14. Employment Rights

The company reports on how it complies with nationally and internationally recognised standards relating to employee rights as well as on how it fosters staff involvement in the company and in sustainability management, what goals it has set itself in this regard, what results it has achieved thus far and where it sees risks.

The Bank plans to achieve the objectives set out in the business strategy by a need-based recruitment of employees, continuous personnel development and a high employee retention rate. An appreciative consideration of employee interests as specified in international standards as well as constructive and targeted information provision and involvement of employees is the goal of this concept.
Furthermore, OLB still pursues the objective of creating the framework conditions and work environment that enable equal opportunities and a diversity in the company. This is associated with the aim of ensuring and pushing access to further education for all employees (also on topics like health management and digitalization), so as to overcome the challenges of demographic change. These objectives all have the same priority. The Bank attaches special importance on an appreciative and cooperative treatment of employees as part of the company culture, and as the basis for the sustainable success of the company. The concepts all have a long-term orientation, are agreed with the management and verified for effectiveness on a regular basis. That is done, in particular, in the context of the (annual) alignment of the Bank’s business strategy. A HR strategy taking into account all employee matters is planned until the end of 2023.
The Bank uses different measures and instruments which can only be successful in an environment of mutual respect, open communication and trusting cooperation. One essential measure in the year 2020 was the first-time realization of the annual performance assessment for employees, which included an employee discussion. One essential content of such assessment is an exchange about future fields of learning and development and about individual measures. A trusting cooperation also includes the compliance with rules and standards which have evolved from statutory, industry-wide, intra-company and individual agreements. Regular meetings of employee representatives and Board members ensure a trusting cooperation and a continuous communication. The success of this concept is revealed, inter alia, in a high average period of employment in the company and a high rate of vacancies that can be filled by internal personnel.
The Bank exclusively operates business locations in Germany and is exclusively active within Germany as regards employee matters. OLB complies with all legal provisions and standards applicable in Germany. That relates, in particular to work conditions, the rights of employees, health protection and occupational safety and the rights of unions. The Bank is very active in all of these areas. The vast majority of its employees is employed on the basis of collective bargaining agreements which provide for, in particular, the remuneration, working hours, their claim to vacation and the general working conditions.
OLB maintains a constructive and trusting cooperation with the bodies representing its employees. The Board of Directors, the departments of Human Resources and Communication and the Work Council all advocate employee rights. Employee’s rights of co-determination arising from the Works Constitution Act and other legal standards are being complied with. Employee representation bodies are involved in the plans for all essential corporate changes at an early stage.
The participation of employees in sustainability management is based on established communication standards. Such a participation in the Bank’s sustainability management can be promoted best by using digital options of employee participation. This includes the comment function available on the intranet or a direct information about contacts, since this allows employee to disclose and determine their opinion and needs (e.g. on topics such as diversity). Even events in which the Board of Directors take part, or meetings of departments and sales employees with specialist Board members or meetings on a group or department level contribute to an open dialogue within the company. The Bank requests and promotes an active feedback and participation of employees through information events which the Board of Directors initiatives, in case of need, for employees in all business regions. Employees are not promoted in any other way to participate in the sustainability management.
The Bank was able to determine that it achieved its objectives regarding the compliance with laws and regulations on working conditions, rights of employees for health protection and occupational safety. No date has been set yet by which the objectives in terms of cultural aspects such as good cooperation or appreciative conduct are to be achieved, since these are objectives for which no measure of achievability can be determined. The Bank may only include and assess indications for an achievement of such objectives (e.g. staff fluctuation, term of service in the company).
The achievement of the Bank’s targets in the year 2020 was also characterised by the Corona pandemic and associated with changes in the communication and cooperation with and among staff members. OLB’s crisis unit discussed the risks of the pandemic for employees from the beginning of the crisis. It provided timely and targeted reports about decisions taken by the Bank and the effects on the working conditions of employees. Employee representatives were integrated in the crisis unit at any time.
The increasing spatial separation of the workplaces due to employees working from home and the further flexibilization of their working hours and workplaces caused challenges in communication. A more digital communication, supported by the introduction of e.g. video conference systems or MS Teams as communication medium ensures that options are available for communication, without the need for employees to be present in the branch offices. Such were widely used. New provisions for occupational health and risk analysis regarding infection protection will be included in the Bank’s occupational safety system. The concepts will be verified and adapted in coordination between personnel and Board of Directors when they assess whether the objectives have been fulfilled (e.g. when determining the share of women in leadership positions or by assessing negotiations in executive bodies, for approving the reconciliation of interests or social plans).
The Bank permanently analyses the achievement of its targets and the risk and does so, in particular, when it determines business objectives while analysing their impact on employees matters. It determines both the risks arising from its business activity (e.g. consulting and sale of bank products), from business relationships (e.g. bank clients such as private clients, corporate clients or private banking clients) and from our services (e.g. financing advice, insurances or investment types). The operational losses / risks found systemically in the past (e.g. due to court decisions or damage arising from consulting) provide indications for future risk classifications for certain measures. No essential risks can be found which might have serious negative effects on employee matters. The interests of employees will continuously be taken into account in the course of merger processes and the use of synergy effects for an increase in efficiency.

