CODE OF CONDUCT

of
VIETNAM PROSPERITY
JOINT-STOCK COMMERCIAL BANK

Issued with Decision

No. 729/2013/QD-HDQT, dated 20 November 2013
 CODE OF CONDUCT 02

Table of Contents
Enquiry Handling & Misconduct Reporting 3
Contact Point Telephone Numbers and Addresses 3
Article 1: Introduction to 6 Core Values of VPBank 4
Article 2: Introduction to the Code of Conduct of VPBank 5
Article 3: Responsibilities towards VPBank 6
Article 4: Responsibilities towards colleagues 9
Article 5: Responsibility to customers, partners, suppliers, and other stakeholders 10
Article 6: Responsibilities towards State’s legal and regulatory agencies 11
Article 7: Responsibilities towards the community 11
Article 8: Guidance for complying with VPBank’s Code of Conduct 12
 CODE OF CONDUCT 03

Enquiry Handling & Misconduct Reporting

Q&A
As a VPBank’s employee, if you are not sure
whether or not your decision violates the
ethical standards after answering all the
questions in Article 8 of this Code of Conduct,
you should contact your direct manager or the
Legal and Compliance Center via the phone
numbers and addresses below for advice. You
should immediately report to the Legal and
Compliance Center when detecting any
misconduct or sign of arising misconduct.
VPBank is committed to keeping confidential
the identity of the employee who reports
misconducts/signs of misconduct and strictly
prohibiting all acts of retaliation against those
who have reported misconducts/signs of
misconduct.

Contact Point Telephone

Numbers and Addresses
You can raise enquiries or report misconducts or
signs of arising misconduct by contacting the
following address and telephone numbers:

Compliance Department under Legal and Compliance Center

Telephone number: (04) 39385111 (Ext: 100515; 100513)
Email: kiemsoattuanthu@vpb.com.vn
Address: 4th Floor, 72 Tran Hung Dao, Hoan Kiem, Hanoi.
Head of Internal Audit
Telephone number: (04) 73056600 (Ext: 8259)
Address: 6th Floor, 72 Tran Hung Dao, Hoan Kiem, Hanoi.
Head of Supervisory Board
Telephone number: (04) 39288898
Address: 6th Floor, 72 Tran Hung Dao, Hoan Kiem, Hanoi.
 CODE OF CONDUCT 04

Chapter I:
INTRODUCTION
Article 1: Introduction to 6 Core Values of VPBank
This Code of Conduct was prepared on the basis of the 6 Core Values of VPBank:

1. Customer Focus
a) Always respect customers.
b) Understand the needs of customers to advise the best products and services to
satisfy customers’ expectations to the fullest.
c) Focus all resources on serving customers, reflected in both specific actions as
well as policy development.

2. Productivity
a) Value both results and behaviors in creating results.
b) Adopt ongoing process improvement, optimize resources and minimize waste.
c) Celebrate all innovations to deliver superior products and services with
outstanding quality and lower cost.

3. Ambition
a) Show no complacency to the status quo and always set out challenging
objectives.
b) All impossible targets are made possible with a specific roadmap.
c) Take initiatives to build foundations for a future sustainable growth.

4. People Development
a) Develop human resources for the long-term prosperity of VPBank.
b) VPBank is the destination of all potential talents and home of ambitious talents.
c) Developing suitable career paths and promotion programs for each individual to
reach his/her full potential and dream career is the responsibility of managers of
all levels.

5. Trust
a) Win trust of customers, colleagues and partners.
b) Build trust in the principle of mutual benefits.
c) Be honest and objective in all activities.

