20. Conduct that Complies with the Law and Policy

The company discloses which measures, standards, systems and processes are in place to prevent unlawful conduct and, in particular, corruption, how they are verified, which results have been achieved to date and where it sees there to be risks. The company depicts how corruption and other contraventions in the company are prevented and exposed and what sanctions are imposed.

Assuming responsibility is part of the everyday life of a bank. This involves Deutsche Hypo avoiding any business or social commitments that conflict with the Bank’s social responsibility. Financing guidelines have been adopted for example to avoid controversial areas of business such as arms transactions and pornography. A Reputation Committee provides advice on issues relating to specific business transactions as and when required.

Deutsche Hypo has also appointed a Compliance Officer who also presides over the Compliance organisation of the NORD/LB Group. The main areas of activity are regulatory compliance, capital market compliance and prevention of money laundering / fraud compliance. The prevention of money laundering and terrorism financing is also regulated consistently due to the establishment of a Group Money Laundering Officer. Compliance with these guidelines is ensured through regular control and monitoring activities of the department Compliance and Safety and the Money Laundering Officer.

All employees of Deutsche Hypo are required to participate in web-based compliance training immediately upon employment and at least every three years thereafter. This training is designed to educate participants on compliance-related topics such as the prevention of money laundering, embargoes and other criminal activities.