15. Equal Opportunities

The company discloses in what way it has implemented national and international processes and what goals it has for the promotion of equal opportunities and diversity, occupational health and safety, participation rights, the integration of migrants and people with disabilities, fair pay as well as a work-life balance and how it will achieve these.

Based on the remuneration strategy, OLB’s remuneration systems are already designed in manner to ensure an adequate and market-conform pay for all employees, in compliance with the regulatory requirements. Such design supports the fundamental objectives of the Bank’s human resources strategy such as recruitment, development and long-term retention of sales staff and highly qualified employees for special activities. The remuneration for the vast majority of the staff arises on the basis of regulations set out in the collective agreement for the private banking industry and is regularly specified by taking into account the type of function exercised by staff members and their individual qualification.
OLB strictly rejects discrimination and disparagement of any type. Objective of the Diversity concept is to avoid discrimination and to create an open and diversified company culture. The principles of conduct set out in the Code of Conduct implement these principles and provide guidelines. The Diversity concept was prepared in cooperation with the Board of Directors and its implementation was accompanied appreciatively by communication measures. Employees were involved through the organisation of topic workshops and through the Bank’s intranet site on Diversity. Surveys provide all staff members with the option to publicly give their opinion on corporate matters.
OLB clarifies in its trainings on the basics of compliance and on the General Act for the Equal Treatment of Women and Men: any and all discrimination in every day work on the grounds of race or ethnical origin, gender, religion, philosophical believes, disability, age or sexual identity shall be prevented or eliminated.
In 2015, OLB signed the “Diversity Charter“ for the first time and thus publicly expressed its will to implement diversity. Objective of the regular internal communication and an open employee participation in most different dimensions of diversity is to make it visible, make all employees aware of it and to appreciate it. This objective was once again implemented by the Bank through its regular participation in the Diversity Days of the city of Oldenburg and as member of the city of Oldenburg’s diversity network in the reporting year. In addition, migrants are enabled to start a professional career in the Bank through internships and trainings.

Two of the twelve members of the Bank’s Supervisory Board were female on the reporting date of 31 December 2020. One member of the Board of Directors is a woman. The Bank’s corporate philosophy is to equally promote women and to deploy them in leadership positions in line with their performance. Staff development programmes, targeted preparations for future tasks and mentoring programmes for future officers are the measures applied by the Bank to this end. Such are regularly addressed and reviewed during fundamental staff discussions. The first-time specification of target figures for implementing the German Act on an Equal Participation of Women and Men in Leadership Positions of the Private Economy and Public Service was mostly realised with effect from 1 July 2017. The Bank has not been able to fully achieve all of the newly determined target figures until the end of 2019, so that the target figures continue to apply and the period for achieving them was prolonged until 2023. For the Board of Directors and the two leadership levels below the Board, they amount to 25 % each. The target figure for the Supervisory Board is 2/12.
Objective of the corporate health management is the support of employees and officers in their efforts to preserve and maintain their health. That also applies to the framework conditions available for flexible work and the consideration of technical and health qualifications of employees. The Bank pursues relation-related and behaviour-related objectives and measures in line with the stress and strain concept issued by the professional associations. These objectives should be achieved by the company creating healthy and flexible conditions and processes in the operation and by making suitable offers that promote health (e.g. seminars on mental strain, active self-management or e-training on health topics). The objective exceeds the compliance with existing legal regulations, such as occupational health, workplace ordinance or screen work ordinance. The Bank takes preventive measures as part of its corporate health management to systematically identify and prevent from the outset or reduce physical and psychological strains at the workplace (e.g. regular offers of the local company doctors to consult on health topics or financial support for corporate sports offers). Implementation and effect of the selected measures are verified on a regularly basis or after their performance and assessed based on their suitability for the planned objective. This will be done by including the bodies and representatives of severely disabled persons in committee meetings that are conducted on a quarterly basis.
Compatibility of work and private life also means to create flexibility in terms of working hours and workplaces. Company agreements on trust-based working hours and options for external workplaces (home office) implement regulations which provide our staff with a high degree of flexibility and individual working hour models in all fields of the Bank. Offers for child care are used regularly and even the care for and nursing of relatives is becoming increasingly important; the Bank has, so far, always found satisfactory and individual solutions for affected employees. In order to determine the achievement of these objectives, the Bank uses both quantitative results (e.g. the number of risk assessments performed, the number of employees working permanently from home or assessments in relation to individual working time agreements) and qualitative influence factors whose achievement cannot be determined easily (e.g. openness for health-related topics such as mental illnesses, company culture in relation to flexible working). The Bank has started taking up the challenges posed in 2020 in terms of health protection and risks caused by infections already at the beginning of March. Structural solutions (e.g. establishment of an OLB crisis unit, new digital communication options) or targeted continuous communication (e.g. instructions on the intranet and by email as well as assistance in learning management system) ensured the implementation of measures that protected our staff members. This included, e.g. the increase of the number of staff working from home, the reduction of our opening hours, of contact rates and thus a decrease of contacts to clients, the provision of face masks and a continuous repetition of hygiene regulations.

