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.