6. Make a Difference
a) Be a model enterprise for a prosperous Vietnam.
b) Be a trusted partner and respected recruiter.
c) Share success with all members of the organization and with the community.
 CODE OF CONDUCT 05

Article 2. Introduction to the Code of Conduct of VPBank

1. VPBank takes its pride in being one of

the first joint-stock
commercial banks
established in Vietnam. In
its development history,
VPBank has steadily
overcome challenges to
honorably take a firm position
among the top joint-stock
commercial banks in Vietnam
today. This achievement is
attributable to endless efforts of
many staff generations, who have
always embraced VPBank’s core
values and contributed to building
VPBank’s reputation and prestige.
2. This Code of Conduct was prepared to set
out professional ethical standards, with an
aim to guide our behaviors to be in line with
VPBank’s core values.
3. This Code of Ethics is applicable to all 6. VPBank shall strictly deal with any behavior
employees of VPBank. The compliance with which is against the standards set forth in this
standards set out in this Code of Conduct is the Code of Conduct. VPBank expects each of its
responsibility of each and every employee, employees to be fully aware that the violation
which aims at protecting the reputation and of provisions in this Code of Conduct shall be
prestige of VPBank. strictly dealt with in accordance with
applicable laws and VPBank’s internal
4. The guiding principle for behaviors and
regulations, ranging from reprimanding to
professional ethics that each employee should
dismissal and/or request of criminal
follow is that he/she shall not trade off
prosecution in accordance with the laws. Each
VPBank’s reputation and prestige for a private
employee is responsible for reading this Code
interest or even for VPBank’s interest. We all
of Conduct and signing to confirm that he/she
bear in mind that the damage to reputation or
fully understands the behavioral standards set
prestige of VPBank – an organization operating
forth in this Code of Conduct and commits to
on the basis of customer trust and being
adhere to them.
customer focused – shall inflict widespread
and profound impacts on the bank’s business
operation.
5. The standards set forth in this Code of
Conduct shall guide decisions to be made by
each employee in many instances. However,
no Code of Conduct can cover every situation
that can arise in reality. Hence, we believe that
each employee will always rely on his/her
integrity to make decisions that protect
VPBank’s prestige and reputation.
 QUY TẮC ỨNG XỬ 06

Chapter II
VPBANK’S CODE OF CONDUCT
Article 3: Responsibilities towards VPBank
Being a member of VPBank’s workforce, you are a
representative for the prestige, reputation, image,
interests and core values of VPBank. Accordingly,
you are responsible for complying with the
following principles:
Principle 1: Complying with ethical
standards at work
VPBank expects its employees to work with the
highest ethical standards, to treat colleagues,
customers, and partners whole-heartedly, and to
work to get the best competitive advantages 1. Only provide confidential information as
through perfect product and service quality, not specified above after obtaining approval of
through unethical activities or legal violations. VPBank’s authorized managers or at the
request of the State’s regulatory or law
VPBank strictly prohibits each of its employees enforcement agencies, on the condition that the
from bribe taking or giving related to colleagues, provision of such information is in accordance
customers, partners or any other organizations with VPBank’s applicable regulations;
and individuals so as to influence a decision, gain
2. Take necessary steps to make sure that the
an advantage, avoid a disadvantage, or seize a distribution, copying, sending, receiving,
business opportunity for him/her or related maintenance, storage, and destruction of
parties. confidential information shall not result in the
Principle 2: Keeping confidential all leakage of such information to unauthorized
information of VPBank persons;
3. Make sure that the access to your working
Whilst working at VPBank and even after
space and computer is under your complete
termination of work at VPBank, you are control in order to avoid illegal access by
responsible for keeping confidential all unauthorized persons;
information you come to know in the course of
4. For digital information, comply with regulations
working at VPBank. Confidential information (in
on computer access, intranet, pass word, to
the form of document or digital information) of prevent the unlawful access to VPBank’s
VPBank includes, but not limited to, strategic confidential information;
documents, projects, operation plans, figures,
5. Do not install, alter, add or copy software
financial reports of VPBank (excluding those
programs on VPBank’s intranet without
subject to public disclosure), operating
permission;
guidelines, technology systems, advertisement
programs, product-service regulations of 6. Do not discuss confidential information of
VPBank in public places or forums (even
VPBank, information relating to customers,
internal forum of VPBank), on mobile phones,
suppliers, partners, or other information which
or other means of communication which might
has been classified as confidential or internal lead to leakage of VPBank’s confidential
information. To protect the confidentiality of information;
VPBank’s information, you are responsible for
7. Fully comply with other regulations on
complying with the following provisions:
VPBank’s information confidentiality.