16. Qualifications

The company discloses what goals it has set and what measures it has taken to promote the employability of all employees, i.e. the ability of all employees to participate in the working and professional world, and in view of adapting to demographic change, and where risks are seen.

The qualification of our staff is an essential lever for the preservation of the health of employees and for achieving the objective of our corporate health management – i.e. the above mentioned support of employees in relation to the stress and strain concept issued by the professional association.
OLB sets high demands to the qualification of its employees. The technical competency of staff members is a decisive criterion, in particular for the personal advice and consulting of clients over the phone. As a consequence of this claim to quality, special emphasis is placed on hiring highly qualified employees who focus on consulting and sale in order to ensure the quality of advice for our clients. And, to always keep the knowledge and abilities of employees on the best and latest level, OLB attached great importance on a comprehensive further education and training of its staff members. The core element of this offer is the Learning Management System iQ which includes comprehensive digital offers so that further training and education can be performed both in relation to the activity and in a comprehensive manner and independently of the employee’s location. OLB received the eLearning Award 2021 in the segment of eLearning Production, on the basis of the contents included in iQ in the year 2020. During the Corona virus pandemic, staff members quickly received suitable digital offers in iQ to be able to master the new challenges – including, in particular, e-training in relation to mobile work and virtual team communication.
Additional advanced training offers (both seminars with personal attendance, webinars (that replaced some of the formats with personal presence in 2020) and e-trainings) on health topics and offers on personality development were provided, regular staff discussions with superiors were integrated in the processes (e.g. corporate integration management or regular assessment discussions) and the Bank pursued comprehensive awareness-raising measures to health topics through the intranet and iQ to ensure that employees are able to render their services in an optimum manner. The further increase of the iQ offer in 2020 forms a good basis for the qualification of employees and highly supports the achievement of the objectives in view of the qualification for 2020. Higher usage rates in some of the voluntary offers are still desirable. Given the comprehensive digital options and available options in iQ, OLB had already been well prepared for the pandemic.
The Bank has exclusively business locations in Germany and is exclusively active on a national level as regards staff matters. It plans to equip all office workplaces with height-adjustable desks which exceeds the national standards. The awareness of staff members for physical strain is raised in connection with regular site-visits, incl. behavioural recommendations by company physicians and by the officer for occupational safety. They also provide concrete support at the workplace for employees in their efforts to develop a long-term and age-appropriate working style.
No date has been set yet for achieving these objectives, since these are long-term objectives. An indication for the degree of achievement of such objectives can be derived from indicators (e.g. the number of accidents, reports on the inability to work of employees issued by health insurances) which are analysed on a regular basis. The assessments made in the year 2020 provided information on a good achievement of these objectives.
OLB offers its employees numerous career and development options. Externally offered advanced and further training options as well as inhouse training sessions are available to all employees. This ensures that employees are involved in sustainable topics. Likewise, the Bank supports its employees when they enrol in advanced training in parallel to performing their occupation (training to become a banking specialist and banking administration specialist or Bachelor and Master studies). Applicable guidelines provide for both financial and intangible support.
Strategic succession plans are made and needs for advanced training are determined in annual discussions between the department of Human Resources and the officers of the Banks. In addition, top performers and staff with top potentials are identified systematically.
The average age of all actively employed staff members (not including trainees) of OLB was 45 years at the end of 2020. The age group between 45 and 54 years was most strongly represented in the Bank.
The Bank permanently analyses the achievement of its targets and its risks and does so, in particular, when it determines business objectives while analyzing their impact on the qualification of employees. It determines both the risks arising from the business activity (e.g. consulting and sale of bank products), from business relationships (e.g. bank clients such as private clients, corporate clients or private banking clients) and from our services (e.g. financing advice, insurances or investment types). The operational losses / risks found systemically in the past (e.g. due to court decisions or damage arising from consulting) provide indications for future risk classifications for certain measures. No essential risks can be found which might have serious negative effects on the qualification of employees.

