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.

The public perceives Rentenbank in a special way due to its promotional mandate. It is absolutely crucial that all committees’ and employees’ conduct is impeccable for the Bank to succeed. This is based upon a culture of compliance which is actively embraced by the Management Board and all employees, and complemented by monitoring processes to prevent unlawful conduct. Rentenbank has a zero-tolerance approach to corruption, fraud and other criminal activities as part of its approach (objective: 0 incidents), and it sanctions offences with disciplinary measures and, if necessary, criminal proceedings. This objective has always been attained in the last few years.

Public Corporate Governance Code
As Rentenbank recognises that effective corporate governance is very important and demands the utmost integrity from all those involved in these activities, Rentenbank’s Supervisory Board adopted the Public Corporate Governance Code (version as of 30 June 2009) that was approved by the federal government on 16 July 2009. Rentenbank’s Management and Supervisory Boards identify with and recognise the principles of the PCGK. Any deviations from the principles of the PCGK are disclosed and explained in the declaration of conformity on an annual basis. 

Codes of conduct
Rentenbank has produced a code of conduct for all employees. This forms the cornerstone of a legally-compliant and ethically-oriented, sustainable corporate culture and is further supplemented by specific policies for preventing criminal activities or accepting gifts and invitations. Employees can access all relevant policies posted on the Bank’s intranet. In the event of criminal activity or misconduct, employees can approach their line managers or the Compliance or Money Laundering Officers in confidence or, if preferred, anonymously via an external ombudsman. Members of the Management Board are subject to a special code of conduct. This includes key principles relating to conflicts of interest, regulations about the giving and receiving of gifts and invitations, presentations, trading on the financial markets, as well as sideline activities and honorary positions.

Prevention of money laundering and other criminal activities
The Bank has appointed a Money Laundering Officer to prevent money laundering, terrorist financing and other criminal activities. The Money Laundering Officer reports directly to the Management Board. They produce a risk analysis on the aforementioned issues on an annual basis and assess the risks associated with clients and business partners as well as risks related to products, processes and transactions.

Carrying out identity checks of contractual partners (know-your-customer principle) is one of the most important parts of complying with the diligence obligations required within anti-money laundering regulations. We abide by all the relevant procedures and processes required. In this regard, Rentenbank’s special business model as a promotional bank in Germany and Europe and the allocation of loans in line with the principle of using local banks in order to mitigate risk are taken into account.

Employees and people of a comparable role are expected to report anything suspicious or potential breaches to money laundering obligations to the Money Laundering Officer, or get in touch with the ombudsman for Rentenbank while retaining the confidentiality of their identity. Suspected cases of money laundering are submitted immediately by the Money Laundering Officer to the Financial Intelligence Unit of the Central Customs Authority (Germany). We are not aware of any breaches due to money laundering, terrorist financing and other criminal activities in 2020.

Data protection
Rentenbank implements the legal requirement of General Data Protection Regulation (GDPR) and the Federal Data Protection Act. New starts are required to comply with these standards. Our appointed data protection officer is the spokesperson and contact person for any matters relating to data protection, and reports directly to the Management Board.

Employee training
The Bank is heightening awareness among its employees about the important provisions through regular compulsory training sessions, especially regarding money laundering, fraud prevention, data protection and information security. Participation is monitored. In addition, regular employee training sessions on topics ranging from current developments/methodology to precautionary instructions take place.

Additional controls
Over and above the regular monitoring activities undertaken by the Compliance and Money Laundering Officers, Internal Audit and external autonomous auditing companies also carry out annual checks. An exact description of how Rentenbank organises its risk management can be found in the Management Report within our Annual Report.

Risks
Risks arise during the approval of loans and grants as well as in the procuring of or granting of contracts. Due to our on-lending through local banks, almost all of Rentenbank’s business partners are credit institutions based in Germany or Europe. Therefore, minimal risk may generally be assumed.