Principle 3: Protecting VPBank’s brand
One of the most important assets of
VPBank is its brand and the associated
values and traits. To protect VPBank’s
brand and the consistent identification of
such brand, you are required to follow
regulations and guidelines on VPBank’s
brand usage and brand trademark signs in
all internal documents, transaction
materials with external parties, marketing
publications, emails, artefacts, signposts,
name tags, ATM, etc. In order to protect the
values and traits of VPBank’s brand, you
should be a brand ambassador of the Bank,
which is reflected in your efforts to bring in the
best experiences for customers, partners and
stakeholders. If VPBank’s brand and/or VPBank’s
brand identification signs are found to be misused
or violated in terms of copyright, you are
responsible for timely notifying the Marketing
and Communications Center for solutions.
Principle 4: Protecting VPBank’s assets
As a VPBank staff, you are responsible for
protecting VPBank’s tangible and intangible
assets. VPBank’s assets include, but not limited
to, cash, stock, physical facilities, working tools,
means of transportation, email system, internal
network, information of VPBank and its staff,
information of customers, suppliers, partners,
intellectual property rights (computer programs,
computing models, etc.), as well as other assets
of VPBank. To protect VPBank’s assets, you are
responsible for complying with the following
provisions:
1. Only use VPBank’s assets for VPBank-related
work, not for personal purposes or other
purposes without permission of authorized
managers;
2. Use VPBank’s assets properly and
economically without causing damage to
VPBank’s prestige and interests;
3. Do not embezzle VPBank’s assets in any forms;
any acts of embezzlement of VPBank’s assets
will be strictly sanctioned in accordance with
internal regulations of VPBank and the laws;
4. Apply appropriate preventive measures or
promptly notify the security unit of VPBank to
adopt suitable measures when discovering
VPBank’s assets to be stolen, damaged,
illegally exploited or misused;
5. Upon contract termination with VPBank, you
are responsible for returning all assets and
information being kept or received from work
relations at VPBank; all assets and information
CODE OF CONDUCT 07
kept or received by VPBank’s staff from work
relations at VPBank shall be the exclusive
assets of VPBank;
6. Fully comply with other VPBank’s regulations
on asset protection.
Principle 5: Ensuring the accuracy of VPBank’s
records and data
All information, records, and data serve as the
basis for VPBank to make suitable decisions.
Accordingly, you are responsible for making sure
that all VPBank’s information, records, data,
figures are adequate, accurate, timely and truly
reflective of VPBank’s business operation and
financial situation. For this purpose, you are
required to comply with the following provisions:
1. Make commitment to ensure that VPBank’s
information, records and figures under your
scope of work reflect honestly and accurately
the business performance and financial
position of the Bank. If suspecting or knowing
any inaccuracy in VPBank’s records or figures,
you should promptly notify the Finance Division
or Legal and Compliance Center.
2. Make commitment to ensure that information,
records and figures collected from customers,
suppliers, and partners reflect honestly and
accurately the business performance and
financial status of customers, suppliers and
partners. VPBank strictly prohibits all acts of
faking, collaging, editing, erasing, hiding
information of customers, suppliers, partners
as well as other acts that may distort VPBank’s
decisions and/or cause damage to VPBank’s
interests. VPBank notes that all above-
mentioned acts shall be strictly sanctioned in
accordance with VPBank’s internal regulations
and the laws.
3. Make commitment to coordinate with
compliance unit, internal audit division, and
external audit agency to support these units to
perform their functions.