Key Performance Indicators to criteria 14 to 16

Key Performance Indicator GRI SRS-403-9: Work-related injuries
The reporting organization shall report the following information:

a. For all employees:
i. The number and rate of fatalities as a result of work-related injury;
ii. The number and rate of high-consequence work-related injuries (excluding fatalities);
iii. The number and rate of recordable work-related injuries;
iv. The main types of work-related injury;
v. The number of hours worked.

b. For all workers who are not employees but whose work and/or workplace is controlled by the organization:
i. The number and rate of fatalities as a result of work-related injury;
ii. The number and rate of high-consequence work-related injuries (excluding fatalities);
iii. The number and rate of recordable work-related injuries;
iv. The main types of work-related injury;
v. The number of hours worked.

You will find the remaining numbers c-g of the indicator SRS 403-9 in the GRI standard and may additionally report them here.

Key Performance Indicator GRI SRS-403-10: Work-related ill health
The reporting organization shall report the following information:

a. For all employees:
i. The number of fatalities as a result of work-related ill health;
ii. The number of cases of recordable work-related ill health;
iii. The main types of work-related ill health.
b. For all workers who are not employees but whose work and/or workplace is controlled by the organization:
i. The number of fatalities as a result of work-related ill health;
ii. The number of cases of recordable work-related ill health;
iii. The main types of work-related ill health.

You will find the remaining numbers c-e of the indicator SRS 403-10 in the GRI standard and may additionally report them here.

In the year 2020, OLB was informed of 23 accidents that had been reported to the professional association. This number of accidents consists of 18 commuting or traffic accidents and five other accidents (for example contusions, bruising, stumbling or cutting damage). No accidents occurred during corporate sports offers and none were caused by the working conditions.
A great reduction of (commuting) accidents can be reported for 2020 since many employees worked from home. The causes and reasons for work accidents and illnesses of employees are generally not recorded based on individual reports and are thus unknown. Anonymised reports about the inability to work of employees as issued by health insurances gave no indications for concrete health risks in the Bank’s operation.

Key Performance Indicator GRI SRS-403-4: Worker participation on occupational health and safety
The reporting organization shall report the following information for employees and for workers who are not employees but whose work and/or workplace is controlled by the organization:

a. A description of the processes for worker participation and consultation in the development, implementation, and evaluation of the occupational health and safety management system, and for providing access to and communicating relevant information on occupational health and safety to workers.

b. Where formal joint management–worker health and safety committees exist, a description of their responsibilities, meeting frequency, decision-making authority, and whether and, if so, why any workers are not represented by these committees.

OLB concluded agreements with the Works Council on topics of health and safety “Trust-Based Working Time“ and “Home Office Workplaces“ or “Overload Protection“. Furthermore, it agreed on the processes and approaches of the Corporate Inclusion Management and the offers and actions belonging to the corporate health management with the executive bodies. Any changes regarding their successful implementation, regarding inabilities to work, the re-integration of employees in the workplace or qualifications are regularly discussed with the executive bodies and in committees. Meetings of the occupational health committee in which employee representatives take part are held at least on a quarterly basis and the locations, corporate physicians and officers for occupational safety from all over Germany are involved in such meetings. Employee representatives took part in the OLB crisis unit at all times in 2020 and such unit held meetings almost every week on the subject of health protection in the pandemic and on the impacts on the working conditions of employees.

Key Performance Indicator GRI SRS-404-1: Average hours of training
The reporting organization shall report the following information:

a. Average hours of training that the organization’s employees have undertaken during the reporting period, by:
i. gender;
ii. employee category.

OLB employed 2,019 active employees (not including the Board of Directors, employees in the passive phase of their part-time retirement, employees suffering from long-time illnesses, staff exempted from work, employees in maternal / paternal leave, trainees and interns) on the reporting date of 31 December 2020. In addition, 169 trainees and interns were active for OLB at that time. The number of seminar days in the entire OLB stood at 1,630 days and 275.5 webinar days, that means an average of 0.9 seminar and webinar days per active employees (incl. trainees) (which corresponds to 6.9 hours) and per year. The digital offer was expanded in the reporting period to 100 e-trainings with an average of 50 minutes of required work.

Key Performance Indicator GRI SRS-405-1: Diversity
The reporting organization shall report the following information:

a. Percentage of individuals within the organization’s governance bodies in each of the following diversity categories:
i. Gender;
ii. Age group: under 30 years old, 30-50 years old, over 50 years old;
iii. Other indicators of diversity where relevant (such as minority or vulnerable groups).

b. Percentage of employees per employee category in each of the following diversity categories:
i. Gender;
ii. Age group: under 30 years old, 30-50 years old, over 50 years old;
iii. Other indicators of diversity where relevant (such as minority or vulnerable groups).

