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.