Principle 6: Communicating with the media
and/or the public
As a public company, VPBank is obliged to comply
with regulations on disclosure of information to
shareholders, investors, the public, and ensure
the visibility and transparency of its operations.
Therefore, the interaction, speaking, or provision
of information to the media and/or the public
requires caution and compliance with VPBank's
internal regulations and applicable laws. For this
purpose, you are required to pay attention to and
comply with the following provisions:
1. Only people authorized under VPBank’s current
regulations on public speaking shall, on behalf
of VPBank, be entitled to interact, speak,
provide information to the media and/or the
public, including external forums and on the
internet;
2. When asked by the media to answer or speak,
you should explain the internal regulations of
VPBank regarding this matter, and recommend
the mass media to contact the Marketing and
Communications Center for reply. When
obliged to answer, you should clearly state
that the answer shall be in the name of an
individual, not in the name of VPBank, and
ensure that the answer will not mislead others
to understand that it is an answer of VPBank;
3. The Marketing and Communications Center is
responsible for establishing and maintaining
regular relations with the media to provide
adequate information in accordance with the
State’s regulations on information disclosure
and ad-hoc information as required by VPBank;
4. Fully comply with VPBank’s prevailing
regulations on public speaking and
communications.
Principle 7: Avoiding conflicts of interest
with VPBank
In day-to-day work, you may encounter conflicts
of interest or possible conflicts of interest with
VPBank. Conflicts of interest occur when an
individual's actions conflict or adversely affect or
seemingly conflict or adversely affect VPBank.
Conflicts of interest are also considered to occur
when an individual or his/her family members
receive benefits, products, services, or
preferential treatments because of his/her
CODE OF CONDUCT 08
position at VPBank. To avoid conflicts of interest
between employees and their related persons, on
one hand, and VPBank, on the other, you are
required to comply with the following principles:
1. Not participate in making decisions on activities
(economic contract execution, product and
service provision, etc.) whose implementation
may bring direct or indirect benefits to you or
your related persons (parents, spouse,
children, siblings or enterprises over which
such persons have controlling right). When
discovering the occurrence or possible
occurrence of the above situations, you are
required to proactively report to your direct
manager for making appropriate decisions to
avoid conflict of interests;
2. Not participate in any outside activities which
compete with or affect the interest of VPBank.
If you are engaged in outside investment or
business activities, please note that the
following provisions should be complied with:
a. You are not allowed to work, collaborate or
cooperate in any other forms with VPBank's
competitors, if such activities directly or
indirectly exert negative impacts on the
reputation, brand, business conditions, or
market share of VPBank.
b. Your outside investment or business
activities shall not affect the work
performance at VPBank. You are only
allowed to undertake such investment or
business activities outside the working hours
at VPBank;
c. You are not allowed to take executive or
managerial roles in or work in any form for
any organization operating in the banking
and finance sector without VPBank’s
permission/assignment;
 CODE OF CONDUCT 09

3. You are not allowed to use internal information

which is accessible by you in work-related
activities and not yet publicly released in order
to gain personal benefits;
4. People with family relationships (spouses,
children, parents, siblings) are not allowed to
work in the same universal branch or the same
division/center/department directly under CEO
or in the same subsidiary company or in jobs
with direct reporting lines;
5. You are not allowed to borrow money or assets
from customers who have credit relations with
VPBank (except credit institutions) or from
partners who are undertaking economic
transactions with VPBank;
6. You are not allowed to lend money or assets to transactions, which results in conflicts of
customers or partners who have credit interest, bribe taking, facilitating money
relations with the branch where you are laundering or failure to report such cases, etc.); or
working;
3. Acts of concealing any of the
7. You are not allowed to receive or hint at any aforementioned cases.
material and spiritual benefits which lead to Upon detection of the above cases, you should
conflicts of interest with VPBank in the course immediately report to your direct manager. If you
of handling the assigned work; find it impossible to report to your direct manager
8. In case of failure to complying with the above or the case should be additionally reported to the
principles, which leads to conflicts of interest higher level after having been reported to the
between VPBank and VPBank’s employees or direct manager, you are advised to contact the
their related persons, the interests of VPBank Compliance Department under the Legal and
shall be placed higher than those of others in Compliance Center. If the misconduct is deemed
the process of handling the consequences. to be extremely serious and/or related to the
Compliance Department, you should directly
Principle 8: Reporting misconducts
report the Head of Supervisory Board or the Head
Misconducts are the acts that are in violation of
of Internal Audit of VPBank. The email addresses
law, contrary to the policies, regulations and
and phone numbers of the focal points for
procedures that VPBank has issued and are still
receiving such reports are listed in the first
valid, or the acts outside the scope of authority of
session of this Code of Conduct.
a staff or employee that may do harms to the
reputation and prestige of VPBank and/or trigger You can report the above acts via in-person
conflicts of interest. You should promptly report meetings, telephone calls, emails or in writing and
when detecting such misconducts or suspecting can require your identity to be kept confidential. If
potential misconducts as those listed below: reporting via in-person meetings or telephone
calls, you are obliged to send an official report via
1. Acts in violation of the law (e.g. fraud, tax
email or in writing afterwards. Your direct
evasion, etc.) that have been occurring or are
manager, the Compliance Department, Head of
likely to occur;
Supervisory Board or the Head of Internal Audit
2. Acts in of violation of policies, regulations and shall be responsible for confirming the receipt of
procedures of VPBank that have been occurring such report with the reporting employee as well
or are likely to occur (e.g. provision of false as recording follow-up actions afterwards.
information to regulatory agencies, insider
trading, failure to report conflict-of-interest