OLB’s Supervisory Board consists of 12 members as of 31 December 2020 [see OLB Supervisory Board].
Structure of the Supervisory Board:
  total male female
< 30 years - - -
30-50 years 41.7 % 25.0 % 16.7 %
> 50 years 58.3 % 58.3 % -


Structure of the 2.019 active employees:
  total male female
< 25 years 86 53 33
25 - 34 years 346 140 206
35 - 44 years 474 224 250
45 - 54 years 618 316 302
55 - 64 years 489 272 217
> 65 years 6 3

1,381 employees (68 %) of the 2,019 active employees worked full time on the reporting date of 31 December 2020, 638 of them (32 %) worked part time for the company. 925 of the employees working full time were men (67 %) and 456 (33 %) of them were female. 83 (13 %) of the employees working part-time were men and 555 (87 %) were women.

Key Performance Indicator GRI SRS-406-1: Incidents of discrimination
The reporting organization shall report the following information:

a. Total number of incidents of discrimination during the reporting period.

b. Status of the incidents and actions taken with reference to the following:
i. Incident reviewed by the organization;
ii. Remediation plans being implemented;
iii. Remediation plans that have been implemented, with results reviewed through routine internal management review processes;
iv. Incident no longer subject to action.

No discrimination is tolerated pursuant to OLB’s Code of Conduct and such is subject to punishment, in case of need. No cases of discrimination were reported in the year under review.

17. Human Rights

The company discloses what measures it takes, strategies it pursues and targets it sets for itself and for the supply chain for ensuring that human rights are respected globally and that forced and child labour as well as all forms of exploitation are prevented. Information should also be provided on the results of the measures and on any relevant risks.

Respecting and protection human rights and a strict rejection of any type of forced labour, child labour and exploitation are a matter of cause for OLB as a company and for its employees. Legal provisions applicable in its domestic market of Germany will always be complied with by the Bank. OLB has normally very trusting and long-term relations to its clients, business partners or service providers. It also expects compliance with the applicable provisions under highest standards from its clients, business partners and service providers. Any violation of human rights would not be tolerated by OLB. No such incident has occurred so far in OLB.
OLB has not prepared its own concept on human rights for reasons of materiality and it does not plan on preparing it at the time of preparation hereof. The respect and protection of human rights is nonetheless deeply rooted in OLB’s company culture, in particular in its Code of Conduct. OLB is convinced that good Corporate Governance is not restricted to the compliance with certain standards, but is positively influenced by the company culture and the personal integrity of persons bearing responsibility for the company. It is, therefore, very important for the Bank to raise the awareness for this topic among its employees.
This is ensured, inter alia, by the Code of Conduct which applies to all staff members of OLB. OLB’s Code of Conduct is approved by the entire Board of Directors and is available on OLB’ homepage in the “Investor Relations“ segment [see OLB Code of Conduct]. In the year under review, OLB completely revised the design of its Code of Conduct, closely verified its contents and included more precise statements wherever required. The Code of Conduct is one essential basic element for the values that OLB lives every day and is to be considered as the minimum standard for the conduct of all employees of the Bank. The Code of Conduct and its compliance is reviewed in a work group consisting of representatives of Compliance, Human Resources and Communication, Legal, Internal Audit and the office of the Board of Directors in case of need, however at least once per year. OLB supports and respects the protection of human rights and ensures that it will not cooperate in any violation of human rights, it protects the freedom of association and the effective recognition of the right to conduct collective negotiations; in addition, OLB supports the elimination of all forms of forced labour and the actual abolition of child labour. Likewise, it supports the elimination of discrimination during recruitment and employment.
Against the backdrop of national and international guidelines, sanctions, embargos or similar restrictions which govern OLB, new contract partners must be verified prior to the conclusion of any agreements on the basis of the intra-bank guideline for the assessment of contract partners.
OLB considers human rights as a specifically sensitive topic among the “Social Areas“ of the ESG criteria which are worthy of being protected. The Bank would incur an operational risk from violations such as, in particular the financing of projects, which endanger or abuse human rights. The operational risk is for OLB the risk of a direct or indirect loss or loss of reputation caused by an inadequacy or failure of its internal processes, by humans or systems or due to external events. OLB pursues the strategy of primarily avoiding operational risks or reducing existing operational risks. OLB’s instrument for managing operational risks comprises an internal risk capital model based on scenario analyses. Risk indicators support the management of operational risks.
No essentials risks which might have a negative effect on the compliance with human rights in OLB’s business activities could be found on this basis by the Bank. Therefore, OLB considers itself as being compliant with human rights in its business activities.

Key Performance Indicators to criteria 17

Key Performance Indicator GRI SRS-412-3: Investment agreements subject to human rights screenings
The reporting organization shall report the following information:

a. Total number and percentage of significant investment agreements and contracts that include human rights clauses or that underwent human rights screening.

b. The definition used for ‘significant investment agreements’.

