Code of Ethics

1. Purpose

The Code of Ethics is the foundational policy and guiding framework for performing your role.

It sets clear expectations for engaging with and balancing the interests of our stakeholders: customers, shareholders, regulators, suppliers, colleagues and the communities in which we operate. It also includes our expectations for when you represent GoTyme Bank. To achieve our vision, we must earn and keep the trust of our customers, shareholders, regulators, suppliers, colleagues and the many communities in which we operate. We must always act according to our vision and values. If we all do, we can have a consistent, positive impact.

2. General Principles

The Code of Ethics:

• Can help you make the right decisions. Your decisions can be shaped by two important questions: Can we do this – does it comply with relevant laws, regulations and GoTyme Bank’s policies? Should we do this – is it aligned to our vision and values?
• Should inspire you to perform at your best and seek to achieve our vision and live our values. You are required to comply with this Code of Ethics both when you are at work and beyond to the extent that your behaviour could damage GoTyme Bank’s reputation or interests. This is important because our stakeholders may see you as representing GoTyme Bank even when you are not at work.
• Your actions can have a significant impact on our stakeholders and the trust they place in us and affect your colleagues and how they live our vision and values. Throughout your time at GoTyme Bank it is an essential requirement that you and each of your colleagues commit to and comply with the following common principles:

3. Employee Commitments

All employees are required to make the below undertakings.

I commit to honesty and fair treatment

• I will be honest and demonstrate integrity in every aspect of my work and whenever I represent GoTyme Bank, including in balancing and fulfilling customer, shareholder, colleague and other stakeholder needs.
• I will act fairly, ethically and reasonably whenever I represent GoTyme Bank in my dealings with customers, colleagues and other stakeholders.
• I will maintain the good reputation of GoTyme Bank and perform my duties diligently and conscientiously, in the best interest of GoTyme Bank and its customers.
• I recognise this is essential to our stakeholders’ trust in us.
• I will be straightforward in how I create, improve and talk about our products and services; thorough in how I manage risk; and transparent in the way I provide necessary information on our business whilst also maintaining my commitment to confidentiality.
• I will express to my colleagues, manager or other leaders my full and truthful views, positive or negative, on GoTyme Bank’s business, practices and policies and their effects upon our stakeholders.
• I will quickly and openly acknowledge my mistakes and talk to my manager about them.
• To support our performance framework, I will respond to appropriate requests for feedback on my colleagues’ demonstration of our vision and values with honest, fact-based input.
• I understand that dishonesty conflicts with our vision and values. I will be vigilant in identifying and reporting any knowledge of dishonesty, fraud, breach of policy or law, concealed practices, errors or risks that may affect GoTyme Bank or our stakeholders.
• I understand that any legitimate concerns I raise will be taken seriously and, upon request, will be treated in confidence.

I commit to maintaining confidentiality

• I understand that when I act on behalf of customers, shareholders, colleagues or other stakeholders in my role, they trust me to protect their valuable property, including their personal and other information.
• I will treat their and GoTyme Bank’s information in confidence, respecting GoTyme Bank and our stakeholders’ trust.
• I will not use this information for inappropriate purposes or personal gain or allow unauthorised access to it.
• I will only engage with regulators or the media, or make public statements about GoTyme Bank, if required and authorised. If so, I will comply with relevant policy and only use verified, accurate and authorised information.
• I am bound by this commitment to confidentiality even if I leave GoTyme Bank.

I commit to disclosing and managing conflicts of interest

• I understand that a conflict of interest arises where my personal interests, or those of someone close to me, conflict with the interests of GoTyme Bank or our stakeholders.
• This could include the misuse of information obtained in my role, being influenced by personal relationships with customers, suppliers or colleagues, accepting gifts or hospitality from third parties or where I, or someone close to me, may stand to benefit from a transaction between GoTyme Bank and another party.
• I recognise that conflicts of interest could harm our stakeholders’ trust in GoTyme Bank.
• I will avoid actual or potential conflicts wherever possible. If any conflict arises or could be perceived, I will disclose it to my manager, ensure the conflict is appropriately managed in ways consistent with all other relevant policies and that I have permission to continue before I act.
• I will not use information obtained during my work for my own benefit, for those close to me or for other purposes not connected with my role and duties.