Article 4: Responsibilities
towards colleagues
VPBank is resolved to build a trust-based, healthy
and professional working environment in order to
maximize staff potential, collective wisdom, and
strength of the organization. For this purpose, you
are responsible for complying with the following
principles:
Principle 9: Working relationships with
colleagues
In working relationships with colleagues at
VPBank, you are expected to:
1. Respect and trust colleagues, exchange work-
related issues openly, be ready to listen to
contrary opinions, and debate on the basis of
arguments and facts;
2. Promote teamwork spirit, take personal
responsibility for work assigned by the team,
constantly learn from the knowledge and
experience shared by team members to
improve work efficiency, and willingly receive
comments from members of the team;
3. Encourage and support the professional
development of colleagues, promote the spirit
of continuous learning and development
efforts of colleagues;
4. Respect the privacy of colleagues;
5. Refrain from borrowing money or assets from
colleagues.
Principle 10: Working relationships with
senior colleagues
In working relationships with senior colleagues,
you are requested to comply with the following
provisions:
1. Strictly obey working discipline and perform
the task assigned by senior colleagues. If
finding a senior colleague’s decision not
reasonable or suitable with reality, you should
immediately report to the senior colleague for
review. If the senior colleague does not change
his/her decision, you are responsible for
implementing it, yet with the right to reserve
your opinion and report to more senior
colleagues;
2. Do not come to senior colleagues’ private
residences unless being invited by a senior
colleague for a group event or required by the
senior colleague for a work-related reason;
QUY TẮC ỨNG XỬ 10
3. Do not present senior colleagues with gifts in
cash or in kind (except for souvenirs or other
gifts valued no more than VND1 million on
special occasions such as birthdays, weddings
or funerals, etc.), or offer them with
preferences beyond the common level
applicable to other organizations and
individuals (through your private business
facility or those of your families).
Principle 11: Working relationships with
subordinates
In working relationships with subordinates, you
are requested to comply with the following
provisions:
1. Always lead by example in terms of work-
related behavior, lifestyle, and compliance
with labor discipline, VPBank's internal
regulations, and provisions of applicable laws;
2. Give instruction, orientation, and training to
subordinates on working activities, especially
on the compliance with core values, behavioral
standards, and the Bank’s Code of Conduct;
3. Support subordinates to solve difficulties and
problems; ensure fair treatment of
subordinating colleagues; and protect the
legitimate interests of subordinating
colleagues;
4. Do not receive gifts from subordinates (except
for souvenirs or other gifts valued no more
than VND1 million on special occasions such as
birthdays, weddings or funerals, etc.); do not
ask or hint at asking subordinating colleagues
for gifts or any preferential treatments;
5. Handle reports or complaints on behaviors in a
way that keeps confidential the identity of the
reporting person and is consistent with
VPBank’s complaint handling policies and
processes.
 CODE OF CONDUCT 11