The business activities performed by OLB are in compliance with the legal provisions applicable in Germany and thus with the highest standards in relation to the protection of human rights and the prohibition of forced and child labour and any type of exploitation on an international level. Therefore, OLB considers any disclosures on the total number of investment agreements containing clauses on human rights and on those which were audited for human rights aspects as being irrelevant for the purposes hereof.

Key Performance Indicator GRI SRS-412-1: Operations subject to human rights reviews
The reporting organization shall report the following information:

a. Total number and percentage of operations that have been subject to human rights reviews or human rights impact assessments, by country.

All of OLB’s business locations are based in Germany. They are subject to the legal provisions applicable in Germany and thus the highest standards in relation to the compliance with human rights and the prohibition of forced and child labour or any form of exploitation on an international level. Therefore, OLB considers it irrelevant to inform about the total number of business locations in which the compliance with human rights was verified or in which a human rights impact assessment was performed.

Key Performance Indicator GRI SRS-414-1: New suppliers subject to social screening
The reporting organization shall report the following information:

a. Percentage of new suppliers that were screened using social criteria.

The suppliers engaged by OLB are mainly from Germany and the remaining number of suppliers is based in OECD countries. They are thus subject to internationally applicable standards in relation to the compliance with human rights and the prohibition of forced or child labour or any type of exploitation. Therefore, OLB considers it irrelevant to name any new suppliers here which were audited on the basis of social criteria.

Key Performance Indicator GRI SRS-414-2: Social impacts in the supply chain
The reporting organization shall report the following information:

a. Number of suppliers assessed for social impacts.

b. Number of suppliers identified as having significant actual and potential negative social impacts.

c. Significant actual and potential negative social impacts identified in the supply chain.

d. Percentage of suppliers identified as having significant actual and potential negative social impacts with which improvements were agreed upon as a result of assessment.

e. Percentage of suppliers identified as having significant actual and potential negative social impacts with which relationships were terminated as a result of assessment, and why.

OLB learned of no actual or potential effects relating to human rights in its supply chain during the reporting year which would have caused the need for an in-depth verification or any entrepreneurial consequences.
For reasons of relevancy, OLB thus did not consider targeted audits as being necessary and, accordingly, refrained from auditing any of its suppliers.

18. Corporate Citizenship

The company discloses how it contributes to corporate citizenship in the regions in which it conducts its core business activities.

OLB’s business strategy comprises the objective to perform activities that are sustainable under ecological and social aspects. Therefore, it has, for many years now, been strongly active in community work. It is, one the one hand, a top employer and one of the large companies offering training for apprentices and it is, on the other hand, a committed promotor and sponsor for projects from most different fields. The vast majority of the projects is performed by charitable organisations and relates to youth, culture and social matters. On regular occasions during the year, the Bank analyses whether it lives up to the claim of its social commitment or whether new objectives or a new funding focus should be agreed upon. OLB and its foundation supported about 450 projects with a total volume of more than EUR 800,000 in the year 2020. This included donations of more than EUR 43,000. The sums mentioned herein implicitly include the funding granted by the Bankhaus Neelmeyer brand. No support was granted in the reporting year in the name of the Wüstenrot Bank brand. OLB’s commitment in the field of support and sponsoring is, at the same time, a preventive measure against potential reputational risks.
The total amount of funding fell compared with the year before, (previous year: EUR 1.1 million), however, the number of funded projects went up (previous year: more than 300 projects). Reason for this development is, on the one hand, the restrictions caused by the Corona virus pandemic which applied in the course of the year and which impaired or prevented the performance of projects. On the other hand, OLB-Stiftung performed two special actions in the year 2020 (“150.000 gute Gründe für die Jugend“ (150,000 good reasons for young people) and “Corona Soforthilfe“ (Immediate Corona Relief)) which ensured the support of numerous projects. These and many other funds granted to charitable organisations are provided mainly from the net proceeds of the “OLB Glückssparen“ (Happy Savings) project, for the grant of which OLB-Stiftung, being the carrier of OLB Glückssparen, observes the “Geschäftsordnung für Förderungen aus Reinerträgen des OLB Glückssparens“ (Rules of Procedure for Funding Made from Earnings of OLB Glückssparen). OLB-Stiftung was founded on the occasion of OLB’s 125th anniversary in 1994 with the purpose of promoting culture, science and the protection of the environment within the region. The work of the Foundation focusses on projects initiated by the Foundation which emphasis the strength of the Weser-Ems region and which give new ideas and impetus to the development of the North Western region of Germany. 
In 2020, OLB-Stiftung performed the eleventh tender for the OLB Wissenschaftspreis (Science Price). The most excellent works submitted by state-recognised universities and technical colleges will be awarded prices totalling EUR 28,000 in 2021. This award has the highest prize money of its type in the North West of German and is considered a recognised contribution to promoting the science region North West. The Board of Directors of OLB-Stiftung which also includes one member of OLB’s Board of Directors is informed about all funded projects on a regular basis. Science and research specifically for the federal state of Bremen are promoted at Bankhaus Neelmeyer through the Peter Franz Neelmeyer-Stiftung (Foundation). This foundation was founded in 2004 to strengthen and provide focussed support for the sciences at the location of the Bankhaus Neelmeyer in Bremen.
In addition to the funding activities, universities and technical colleges of the Weser-Ems region and in Bremen are supported by the Deutschlandstipendium (German Scholarship) and schools receive assistance in the training of applicants. The Bank also welcomes any honourable commitment of their employees who are active in many associations.
Sponsoring projects of a commercial nature must be financed from the Bank’s own funds as a PR action. Applications for such funds can be submitted to the Corporate Communication department. OLB’s Board of Directors is regularly informed about and involved in essential activities. The funding of sponsoring projects is prohibited under the Bank’s guidelines during relevant offer phases and when concrete steps are taken to initiate transactions, during recent conclusions of contracts and during ongoing tender and bidding processes. This is verified by the Internal Audit department of OLB in regular intervals. The compliance with internal guidelines and existing documents is verified on the basis of spot checks. Audits of the financial statements of foundations are performed by external auditing bodies.
Persons interested in establishing foundations can benefit from OLB’s decades of experience in working as a foundation and are supported professionally and with trust on their path to establishing a foundation. The charitable OLB-Treuhandstiftung Weser-Ems (Trust Foundation) offers the option to pursue dedicated foundation purposes through endowments under this umbrella foundation. Suitable projects are found in the region through a cooperation in the Foundation’s Advisory Board and the founder’s intentions will be implemented in an effective manner. This option might also be offered through Peter-Franz-Neelmeyer-Stiftung (Foundation) as umbrella foundation.
In 2020, it proved impossible to perform the dedicated risk analysis in relation to social matters which the Bank had planned. But, it still plans to do it. All available internal capacities were needed otherwise on account of the higher and changing requirements caused by the Corona virus pandemic. The Bank currently verifies the involved areas and the responsibilities for an implementation.

