Governance with Sustainability-Related Aspects
NORD/LB aligns its governance with legal requirements, regulatory requirements and internal policies. This framework describes responsibilities, decision-making pathways and control mechanisms and is embedded in the Bank's business and risk management.
Anti-Greenwashing at NORD/LB
Sustainability communications must be clear, substantiated and transparent. The binding framework for this is provided by the internal Anti-Greenwashing Governance. The Governance must be applied across all business areas and is reviewed annually and, where necessary, updated to reflect new regulatory developments. Employees are supported through awareness-raising measures, training and internal communication guidelines. The Fair Advertising Policy sets out the principles of fair advertising in greater detail: statements must be factually accurate, clear, complete and not misleading, while sustainability claims must be truthful, substantiated and consistent. Vague wording, exaggeration, selective presentation and generic environmental claims should be avoided. Suspected cases must be escalated through the designated reporting channels, namely Fraud Prevention Management or Compliance.
NORD/LB's Corporate Governance Framework
Our Governance Framework in the Interests of Our Stakeholders.
We have robust corporate governance based on clear responsibilities, transparent decision-making processes and effective control mechanisms. As an institution under public law, we align our corporate governance with legal and regulatory requirements and internal policies. Reliable structures support responsible and sustainability-oriented corporate governance. This is based on clearly defined governing bodies and committees, in particular the Owners' Meeting, Supervisory Board and Managing Board, clearly delineated responsibilities, and a policy and control framework shaped by supervisory requirements, including the German Banking Act (KWG), MaRisk and relevant EBA Guidelines. The following description summarises the key provisions of the State Treaty, the Statutes and the Rules of Procedure. It shows how responsibilities, reporting obligations, committees, control mechanisms and the involvement of the Managing Board and Supervisory Board in strategic and risk-related matters are structured. This provides transparency on how NORD/LB addresses the requirements for sound internal governance under European and national supervision.
The following core areas of corporate governance:
- Internal management governance:
Strengthening organisational structures and decision-making mechanisms for the proper overall management of NORD/LB. - Position Governance:
Transparent roles and consistent responsibilities; accountability based on clear authorisations and qualifications of the Managing Board and Supervisory Board that are appropriate in terms of expertise and responsibilities. - Governance (Board, Branch & Committees):
Proper establishment, operation and documentation of decision-making bodies, with a focus on individual accountability. - Policy Governance:
Maintaining an appropriate policy framework to support the control environment (e.g. Rules of Procedure of the Supervisory Board, Managing Board and committees). - Legal entity management:
Oversight of significant changes to the organisational structure and shareholdings (e.g. matters subject to fundamental or approval reservations by the Owners' Meeting/Supervisory Board).
Normative governance framework:
- State Treaty
- Statutes of NORD/LB
- Rules of Procedure: Supervisory Board (GO AR), Presidential& Nomination Committee (GO PNA), Remuneration Control Committee (GO VKA), Risk Committee (GO RisikoA), AuditCommittee (GO PrüfA), Managing Board (GO Board)
- Essential legal regulations:
- German Banking Act (KWG), in particular §§ 25a–25d
- MaRisk (BaFin Circular 06/2024)
- EBAL Guidelines on Internal Governance and Fitness Assessment
Declaration on the German Corporate Governance Code (CGC) of NORD/LB
The German Corporate Governance Code contains nationally and internationally recognised standards for good and trustworthy corporate governance. Its purpose is to promote the confidence of investors, customers, employees and the public in the management and supervision of a company. Due to its legal form as an institution under public law, the Code is not legally binding on NORD/LB. Nevertheless, transparency and reliable corporate governance are essential elements of our self-understanding. NORD/LB therefore follows the recommendations and suggestions of the Code voluntarily, insofar as this is possible and appropriate within its legal form and ownership structure.
ESG firmly embedded - The ESG Governance Framework of NORD/LB
As a bank, we take the requirements associated with a sustainability-oriented transformation of the economy into account in our business and risk management. NORD/LB's ESG Governance Framework provides transparency on the structures, roles, processes and instruments used to embed ESG within the Bank. It supports the management and further development of the ESG organisation and provides guidance for internal and external stakeholders. This underlines NORD/LB's aim to integrate sustainability-related aspects into its organisation in a structured, transparent and responsible manner.
Our Commitment & Memberships
NORD/LB has endorsed the ten principles of the UN Global Compact relating to human rights, labour standards, environmental protection and anti-corruption and reflects these principles in internal policies, including the Transformation Guidelines. In doing so, the Bank establishes a framework to support responsible conduct in its business and operational activities and to systematically consider ESG-related risks and requirements.
