Compliance
For NORD/LB and its employees, ethical behaviour with integrity is highly valued. The bank's compliance department is committed to protecting applicable laws and complying with market-specific guidelines. Responsible actions play an important role here, which is part of the bank's self-image.
Living integrity: Compliance management at NORD/LB
At NORD/LB, we see compliance as an indispensable component of responsible corporate governance. Our Compliance Management System (CMS) ensures that all legal and regulatory requirements as well as internal standards are consistently adhered to. It is based on the basic elements of an effective CMS in accordance with IDW PS 980: compliance culture, objectives, risk analysis, programme, organisation, communication and monitoring.
NORD/LB's CMS includes binding requirements such as the Code of Conduct and the Corporate Compliance Policy, which apply to all employees. These form the framework for guidelines, work instructions and processes that ensure a clear structure and uniform standards.
Implementation takes place along the lines of defence: the first line is responsible for operational compliance, while the second line – Compliance & Security – ensures monitoring and further development. In addition, training, regular inspections and reports to the Board of Management and other bodies of the Bank ensure transparency and effectiveness.
A central principle of our CMS is anchoring at the highest level: All policies and guidelines are approved by the Management Board of NORD/LB. In this way, we ensure that legal requirements and ethical principles are complied with in all business processes – for the sustainable success of the company and the trust of our customers and our partners.
Values and Goals
We are shaping a future worth living. As a financial partner, we are taking this path together with our customers and creating value. Our strategy and our self-image are based on responsible, transparent and credible cooperation with our customers, shareholders, investors and in other business relationships as well as the public.
Our core values: Ambitious, sustainable, human.
Our Code of Conduct
The principles of conduct laid down in our Code of Conduct are intended to provide guidance for our daily actions. With consistent observance, we contribute to combining our standards of compliance with law and order with ethically correct behaviour and thus linking entrepreneurial success with social responsibility. This applies to the Management Board as well as to all managers and employees of the NORD/LB Group.
Download: Code of Conduct (PDF)
![[Translate to English:] Mann mit Pfeilen rot und grün in der Hand, die sich auf einander zu bewegen.](/fileadmin/redaktion/Compliance/Bilder/Bild_Interessenkonflikte.jpeg)
Interessenkonflikte und politische Einflussnahme
NORD/LB has a comprehensive policy on conflict of interest management that applies to all employees, managers and members of the Management Board and Supervisory Board. The aim is to avoid situations in which personal or political interests could collide with the interests of the bank – or even the appearance of such a conflict arises.
This also includes political relationships and influence: If elected officials or related persons are appointed to or hold political office, clear disclosure and reporting obligations as well as internal control mechanisms apply. Compliance with legal and regulatory requirements is ensured by organizational measures, transparency and advice through compliance. In this way, we at NORD/LB ensure that decisions are made independently and exclusively in the interests of the clientele and the company.
Data protection
Data protection is an integral part of our corporate governance. We have clear governance structures in place to ensure responsible governance and monitoring of all data protection activities. The Board of Directors receives regular formalized reports on the relevant data protection issues.
All employees also undergo mandatory data protection training and are sensitized to the secure handling of personal data through regular internal awareness campaigns. In addition, we continuously conduct data protection impact assessments, risk analyses, and internal audits and reviews to ensure the effectiveness of our measures.
At NORD/LB, we have established a process for reporting and dealing with possible data breaches in order to ensure transparency and a rapid response.
Money laundering
One of the central tasks of NORD/LB's compliance function is compliance with legal and regulatory requirements for the prevention and combating of money laundering and terrorist financing. In doing so, we take into account not only national laws and regulatory requirements, but also internationally recognized standards. These include, in particular, the recommendations of the Financial Action Task Force (FATF) and the Wolfsberg Anti-Money Laundering Principles, which serve as authoritative guidelines for effective and responsible action.
Embargoes and sanctions
NORD/LB is committed to strict compliance with all applicable legal and regulatory requirements in the area of embargoes and sanctions. We ensure that our business activities do not violate national or international sanctions lists, embargo regulations or other restrictive measures. To this end, we use comprehensive review processes and control mechanisms to identify risks at an early stage and act in accordance with the rules.
Fraud / Bribery / Corruption
NORD/LB is committed to acting with integrity and responsibility in all its business activities. Preventing and combating bribery and corruption is our top priority. We are strongly committed to identifying risks at an early stage and consistently preventing violations. Our actions are based on the applicable legal and regulatory requirements as well as internal guidelines that set strict standards for transparency and fairness. In addition, we are guided by internationally recognized standards and best practices to ensure that our business activities meet the highest compliance requirements at all times.
With these measures, NORD/LB underlines its clear commitment to integrity and adherence to ethical principles – for the trust of our customers, business partners and the public.
Whistleblowing / whistleblowing system
Compliance with legal regulations, regulatory requirements and internal guidelines is a top priority for NORD/LB. Only through consistent compliance with the rules can we minimize risks and avert damage to our company, our employees and business partners. Misconduct must be detected at an early stage, dealt with and remedied immediately. That is why we operate an independent and confidential whistleblower system that is open to all employees and external partners.
Information can be submitted at any time and in any language. The system guarantees the greatest possible protection for whistleblowers and those affected. Investigations are only carried out after careful examination and in compliance with the highest confidentiality in a fair and transparent process. We also offer the option of anonymous reporting and ensure that whistleblowers who do not abuse the system will not be disadvantaged. The presumption of innocence applies to all parties involved until a violation is proven. Potential violations of our Code of Conduct, including serious risks or human rights and environmental violations in the supply chain, can also be reported through the whistleblowing system. In this way, we ensure that necessary measures to end or minimise risks are taken immediately.
Cybersecurity / Information Security
With the increasing digital networking of business and society, cyber security and resilience against cyber risks are becoming increasingly important. As part of the critical infrastructure, NORD/LB has a special responsibility to protect not only its own information, systems and premises, but also the data of our customers and partners.
Cyber security is a key trust factor for us and thus an essential part of our competitiveness. Cyber and information security risks are managed within clearly defined governance structures and are the responsibility of the Chief Information Security Officer (CISO). Regular formal reports to the Board of Directors ensure that cyber risks are assessed and managed at the highest level. To promote a high level of security awareness, we conduct mandatory cybersecurity training for all employees and check the effectiveness of our measures through regular internal audits. For dealing with security incidents, NORD/LB has a binding incident management guideline as well as clearly defined processes that ensure a quick and effective response. In addition, external audits and audits ensure compliance with the highest regulatory and industry-specific standards. A comprehensive disaster recovery plan guarantees that we can recover our systems and data in a timely manner in the event of an emergency. Our management systems thus underscore our commitment to robust and future-proof information security.
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