Key Performance Indicators to criteria 18

Key Performance Indicator GRI SRS-201-1: Direct economic value generated and distributed
The reporting organization shall report the following information:

a. Direct economic value generated and distributed (EVG&D) on an accruals basis, including the basic components for the organization’s global operations as listed below. If data are presented on a cash basis, report the justification for this decision in addition to reporting the following basic components:
i. Direct economic value generated: revenues;
ii. Economic value distributed: operating costs, employee wages and benefits, payments to providers of capital, payments to government by country, and community investments;
iii. Economic value retained: ‘direct economic value generated’ less ‘economic value distributed’.

b. Where significant, report EVG&D separately at country, regional, or market levels, and the criteria used for defining significance.

Balance sheet figures (as of: 31 Dec. 2020) in million Euros
Total assets: 21,475.2
Own Equity: 1,157.2
Customer loan portfolio 15,540.9
Customer deposits 13,011.4
Performance indicators (as of: 31 Dec. 2020) in million Euros
Net interest income 336.3
Net commission income 113.3
Risk provisions for lending business 30.7
Personnel and other general administrative expenses 281.3
Profit before taxes 114.9
Distributed values (as of: 31 Dec. 2020) in million Euros
Personnel expenses 173.2
of which wages and salaries 143.4
of which social security and expenses 29.8
of which pension provisions 8.0
Other taxes (as of: 31 Dec. 2020) in million Euros
Income tax 35.4
Other taxes 0.8
Obligation to deposit protection and market stabilization schemes 6.9
Deposit protection 5.6 
Bank supervision (ECB and BaFin) 0.5
More information is available on the Internet at OLB Financial Reports.  

19. Political Influence

All significant input relating to legislative procedures, all entries in lobby lists, all significant payments of membership fees, all contributions to governments as well as all donations to political parties and politicians should be disclosed by country in a differentiated way.

OLB is member in the Bundesverband deutscher Banken e. V. (Association of German Banks, registered association), which is the key organisation representing its interests and through which submissions for legislative procedures can be made.
It is also member, inter alia, of the local Chambers of Industry and Commerce and the Förderverein Wirtschaft pro Metropolregion e. V. (Association Promoting the Economy for the Metropolis Region, registered association). In addition to obligatory memberships, the Bank also pursues memberships for social or business reasons which are set out in internal guidelines.
According to its claim for independence, OLB is not interested in any intensive networking or influence on a political level. Any payments and contributions to political parties in the name of OLB always require the explicit approval of the competent Board of Directors and no such payments were made in the year 2020. Whenever employees wish to actively engage in political activities, OLB recognises this commitment but also requests that such activities be performed exclusively in the employee’s private environment.