c) After reaching an agreement, once the problem

solving decision has been made by the
competent level (e.g. in a meeting), the staff
and employees shall not bring the issue into
discuss again and shall express their
viewpoints in consonance with the made
decision.
3. Rule 3: The cooperation spirit
a) a) An employee should strive to resolve
conflicts with his/her colleagues prior to
escalating them to higher levels.
b) An employee is suggested to directly discuss
with the colleague(s) engaging in the conflict
Principle 12: Resolving conflicts at work and must not entice other parties to “chatter”
When conflicts arise at work, VPBank’s staff or to form “faction”.
should adhere to the following principles in the c) An employee should explicit the points he/she
course of conflict resolution: fail to negotiate with an aim to find a solution.
It should be deemed that all other remaining
1. Rule 1: Transparency and Listening points are negotiable in an effort to reach the
a) When conflicts arise, you will present your most beneficial solution for all involving
expected goals and results, communicate them parties and the organization.
in a transparent manner to relevant parties as
you start dialoguing about the conflict. Principle 13: Establishing a healthy working
environment
b) You should identify conflicts as specific
problems rather than judgments about people. VPBank looks forward to building a safe and
For example, if a conflict identified as “You healthy working environment for its employees.
failed to deal with my request within the agreed Therefore, VPBank prohibits discrimination,
timeline” is a particular problem, it would be sexual harassment, racism, sexism, theft, fraud,
easier to understand and to handle than “You corruption, insults, threats, retaliation, violence,
are not collaborative.” By separating specific drug use at work in any forms. VPBank’s
issues from human issues, the issues will be employees are not allowed to use a computer to
discussed and resolved without causing harm transmit or receive contents or images which
to the relationships. cause harassment, racism, sexism, threats, or
offense to others. Employees are obliged to
c) You should commit to listen to your colleagues’ report promptly to the closest security team of
opinions before presenting your viewpoints. VPBank when detecting the above behaviors to
You are advised to seek for a comprehensive take place in VPBank’s premises. VPBank
view of the conflict by asking direct questions prohibits any acts of retaliation against VPBank’s
on the assumptions to be aware of the employees who report such behaviors.
colleagues’ views and intentions instead of
inferring or predicting their thoughts about Article 5: Responsibility to customers,
such conflict. In other words, you should be in partners, suppliers, and other stakeholders
your colleagues’ shoes and listen, trying to
understand the objectives, perspectives as well Principle 14: Always keep a customer-
as their reasons during the course of conflict focused mindset
resolution. VPBank always keeps a customer-focused
mindset. Customers’ satisfaction is a measure of
2. Rule 2: Awareness of problem solving
the success and operation quality of VPBank.
a) Right at the start of a conflict, VPBank’s Therefore, all employees of VPBank are obliged to
employees should promptly communicate with fulfill responsibilities toward customers,
relevant parties to work out solutions. A partners, suppliers and other parties as follows:
prolonged or exacerbated conflict must not be
allowed without taking any needed action. 1. Be honest and dedicated in your behaviors to
b) All employees are advised to stay focused on all customers, partners, suppliers, and
the agreed aspects, build consensus on the other organizations and
common goals, and together consider the pros individuals;
and cons of each option or solution before 2. Try best to provide products, services, and
resolving the divergences.

