Prevention of Corruption
The Law on Prevention of Corruption aims to prevent the abuse of official, business, or social positions or influence for personal gain or for the benefit of others. This law prescribes measures for preventing conflicts between public and private interests and regulates restrictions on the exercise of public functions, reporting on assets and possessions by public officials, the protection of persons reporting threats to the public interest that indicate the existence of corruption, as well as other issues of importance for the prevention and suppression of corruption.
The provisions of this law apply to members of the CBCG Council and other CBCG employees who are public officials, as defined under this law.
Therefore, pursuant to this law, members of the CBCG Council and CBCG employees who are public officials submit the income and asset reports which are published on the website of the Agency for Prevention of Corruption.
The prevention of conflict of interest for members of the CBCG Council is also regulated under Article 52 of the CBCG Law. According to this article, a member of the Council shall perform their function in the Central Bank in the manner so that they shall not put their personal interests or interests of persons connected with them before the interests of the Central Bank. The member of the Council shall submit a written statement to the Council on the facts referred to in Article 51 paragraphs 2 to 5 of this Law within 15 days following that of their appointment for the member of the Council and once a year by the end of February in the current year for the previous year. Where a member of the Council is in any way connected with the subject matter of deciding or where they are indirectly or directly interested in that subject matter, they shall disclose their interest at the beginning of the meeting of the Council and shall not participate in the discussion or voting on such a matter, but their presence shall be accounted for the purpose of constituting a quorum at the relevant meeting. Any rights and obligations of the members of the Council not specified in this Law or the Statute shall be subject to provisions of the law governing the prevention of corruption in performing public functions.
Furthermore, the Code of Ethics for members of the Central Bank of Montenegro Council establishes the ethical principles and rules of professional conduct that members of the CBCG Council should observe when exercising their functions.
The employees of CBCG, who are not public officials are subject to provisions of the CBCG Code of Ethics governing the prevention of corruption. Specifically, this Code of Ethics regulates, among other things, the obligation of employees to perform their duties in a manner that ensures compliance with the highest standards of professional conduct and political neutrality, commitment to tasks and duties and loyalty in their performance, avoidance of conflicts of interest, prevention of any damage to reputation of the Central Bank, data protection, and confidentiality as well as the prohibition of disclosing confidential information.
Also, following the provisions of the Law on Prevention of Corruption, the CBCG Code of Ethics includes provisions that specifically regulate the prohibition of accepting gifts and benefits, with the exception of symbolic, protocol or convenient gift whose value does not exceed 50 euros, in line with common business practices and rules on reporting gifts; the obligation to report suspicious activities; adherence to the principles of political neutrality; and prohibition from working outside working hours in another legal entity if such additional work and activities create a conflict of interest. Violation of the rules of conduct established by the Code of Ethics is defined as a serious violation of work obligations, which entails accountability for the violation.
In addition, the CBCG has also adopted the Code of Ethics for employees in the Financial and Banking Operations Department, which regulates additional professional principles for employees in this Department who are involved in the management of international reserves and other portfolios managed by the CBCG on behalf of its clients. The purpose of this Code of Ethics is to improve employee behaviour in line with professional and moral principles, as well as principles of independence and objectivity, based on international standards in this field and good business practices.
In addition to the provisions of this Code of Ethics, employees in the Financial and Banking Operations Sector are required to adhere to the rules of professional conduct established under the Code of Ethics of the CBCG.
Whistleblowers
The procedure for submitting a whistleblower report, the manner of acting on that report, and protecting whistleblowers is regulated by the Law on Prevention of Corruption (Articles 48 to 74). According to this Law, whistleblower is a natural person employed in the private or public sector who has obtained information about irregularities in their work environment and who submits a report on these irregularities (Article 5).
The report can be submitted in written form, orally on record, by mail, electronically, or by phone. The report should include a description of the irregularities and personal information of the whistleblower unless the whistleblower wishes to remain anonymous.
Data on the identity of the whistleblower, the whistleblower’s facilitator, person related to the whistleblower, and the reported person or data that may disclose their identity, the content of the report and the supporting documents will be protected from the authorized access and marked “CONFIDENTIAL”, and they shall be treated in accordance with the internal general act of the Central Bank of Montenegro governing data secrecy and personal data protection.
More detailed information on the submission of reports is provided in the Instruction on Submitting Reports on Threat to the Public Interest that Indicates the Existence of Corruption and the Protection of Whistleblowers.
The mannner of recording and acting upon whistle-blowers' report is regulated in detail in the Procedure on the Manner Recording and Proceedings upon a Whistle-Blower's Report.
In accordance with the Law on Prevention of Corruption, the CBCG, as a public authority, adopts an Integrity Plan every two years. This plan is prepared based on an assessment of the susceptibility of certain positions and work processes to the emergence and development of corruption and other forms of biased behaviour of public officials and employees of the CBCG. The Integrity Plan includes measures that prevent and remove opportunities for the occurrence and development of corruption, ensuring public confidence in their work. The Integrity Plan is published on the CBCG website.