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1. Introduction
1.1 External Appointments
Background External appointments refer to accepting nomination for a management function or carrying out any activity for other parties than the bank, including own business, whether as an employee or otherwise, with or without remuneration in any form what so ever.
Purpose The purpose of this policy is: To ensure that DSA employees and members of the Board can have other roles in society outside their stated roles in DSA, The risks of potential conflicts of interests are avoided, The laws and regulations are complied with.
Contents This policy describes: When approval by the management or the Board is needed for an external appointment, Who can approve the external appointment, Principles that DSA will use when deciding about external appointments of employees or members of the Board, Financial matters, code of conduct, administration and information.
2. Policy Statement 2.1 External Appointments Policy If an employee or a Board member wants to take up external functions in addition to his or her job at DSA, approval is required. It is mandatory for such an approval for external appointments either with or without salary that are either business related or may lead to conflicts of interests or potential conflicts of interest. DSA wants to support personal growth and development of employees. 3. Standard Statement 3.1 Code of Conduct Measures DSA employees and Board members must be aware of possible conflicts of interest and take appropriate actions to avoid even the appearance of these conflicts of interest by: Having the external appointments registered and approved by DSA, Not being involved in decisions regarding the organisation which may affect the relationship between the organisation and DSA, Actively informing the management or the Board if a conflict could arise, Refrain from being the only person who takes decisions on financial matters of the organisation concerned, Retiring from the function if needed in order to avoid any reputation or other damage.
3.2 Application Procedure Permission Members of staff must have written permission from the ED or the Board before accepting external appointments that could endanger DSA's position of independence in relation to third parties by creating a real or apparent conflict of interest. Approval Any staff member that is offered an external appointment and is not sure as to whether there is a relationship with their position in DSA must consult their manager about the need to ask approval. Asking approval in cases is not only in DSA’s interest but also in the interest of the staff member, as it can avoid any embarrassing situation that might arise if DSA was not aware of their involvement with the external organisation. It is the responsibility of a staff member to decide about seeking DSA’s approval. It must be discussed with the ED, and if the ED decides that registration is necessary, a request for approval is submitted and the function will be registered. Required Information Staff members must at least submit the following data: Name, Position in DSA, Name of the company or organisation concerned, The type, working sphere and activities of the company or organisation concerned, The duties and responsibilities, and the time required fulfilling them, Remuneration if any,
The approval authority can ask for more data like legal and tax advice if appropriate. The register is updated annually through an exercise whereby all staff members and Board members declare the status of their appointment/s. The register will be tabled annually in one of the Board meetings for endorsement.
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