Codes of Practice and Conduct

Code of Conduct for Members of the National Asset Management Agency Board, its Committees and NAMA Group Entities This Code of Conduct was first approved by the Board in 2010, and in accordance with good practice has been reviewed each year since 2011. While it is not possible for a set of rules or guidelines to provide for all situations that may arise, Board/Committee members are expected to ensure that all their activities are governed by the ethical standards reflected in this Code in letter and in spirit.

Code of Practice - Commercial Interests of Non-Participating Institutions This Code of Practice sets out how NAMA, in its decisions and actions, will take account of the commercial interests of credit institutions that are not one of the five Participating Institutions . This Code states that NAMA will have due regard to the commercial interests of non participating institutions, act reasonably in the exercise of its powers under the NAMA Act and adopt a consultation approach where appropriate.

Code of Practice - Disposal of Bank Assets This Code of Practice sets out how NAMA intends to manage the disposal of bank assets it has acquired. NAMA will establish and define procedures for the disposal of bank assets including independent appraisals for each bank asset prior to disposal and two such appraisals for larger value or more complex bank assets in excess of €100m in value.

Code of Practice - Risk Management This Code of Practice sets out the various types of risk to which the Agency is exposed and describes the governance, policies, processes and infrastructure it has put in place to manage those risks.

Code of Practice - Servicing Standards for Acquired Bank Assets This Code of Practice relates to the servicing of the bank assets acquired by NAMA and which continue to be administered and serviced by the Participating Institutions on NAMA’s behalf. NAMA has directed the banks to comply with minimum standards of service. It also requires that banks ensure that staff servicing assets on NAMA’s behalf were not involved in the relationship management prior to NAMA’s acquisition of those assets.

Code of Conduct for Officers of NAMA The Code sets out the “best practice” standards of principles and practice in relation to confidentiality, conflicts of interest, insider dealing, market manipulation, prohibition of wrongful penalisation, disclosure of personal interests, personal account transactions and other matters in respect of which NAMA is required by statute to have a Code of Practice. The Code underscores NAMA’s commitment to the highest standards of conduct and has been prepared to assist its Officers in understanding their duties, rights and obligations. The Code is reviewed annually by the NAMA Board and any proposed amendments to the Code are submitted to the Minister for approval prior to publication.