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CODE OF ETHICS & CONFLICT OF INTEREST POLICY
1.1 FSM Development Bank Board of Directors and management is responsible for establishing the cultural environment, and the training of employees, volunteers and board members. The bank’s reputation for honesty and integrity is determined by the personal reputations of individual employees, officers, board members, and all others associated with the bank. To protect this reputation and to warrant customers’ trust, employees as well as all service providers to the bank must strive to avoid situations that might cause a conflict of interest within the Bank, its customers and its suppliers. This policy applies to any officer, employee, volunteer, vendor, contractor, consultant, board member, or other organization doing business with or who is associated with the bank. The following principles have been established as the Bank’s code of ethics. Any exceptions to these policies must be approved in writing. It is FSM Development Bank’s policy that there is zero tolerance for actions that subvert, decrease or otherwise prevent or impair this policy to fulfill its intended purpose.

1.2 Conflict of interest. Conflict of interest occurs when an individual, or any member of the individual’s family, related company, other related organization or interest, receives material tangible or intangible benefits from any influence exerted, legally or illegally, derived from the individual’s involvement with the institution. It is the policy of the bank that all stakeholders conduct their business affairs in such a manner and with such ethics and integrity that no conflict of interest, real or implied, could exist. For the purposes of 30 FSMC Section 125, Acts affecting personal financing interest, the definition of “Close Relatives” is a spouse, a parent, a child or a sibling, or the spouse of any such person.

1.3 Confidential Information. Read More

1.4 Gifts and Fees. Read More

1.5 Business Conduct. Read More

1.6 Eligibility to Bid on Foreclosed Assets. Read More

1.7 Conflict of Interest Disclosure. Read More

1.8 Annual Conflict of Interest Disclosure. Read More

1.9 Anti-Fraud. It is the Bank’s policy that there is zero tolerance for actions constituting fraud. Actions defined as fraud include but are not limited to:

• Misappropriation, personal use of or personal benefit from or outright theft of Bank’s cash, securities, equipment, supplies, or other Bank assets.
• Unauthorized use of organization employees, property, credit cards, phones or other resources.
• Submission of personal or fictitious employee expenses for reimbursement or fictitious or inflated vendor invoices or payroll records for payment.
• Receiving bribes, kickbacks, or other unauthorized personal benefits from customers, vendors, or others.
• Forgery or fraudulent alteration of any check, bank draft, statement, billing, record, form, report, or other financial documents.
• Intentional material misclassification or misrepresentation of assets, liabilities, shareholders, equity, revenues, expenses, costs, or other data in financial statements, reports, regulatory returns, applications, or other communications.
• Intentional failure to disclose material related party transactions, noncompliance with lender requirements, donor/grantor restrictions, or other required disclosure matters.
• Intentional improper use or disclosure of confidential donor, client/customer, employee, or organization proprietary information.
• Any other illegal or unethical activity as defined in National or State law’s.

1.10 Reporting Responsibilities and Safeguards. Read More

1.11 Whistle-blower. A whistle-blower is defined as any individual, inside or outside the organization, who provides substantiated information regarding an officer, employee, volunteer, vendor, contractor, consultant, board member or other organization doing business with or who is associated with the Bank and is in violation of the Bank’s Code of Ethics policies.

1.12 Confidentiality. Read More

1.13 Investigation Procedures. Read More

1.14 Resolution Procedures. Read More

Policies and Guidelines

• ESS MITIGATION AND MANAGEMENT PROCEDURES

• Click the link to download:
ESS-Mitigation-and-Management-Procedures.pdf (3 MB)

• GRIEVANCE REDRESS MECHANISIM

• Click the link to download:
Grievance-Redress-Mechanism.pdf (1 MB)

Preparing Your Complaint

Before you file your complaint with us, take a moment to make sure you have all of your important information. Please note: The system cannot save your complaint in progress, so you will need to complete the form in one sitting.
FSMDB accepts complaints by mail, by e-mail, by phone, or by using the online form.

KNOWING WHAT TO REPORT

• Rules, policies, or regulations of the FSMDB that have been breached

• The full name of the business or person against whom you are logging in a complaint, together with their address

• A thorough explanation of your grievance

• A description of your interaction with the company or person

• When and where the incident happened, along with the exact date and precise location

• Contract details (if applicable) together with payment information

• Method by which the person carried out the claimed offense

• Justification for the offender’s actions

• Why you think there was wrongdoing with the claimed activities

• How you might have tried to settle the conflict, together with the identities of the people you communicated with

Download and fill out the form below. Send the completed form to the Mail address below.

What happens next after you file a complaint?

Here’s what to expect:
Upon filing your complaint, we will review your complaint or question and any documents you submitted. If we need more information, we will get in touch within 30 days using your preferred contact method. We utilize these complaints to present resolutions and, when necessary, take appropriate action.

If you provided your email address, you will receive a confirmation email once your complaint is successfully submitted. To speak with a staff that can assist you with filing a complaint, contact us at +691-320-2840 / 320-2624, Monday – Friday between 8:00 am and 5:00 pm Pohnpei time.

File a Complaint with the Office of the National Public Auditor

If you would rather lodge a complaint with the Office of the National Public Auditor directly, you can do so by visiting their website and completing the form required.
Please click on the following link to continue:
FSM National Public Auditor | Complaint Form (fsmopa.fm)

FSMDB AUDIT POLICY – INVESTIGATIONS
Investigations are independent evaluations of allegations related but not limited to possible: fraud, misuse of resource, abuse of power, conflict of interest, illegal activity, unethical behavior, non-compliance with internal policy, or State or National laws. As a component unit of the FSM National Government, FSMDB will utilize the Office of the National Public Auditor (ONPA) to conduct investigations as needed.

The Board, Audit Committee, Management or the Internal Auditor will request for investigation if there is a need. The full Board or the Audit Committee will approve any request for investigation to be conducted by the ONPA. A decision to refer a case to the ONPA for investigation shall be made free of conflict of interest.