experiences of excellence to customers of
VPBank, including the provision to customers
with accurate, adequate, clear information on
VPBank’s products and services;
3. Fully perform all the commitments or
agreements between VPBank and customers;
wholeheartedly solve customers’ problems and
difficulties which are related to VPBank;
4. Commit to keeping confidential all information
related to VPBank’s customers, partners,
suppliers, and other parties undertaking
transactions with VPBank. VPBank’s
employees understand that information related
to customers or parties undertaking
transactions with VPBank shall never be
disclosed to anyone, including employees of
VPBank, except when that person is related to
the execution of the transaction in question or
as required by legal authorities and in line with
VPBank’s regulations;
5. Employees are strictly prohibited from asking
or hinting at asking customers, partners,
suppliers or other stakeholders for bribes, gifts,
donations, privileges, and special offers for
themselves, their family members or friends, in
return for meeting the requirements of
customers, especially customers asking for
credit from VPBank. VPBank employees are not
allowed to accept money, gifts, privileges or
special offers from current or prospective
customers, suppliers, partners of VPBank,
unless (i) the gift has a symbolic value or is a
corporate gift, or (ii) it is a regular dining
activity, such as a working lunch. VPBank shall
strictly sanction employees who have the above
behaviors in accordance with VPBank's internal
regulations and applicable laws.
Article 6: Responsibilities towards
State’s legal and regulatory agencies
Principle 15: Complying with regulations of
the State’s legal and regulatory agencies
In addition to complying with internal regulations
of VPBank on banking operations and labor
discipline, you are obliged to comply with
regulations of the State’s legal and regulatory
agencies. You should be aware that the violation
of applicable laws will cause serious
consequences to the related organizations and
individuals and negative impacts on the prestige,
reputation, and interests of VPBank. To comply
with the regulations of the State’s legal and
regulatory agencies, you are obliged to follow the
principles below:
CODE OF CONDUCT 12
1. You are obliged to comply with VPBank's
regulations. When finding that VPBank's
regulations are not consistent with provisions of
applicable laws, you are requested to contact the
Legal Compliance Department, Legal and
Compliance Center, for advice;
2. You are obliged to cooperate with the State’s
legal and regulatory agencies upon request and to
follow VPBank’s regulations related to the
provision of information and documents.
Article 7: Responsibilities towards
the community
Principle 16: Working and living with full
responsibility towards the community
One of the core values of VPBank is to “Make a
Difference”. This value implies efforts to build a
model VPBank, which is a trusted partner, a
respected recruiter, and an organization sharing
its success with all members of the organization
and the community. VPBank wishes that its
employees demonstrate their responsibility
toward the community through the following
acts:
1. Help VPBank’s employees who face difficulties
through charity activities launched by VPBank
or other contribution activities;
2. Actively participate in charity programs or
voluntary programs held by VPBank and/or
other organizations;
3. Proactively propose contribution and charity
activities to competent authorities for
decisions;
4. Take specific actions to show gratitude to
VPBank’s employees of previous generations
who made valuable contributions to building
and strengthening VPBank.
 CODE OF CONDUCT 13

Chapter III:
IMPLEMENTING PROVISIONS
Article 8: Guidance for complying with
VPBank’s Code of Conduct

When feeling uncertain whether a decision complies

with VPBank’s Code of Conduct or not, you are
requested to answer the following questions to
evaluate your own decision:
1. Does my decision comply with provisions of
applicable laws?
2. Does my decision comply with the ethical
standards set out in this Code of Conduct as well
as other provisions and policies of VPBank?
3. Shall my decision protect the reputation, prestige,
interests of VPBank and VPBank's shareholders?
4. Is my decision the most moral decision among the
possible decision choices that I have?
5. Will others in my case be willing to make such a
decision?
6. Will I feel comfortable if my decision is shown in
the newspaper?

If the answer to one of the above questions is NO, the
decision you are about to make may cause serious
consequences and you should not make such a
decision. If the answers to all of the above questions
are YES, you can make that decision. If the answer to
any of these questions is uncertain, you should
contact your direct manager for guidance (except for
cases which are related to that direct manager). If the
answer to one of the guiding questions in Article 8
remains uncertain, even after receiving guidance from
the direct manager, you are requested to contact the
Compliance Department, which is under the Legal and
Compliance Center, for specific advice. The
Compliance Department shall be responsible for
providing you with advice on related provisions of the
Code of Conduct, provisions of applicable law and
VPBank’s internal regulations. You are requested to
contact the Compliance Department by email or in
writing (in case of emergency, you may request for
direct advice via telephone, yet a request via email or
in writing should be subsequently sent to the
Compliance Department, together with relevant
documentation, if any).
On behalf of the Board of Directors
Chairman

Ngo Chi Dzung

Key words (updated on VPB E-Office for ease of searching: Code of Conduct of VPBank,
behavioral standards, ethical standards, etc.)

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