Key Performance Indicators to criteria 19

Key Performance Indicator GRI SRS-415-1: Political contributions
The reporting organization shall report the following information:

a. Total monetary value of financial and in-kind political contributions made directly and indirectly by the organization by country and recipient/beneficiary.

b. If applicable, how the monetary value of in-kind contributions was estimated.

In 2020, OLB made no donations to any political parties or political institutions.

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.

OLB attaches great importance to legally compliant conduct and, for this purpose, established an independent Compliance department some years ago which reports to the Board of Directors. Employees of this department advice the Board, the officers and employees of OLB regarding the compliance with legal requirements. The chairman of the Board was responsible for the risk management to prevent money laundering and terrorist financing and for complying with the provisions relevant for anti-money laundering pursuant to Sec. 4 (3) of the GwG [Anti-Money Laundering Act] during the reporting year. The entire Board of Directors is responsible for compliance in terms of the fulfilment of laws and standards applicable to OLB.
OLB’s compliance management system generally pursues the objective that all employees observe the laws and regulations applicable to their work environment as well as the internal instructions and guidelines of which they have been informed. Employees are requested to show an honest and fair conduct in their work environment, to show respect and integrity and to avoid any type of conflict between private and professional interests. OLB has no other objectives going beyond those above.
In detail, the Compliance function has implemented principles, means and processes to avoid unlawful conduct and corruption which comprise, inter alia, the performance of risk analyses. They are used annually to identify the risks which exist in terms of money laundering, terrorist financing and other punishable activities in any bank and the requirements under the Securities Trading and Anti-Corruption Act and to determine the risks existing in OLB by taking into account existing processes and risk mitigation measures. Furthermore, measures are derived on this basis to reduce potential risks. In 2020, the Bank defined adequate measures for all analyzed potential risks (e.g. violations of sanctions, violations against anti-money laundering regulations, legal violations against the WpHG (German Securities Trading Act)) in order to further reduce the risk. No new risks were found in the field of corruption. Existing measures still seem adequate.
In addition, the Compliance department published not only a Code of Conduct but also further Compliance directives and an anti-corruption guideline for all employees. These regulations provide that the Compliance function must approve any acceptance and grant of gifts and invitations beginning with a general value of EUR 40. In addition, the Compliance function is involved in the selection of business partners as part of the verification process regarding existing anti-corruption regulations. No cases of corruption occurred in the reporting period. No fines or other penalties were imposed on OLB or its employees based on corruption allegations.
Any and all employees are informed about the existing requirements through compliance and anti-corruption guidelines which are published in all parts of the company. The Compliance function performs periodic training measures in form of web-based trainings and seminars with personal attendance and also publishes current topics in a Compliance newsletter for all employees. That contributes actively to the preservation and improvement of a Compliance culture in the company. Insofar as any violations are found, such are punished by adequate disciplinary measures.
In order to provide employees of OLB with the option of being able to report to an independent body any anomalies which might exist regarding any unlawful behaviors, different channels have been established through which such information can be transmitted to the Compliance function – also in an anonymized form (whistle-blower system). Compliance will receive such information, regardless of its contents, and will take care of a clarification of the matter – by safeguarding the anonymity of the reporter, as far as possible.

Key Performance Indicators to criteria 20

Key Performance Indicator GRI SRS-205-1: Operations assesed for risks related to corruption
The reporting organization shall report the following information:

a. Total number and percentage of operations assessed for risks related to corruption.

b. Significant risks related to corruption identified through the risk assessment.

Any audits conducted by the Compliance department take into account any and all locations (= 100 % of 76 locations) of OLB and its contractually bound brokers; no risks were identified in these.

Key Performance Indicator GRI SRS-205-3: Incidents of corruption
Die berichtende Organisation muss über folgende Informationen berichten:

a. Total number and nature of confirmed incidents of corruption.

b. Total number of confirmed incidents in which employees were dismissed or disciplined for corruption.

c. Total number of confirmed incidents when contracts with business partners were terminated or not renewed due to violations related to corruption.

d. Public legal cases regarding corruption brought against the organization or its employees during the reporting period and the outcomes of such cases.

No cases of corruption occurred in the reporting period.

Key Performance Indicator GRI SRS-419-1: Non-compliance with laws and regulations
The reporting organization shall report the following information:

a. Significant fines and non-monetary sanctions for non-compliance with laws and/or regulations in the social and economic area in terms of:
i. total monetary value of significant fines;
ii. total number of non-monetary sanctions;
iii. cases brought through dispute resolution mechanisms.

b. If the organization has not identified any non-compliance with laws and/or regulations, a brief statement of this fact is sufficient.

c. The context against which significant fines and non-monetary sanctions were incurred.

In the year 2020, no fines or other penalties were imposed on OLB or its employees due to any allegations of corruption.