the AA1000 Stakeholder Engagement Standard in such a way that it reflected the opinions of İşbank employees and external stakeholder expectations with a large sample size. In 2021, the Bank updated its sustainability priorities in accordance with the AA1000 Stakeholder Engagement Standard in such a way that it reflected the opinions of İşbank employees and external stakeholder expectations with 1.326 stakeholders. The Investor Relations and Sustainability Team met with investors via conferences, roadshows and teleconferences to convey the Bank's attitude towards rapidly changing market dynamics. The Bank also provides regular updates on its ESG performance via the sustainability page of the corporate website. The Investor Relations and Sustainability Division answers all information requests from shareholders as soon as possible via multiple communication platforms, including especially the KAP platform and the corporate website, actively providing information as necessary. On the procurement side in 2021, İşbank conducted a survey designed to evaluate the performance and current status of its suppliers, determined the suppliers’ awareness under specific categories such as Environment, Labor and Human Rights, Ethics and Sustainable Procurement in order to actively manage the environmental and social impact of its supply chain. In addition, organized by the Turkish Marine Research Foundation (TÜDAV), the 3rd Marmara Sea Symposium was held with the main sponsorship of İşbank. Current and vital issues related to the"Marmara Sea" were discussed at the Symposium. In 2021, A consortium, leaded by İşbank as Sustainability Representative, provided USD 100 million in total loan to Dowaksa İleri Kompozit Malzemeler San. Ltd. Şti. For its capacity expansion projects, including the Additional Carbon Fiber Production Line investment. "A Sustainability-Linked Loan Mechanism", which involved the company's green and social targets including energy efficiency, employment and social responsibility indicators, was established in order to improve the sustainability practices in relation to this investment. On the other hand, İşbank reported to the Water Security Program of the Carbon Disclosure Project (CDP) for the first time in 2021. The Bank achieved a score of "B" in the Climate Change Program reporting and a score of "C" in the Water Security reporting under the Carbon Disclosure Project. The Bank has been included in the Sustainalytics ESG risk ratings. It received an ESG score from Refinitiv as part of the BIST Sustainable Index. The Bank was included in the FTSE4Good Emerging Markets Index and the BIST Sustainability Index in 2021 as well.The Bank participated in the Global Compact Turkey Sustainable Banking and Finance Working Group, and contributed to the studies on updating the Global Compact Turkey's Declaration on Sustainable Finance. The Bank conducted impact analyses in accordance with the Principles of Responsible Banking of the United Nations Environment Program Finance Initiative (UNEP FI) as a signatory.3. What type of action has the company taken in the reporting period with the aim of preventing/mitigating the risks/impacts associated with these environmental topics?
4. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following environmental topics?
4.1. For each environmental topic in which the company sets timebound goals / targets, what kind of targets has the company set?
4.2. For each environmental topic in which the company sets timebound goals / targets, how is progress against target / goal tracked?
Optional commentİşbank 2021 Integrated Annual Report, p. 116.5. In the course of the reporting period, has the company been involved in providing or enabling remedy for any actual impacts associated with the following environmental issue(s)?
Climate Action
6. What were the company’s gross global greenhouse gas emissions for the reporting period?
Scope 2 Emissions
Scope 3 Emissions
Optional commentİşbank 2021 CDP Climate Change Report, pp. 30-35, C6. Emissions data, C6.1; https://www.cdp.net/en/responses/21134?back_to=https%3A%2F%2Fwww.cdp.net%2Fen%2Fresponses%3Futf8%3D%25E2%259C%2593%26queries%255Bname%255D%3D%25C4%25B0%25C5%259F%2BBankas&queries%5Bname%5D=%C4%B0%C5%9F+Bankas"7. What percentage of the company's revenue was invested in R&D of low-carbon products/services during this reporting period?
8. Has the organization acted to support climate change adaptation and resilience?
Energy / Resource Use
9. Please report the company's renewable energy consumption as a percentage of total energy consumption in the reporting period.
Technology
10. What percent of the company's revenue came from environmentally friendly products / services during this reporting period?
Sector-specific Questions
11. Which sector(s) does the company operate in? If diversified, choose top 3 by revenue.
Overall Environment
21. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the environment principles, including any challenges faced and actions taken towards prevention and/or remediation.
İşbank Banking is a business model that combines financial and non-financial capital elements with the goal of "producing shareable and sustainable value". With this model, the Bank aims to create value for all its stakeholders both in the short and long term. The value creation model, called "İşbank Banking”, which allows integration of the Bank's sustainability priorities into all decision-making processes, reveals the Bank's understanding of sustainability and the integration of sustainability into business processes. İşbank has positioned sustainability, which is the basis of its business model, as one of the main focal points of its corporate strategy and carries out all its activities in this direction with the participation of all its employees under the ownership of senior management. Looking out for social benefit, as well as the needs and expectations of all its stakeholders, İşbank relates the outputs from its value creation process with the United Nations Sustainable Development Goals that it has contributed to, and demonstrates its support of global goals with the approach of shareable and sustainable value creation. The Board of Directors of the Bank is the highest management authority in İşbank's sustainability management. The "Sustainability Committee" is the management body responsible for the Bank's sustainability activities. It is managed by the Chairperson of the Board of Directors, consists of two members of the Board of Directors and the Executive Committee, where all business units are represented, and enables a holistic follow-up of sustainability issues. The Deputy Chief Executive responsible for the Investor Relations and Sustainability function assumed the role of Sustainability Leader. The Investor Relations and Sustainability Division is responsible for monitoring developments in the field of sustainability, analyzing global trends and ensuring the coordination of these issues within the Bank. İşbank reviews its activities, approaches and strategy in line with developing methodologies and global dynamics on a regular basis. The Bank has structured its perspective on sustainability and its activities in the fields of environment, social and governance under the "Sustainability Management System" it established in 2015, and has been developing this structure both in an organizational sense and with innovations in the end-to-end business model. İşbank's Sustainability Policy and other complementary policies form the basis for the functioning of the Sustainability Management System. İşbank has positioned sustainability, which is the basis of its business model, as one of the main focal points of its corporate strategy with a holistic approach. As an indicator of this approach, the Bank has prepared its first Integrated Annual Report, which includes a comprehensive evaluation of its financial and non-financial performance in 2021. 2021 report summarizes the Bank’s approach to taking responsibility and the value creation for its stakeholders in four main sections. https://www.isbank.com.tr/contentmanagement/IsbankSurdurulebilirlikEN/pdf/2021IntegratedReport.pdfAnti-corruption