I commit to appropriate use of technology and communications

• I commit to using GoTyme Bank technology and communications in my role for business and limited personal uses in an appropriate way, not in an offensive manner and consistently with the law, our values and all policies.
• I will only transmit confidential or customer information by using GoTyme Bank technology and communications, when I am expressly authorised to do so and in compliance with GoTyme Bank’s security protocols.
• I will not allow unauthorised access to any GoTyme Bank information, systems or assets.
• I recognise that my use of social media can reflect on me personally and professionally as well as on GoTyme Bank. If my use of social media could be connected to my employment with GoTyme Bank, I will be responsible for its appropriateness, lawfulness and demonstrate respect for the people and communities I interact with and be clear I am representing only myself unless the content is properly approved in advance by GoTyme Bank.
• I will act in accordance with GoTyme Bank’s social and other media policies at all times.

I commit to operating in a safe and inclusive manner

• I commit to treating customers, shareholders, colleagues, suppliers and other stakeholders fairly and with respect, regardless of gender, culture, belief, sexual identity, disability or age.
• I will uphold GoTyme Bank’s high standards of workplace conduct and our commitment to eliminating unlawful discrimination, harassment, bullying and victimisation.
• I will also take appropriate care for the wellbeing, health and safety of me, my colleagues and our stakeholders, including only allowing authorised access to Group premises.
• This includes taking part in safety awareness learning and hazard and risk management, including reporting any safety, health or wellbeing concerns immediately. When working, or afterhours when I am identifiable as a GoTyme Bank employee, regardless of location, I will comply with GoTyme Bank’s policy relating to alcohol and drugs.

I commit to maintaining personal standards that support our vision and values

• I understand that our stakeholders’ experience with us in and beyond our workplace shapes their view of and trust in GoTyme Bank and our values and impacts our reputation.
• I commit to contributing positively to this by maintaining personal standards, behaviours, finances and relationships at work and beyond (where my actions could impact GoTyme Bank’s interests) in ways consistent with our vision and values, which protect and enhance GoTyme Bank’s reputation and which maintain my ability to perform my role.
• I will do my best to manage my personal finances in a prudent manner and take care not to over commit myself. If I am experiencing any personal or financial difficulties, I know I am able to raise these with my manager and discuss support which may be available through our Employee Assistance programme or other external programmes.
• I will inform my manager if I am involved in any bankruptcy or similar action, or am in serious financial or other difficulty which could impact the performance of my role.
• I will abide by GoTyme Bank’s zero tolerance to bribery, corruption and facilitation of payments and I will comply with relevant GoTyme Bank expense policies.

I commit to understanding and fulfilling all aspects of my role

• I will meet all requirements of my role to the best of my ability, including complying with all laws, general and specific GoTyme Bank policies applying to my role, management directions, training and certification requirements, and exercising the appropriate authority of my role.
• When dealing with customers, I will act in a courteous and efficient manner and provide clear information to customers at all times, as required by my employment responsibilities.
• This also means meeting customer needs and only offering appropriate products and services for which I am appropriately authorised and trained.
• External roles or appointments may affect my capacity to perform my role at GoTyme Bank. I will only hold external employment, directorships or honorary positions in clubs, charities or community organisations or stand for political or public office if there is no conflict with or adverse effect on my duties or GoTyme Bank’s reputation. I will obtain my manager’s written approval before seeking or accepting any such external roles.

The Code of Ethics contains fundamental and common principles which are critical to us achieving our vision and living our values. It is a GoTyme Bank policy which is essential for every role and one with which all employees must comply.

You are accountable for your individual commitments and actions and should support your colleagues in upholding their commitments. Failure to comply with this policy is serious and may have various consequences, including disciplinary action and dismissal.

Contributing your ideas and expressing any concerns are both critical to our vision and values. You are encouraged to share your input on any topic in a genuine way and in good faith. If you don’t think you can uphold the commitments in this policy, or you see others failing to uphold theirs, you should discuss your concerns with your manager, other leaders or your human resources partners. Employees and management are open to give and receive feedback.