Commitment
1. Does the company have an anti-corruption compliance programme?
2. Does your company have policies and recommendations for employees on how to act in case of doubt and/or in situations that may represent a conflict of interest, e.g. with regard to gifts and hospitality, donations, sponsorship, or interactions with public officials?
Optional commentIn addition to the Anti-Bribery and Anti-Corruption Policy, İşbank has the Gifts and Hospitality Policy. It is natural and acceptable that the employees of İşbank (the Bank) build social relationships with their customers. However, it is essential that these relationships do not result in any conflicts of interest. This policy sets forth the legitimate framework of the gifts given or received and the hospitality activities organized in order to strengthen business relationships. https://www.isbank.com.tr/en/about-us/Documents/sustainability/gifts-policy.pdf İşbank also adopts Ethical Principles and Code of Conduct that sets out the ethical code of the Bank as well as the responsibilities and working principles of its employees. https://www.isbank.com.tr/en/about-us/Documents/investor-relations/ethical_principles_and_code_of_conduct.pdfPrevention
3. Who receives training on anti-corruption and integrity?
Optional commentThe content of the e-training "Policy for Combating Financial Crimes and Sanctions Compliance Program", which is assigned to all employees as a mandatory training, is determined by the Corporate Governance Division and covers information about the topic of "Anti-Bribery and Anti-Corruption". Regular communication is carried out to ensure completion of this training by the employees. In 2021, 5,716 employees received 627 hours of anti-bribery and anti-corruption training. Source: 2021 Integrated Annual Report, p. 160.3.1. How often is such training provided?
Optional commentDuring the "Getting to Know Our Bank" course within the scope of "Starting My Career" trainings provided to new employees at İşbank, the requirement to act according to the discipline regulations and the "Ethical Banking Principles" is emphasized. This topic is also covered during the "Policy for Combating Financial Crimes and Sanctions and Compliance Program" class for Officers and Assistant Specialists which is included in the same training program. With the "Banking Law" class included in the Career as a Specialist training for Senior Assistant Specialists and the career training programs for employees promoted to Senior and Assistant Manager roles, information is provided about the legal regulations concerning corruption and other similar crimes. The content of the e-training "Policy for Combating Financial Crimes and Sanctions Compliance Program", which is assigned to all employees as a mandatory training, is determined by the Corporate Governance Division and covers information about the topic of "Anti-Bribery and Anti-Corruption". Regular communication is carried out to ensure completion of this training by the employees. In 2021, 5,716 employees received 627 hours of anti-bribery and anti-corruption training. Source: 2021 Integrated Annual Report, pp. 159-160.4. Does the company monitor its anti-corruption compliance programme?
Response and Reporting
5. Please report the company's total number and nature of incidents of corruption during the reporting year.
6. Within the reporting period, what measures has the company taken to address suspected incidents of corruption independently or in response to a dispute or investigation by a government regulator?
Optional comment7. Does your company engage in Collective Action against corruption?
8. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the anti-corruption principle, including any challenges faced and actions taken towards prevention and/or remediation.
During routine audits conducted by the Board of Inspectors according to Internal Audit Standards, all risks, including antibribery and anti-corruption, are addressed on a periodic basis, and the audit results are reported to authorized divisions of the Bank in accordance with the provisions of applicable legislation, and the outcomes of the reported findings are monitored. Besides existing risks, factors that present potential risks are also identified, appropriate solutions are proposed, and the entire process is monitored. If any violation of anti-corruption policies is detected during the audits, appropriate action is taken according to the internal discipline regulations and legal regulations. In 2021, the Board of Inspectors also conducted inspections concerning the Sustainability Management System and the Compliance Program on Prevention of Laundering Proceeds of Crime and the Financing of Terrorism within the scope of the Head Office audits. Within the scope of 2021 activities, the Bank carried out development and maintenance activities on various practices aiming to provide fast and qualified data for risk assessments, which are the basis for determining personnel-related risks, and for in-house fraud detection and investigation studies. Through examining and reviewing the transactions involving suspicion of misconduct throughout the Bank by the team formed within the Board of Inspectors, the Bank aimed to contribute to both early detection of fraudulent transactions throughout the Bank, and to increase the efficiency and productivity of inspection activities. Source: 2021 İşbank Integrated Annual Report, p. 160. Besides, İşbank regularly organizes annual trainings including fight against bribery and corruption for its employees, and at least once in a year, İşbank Anti-Bribery and Anti-Corruption policy is reviewed by the Corporate Governance Committee in accordance with the requirements and changing operating conditions.